3-i 

CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT

TABLE OF CONTENTS 

3.1 INTRODUCTION ........................................................................................................... 3-1

3.1.1 Definitions............................................................................................................ 3-1

3.1.1.1 Ballast Efficacy Factor ............................................................................. 3-1

3.1.1.2 Ballast Luminous Efficiency .................................................................... 3-1

3.1.1.3 Fluorescent Lamp..................................................................................... 3-2

3.1.1.4 Fluorescent Lamp Ballast ........................................................................ 3-3

3.1.2 Replacement Ballast............................................................................................. 3-3

3.2 MARKET ASSESSMENT .............................................................................................. 3-4

3.2.1 Trade Associations ............................................................................................... 3-4

3.2.2 Manufacturers and Market Share ......................................................................... 3-5

3.2.2.1 Small Businesses ...................................................................................... 3-5

3.2.3 Regulatory Programs ........................................................................................... 3-6

3.2.3.1 Federal Energy Conservation Standards .................................................. 3-6

3.2.3.2 California Energy Commission................................................................ 3-9

3.2.3.3 Canadian Energy Efficiency Standards ................................................... 3-9

3.2.3.4 European Energy Efficiency Standards ................................................. 3-11

3.2.4 Non-Regulatory Initiatives................................................................................. 3-11

3.2.4.1 Federal Energy Management Program .................................................. 3-11

3.2.4.2 Consortium for Energy Efficiency ......................................................... 3-12

3.2.4.3 NEMA Premium .................................................................................... 3-13

3.2.4.4 ENERGY STAR .................................................................................... 3-13

3.2.4.5 Energy Efficient Commercial Building Deduction ................................ 3-14

3.2.4.6 Northeast Energy Efficiency Partnerships ............................................. 3-14

3.2.5 Historical Shipments .......................................................................................... 3-14

3.3 TECHNOLOGY ASSESSMENT .................................................................................. 3-21

3.3.1 Basic Structure of Fluorescent Lamps ............................................................... 3-21

3.3.2 Electrical Characteristics of a Fluorescent Discharge Lamp ............................. 3-22

3.3.3 Fluorescent Lamp Ballast Overview .................................................................. 3-23

3.3.3.1 Starting Method ..................................................................................... 3-24

3.3.3.2 Ballast Factor ......................................................................................... 3-25

3.3.3.3 Ballast Efficacy Factor ........................................................................... 3-25

3.3.3.4 Ballast Luminous Efficiency .................................................................. 3-25

3.3.3.5 Power Factor .......................................................................................... 3-26

3.3.3.6 Total Harmonic Distortion ..................................................................... 3-26

3.3.3.7 Electromagnetic Interference ................................................................. 3-27

3.3.3.8 Safety ..................................................................................................... 3-27

3.3.4 Fluorescent Lamp Ballast Technology Options ................................................. 3-28

3.3.4.1 Magnetic Ballasts ................................................................................... 3-28

3.3.4.2 Electronic Ballasts ................................................................................. 3-29

3.3.4.3 Improved Components ........................................................................... 3-32

3.3.4.4 Improved Circuit Design........................................................................ 3-33
3-ii

3.4 PRODUCT CLASSES ................................................................................................... 3-34

3.4.1 Power versus Efficiency Relationship ............................................................... 3-35

3.4.2 Starting Method ................................................................................................. 3-36

3.4.3 Lumen Package .................................................................................................. 3-36

3.4.4 Sign Ballasts....................................................................................................... 3-37

3.4.5 Product Classes .................................................................................................. 3-37

REFERENCES .......................................................................................................................... 3-39

LIST OF TABLES

Table 3.2.1 EPCA Standards for Fluorescent Lamp Ballasts ...................................................... 3-6

Table 3.2.2 2000 Ballast Rule Standards for Fluorescent Lamp Ballasts .................................... 3-7

Table 3.2.3 EPACT 2005 Standards for Fluorescent Lamp Ballasts ........................................... 3-8

Table 3.2.4 Canadian Standards for Fluorescent Lamp Ballasts ............................................... 3-10

Table 3.2.5 Federal Energy Management Program Efficiency Recommendation .................... 3-12

Table 3.2.6 CEE High-Performance T8 Ballast Specifications ................................................. 3-12

Table 3.2.7 CEE Reduced Wattage T8 Ballast Specifications .................................................. 3-13

Table 3.2.8 Shipments of Four-Foot T8 MBP and Two-Foot T8 U-Shaped Ballasts and Lamps 

and Four-Foot T12 MBP and Two-Foot U-Shaped Ballasts and Lamps ................................... 3-17

Table 3.2.9 Shipments of Eight-Foot Slimline T8 and Eight-Foot SP Slimline T12 Ballasts and 

Lamps ......................................................................................................................................... 3-18

Table 3.2.10 T12 High-Output Ballast Market Share ................................................................ 3-19

Table 3.3.1 Common Linear Fluorescent Lamp Nomenclature ................................................ 3-22

Table 3.3.2 Basic Building Blocks of a Fixed-Light Output Fluorescent Lamp Ballast and 

Associated Characteristics ......................................................................................................... 3-30

Table 3.4.1 EPCA Product Classes Established by NAECA 1988 for Fluorescent Lamp Ballasts

.................................................................................................................................................... 3-35

Table 3.4.2 EPCA Product Classes Established by EPACT 2005 for Fluorescent Lamp Ballasts 3-

35

Table 3.4.3 Product Classes for Fluorescent Lamp Ballasts ...................................................... 3-38

LIST OF FIGURES

Figure 3.2.1 2005 Ballast Market Share .................................................................................... 3-15

Figure 3.2.2 Magnetic and Electronic Ballast Market Share ..................................................... 3-16

Figure 3.2.3 Shipments of Ballasts that Operate Four-Foot MBP Lamps ................................. 3-17

Figure 3.2.4 Shipments of Eight-Foot Slimline T8 and Eight-Foot SP Slimline T12 Ballasts . 3-18

Figure 3.2.5 Shipments of Residential Ballasts ......................................................................... 3-20

Figure 3.2.6 Shipments of T5 High-Output Ballasts ................................................................. 3-21

Figure 3.3.1 Electrical Characteristic of a Gas Discharge Lamp ............................................... 3-23

Figure 3.3.2 Cutaway View of a Typical Magnetic Fluorescent Ballast ................................... 3-28
3-iii

Figure 3.3.3 Fluorescent Lamp Efficacy vs. Operating Frequency of Lamp ............................ 3-29

Figure 3.3.4 Cutaway View of an Electronic Fluorescent Ballast ............................................. 3-30

Figure 3.3.5 Fixed-Light Output Electronic Fluorescent Ballast Block Diagram ..................... 3-30
3-1 

CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT

3.1 INTRODUCTION

This chapter consists of three sections: the market assessment, the technology 

assessment, and product classes. The market assessment provides an overall picture of the 

market for the products concerned, including the nature of the products, industry structure, and 

manufacturer market shares; regulatory and non-regulatory efficiency improvement programs; 

and market trends and quantities of products sold. The technology assessment identifies a list of 

technologies to consider in the screening analysis. The product classes section discusses the 

product classes the U.S. Department of Energy (DOE) considered using for this rulemaking and 

how they were developed. 

The information DOE gathers from the market and technology assessment serves as 

resource material for use throughout the rulemaking. DOE considers both quantitative and 

qualitative information from publicly available sources and interested parties. 

3.1.1 Definitions

Section 321 of the Energy Policy and Conservation Act (EPCA) contains definitions for 

fluorescent lamp ballast and associated terms. DOE codified in the Code of Federal Regulations 

(CFR) the statutory definitions and definitions of supplementary terms for fluorescent lamp 

ballasts in 10 CFR 430.2. Appendix 3A lists these terms and their definitions. 

As part of this energy conservation standards rulemaking, DOE is considering extending 

coverage to additional fluorescent lamp ballasts. (42 U.S.C. 6295(g)(7)(B)) The following 

sections describe in more detail the definitions in EPCA for fluorescent lamp ballasts and note 

DOE’s interpretation of the definitions. Please see the notice of proposed rulemaking (NOPR) 

Federal Register notice for this rulemaking for more discussion on DOE’s consideration of 

additional fluorescent lamp ballasts and its interpretation of EPCA’s definitions. 

3.1.1.1 Ballast Efficacy Factor 

Section 321(30)(A) of EPCA (42 U.S.C. 6291(30)(A)) defines ballast efficacy factor 

(BEF) as:

Ballast efficacy factor means the relative light output divided by the power input of a 

fluorescent lamp ballast, as measured under test conditions specified in ANSI Standard 

C82.2–1984. 

3.1.1.2 Ballast Luminous Efficiency

In the fluorescent lamp ballast active mode test procedure supplementary notice of 

proposed rulemaking (SNOPR), DOE proposed a new metric for describing the performance of a 

fluorescent lamp ballast called ballast luminous efficiency (BLE). After the effective date of any 

standards promulgated by this fluorescent lamp ballast standards rulemaking, ballasts would be 

tested using the new BLE procedure, not the existing procedure which measures ballast efficacy 
3-2 

factor (BEF) procedure. Information on the active mode test procedure can be found on DOE’s 

website.a

Ballast luminous efficiency BLE means the total fluorescent lamp arc power divided by 

the fluorescent lamp ballast input power multiplied by the appropriate frequency adjustment 

factor. BLE describes the percentage of ballast input power that is used in the lamp column to 

produce light. Power delivered to the lamp cathodes (filaments) is not included in the output 

measurement and is considered a ballast loss. This percentage is then multiplied by a frequency 

adjustment factor depending on the frequency at which a ballast operates a lamp. Low-frequency 

operation of a lamp produces fewer lumens per lamp arc watt than high-frequency operation, so 

DOE uses an adjustment factor to account for the decrease in system efficacy. In general, the 

BLE metric results in reduced measurement variation, reduced testing burden, and a more 

straightforward efficiency metric than the existing BEF metric and test procedure.

3.1.1.3 Fluorescent Lamp

10 CFR 430.2 defines a fluorescent lamp as:

Fluorescent lamp means a low pressure mercury electric-discharge source in which a 

fluorescing coating transforms some of the ultraviolet energy generated by the mercury 

discharge into light, including only the following: 

(1) any straight-shaped lamp (commonly referred to as 4-foot medium bipin lamps) 

with medium bipin bases of nominal overall length of 48 inches and rated wattage 

of 25 or more; 

(2) any U-shaped lamp (commonly referred to as 2-foot U-shaped lamps) with 

medium bipin bases of nominal overall length between 22 and 25 inches and rated 

wattage of 25 or more; 

(3) any rapid start lamp (commonly referred to as 8-foot high output lamps) with 

recessed double contact (RDC) bases of nominal overall length of 96 inches; 

(4) any instant start lamp (commonly referred to as 8-foot slimline lamps) with single 

pin bases of nominal overall length of 96 inches and rated wattage of 52 or more; 

(5) any straight-shaped lamp (commonly referred to as 4-foot miniature bipin 

standard output lamps) with miniature bipin bases of nominal overall length 

between 45 and 48 inches and rated wattage of 26 or more; and 

(6) any straight-shaped lamp (commonly referred to 4-foot miniature bipin high 

output lamps) with miniature bipin bases of nominal overall length between 45 

and 48 inches and rated wattage of 49 or more. 

This definition reflects the version adopted in the final rule for general service fluorescent 

lamps (the 2009 Lamps Rule).b

 74 FR 34080, 34176-77 (July 14, 2009). 

 

a DOE’s website for fluorescent lamp ballasts can be found at 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballasts.html. 
3-3 

3.1.1.4 Fluorescent Lamp Ballast 

Fluorescent lamp ballast means a device that is used to start and operate fluorescent 

lamps by providing a starting voltage and current and limiting the current during normal 

operation. 

 As part of this rulemaking, under the authority of 42 U.S.C. 6295(i)(5), DOE is proposing 

extending coverage to additional fluorescent lamp ballasts. In the NOPR Federal Register notice, 

DOE proposes to extend coverage to the following list of fluorescent lamp ballasts:

(1) ballasts that operate 4-foot medium bipin lamps with a rated wattagec of 25 watts 

(W) or more and an input voltage at or between 120 volts (V) and 277V; 

(2) ballasts that operate 2-foot medium bipin U-shaped lamps with a rated wattage of 

25W or more and an input voltage at or between 120V and 277V; 

(3) ballasts that operate 8-foot high output lamps with an input voltage at or between 

120V and 277V; 

(4) ballasts that operate 8-foot slimline lamps with a rated wattage of 52W or more 

and an input voltage at or between 120V and 277V; 

(5) ballasts that operate 4-foot miniature bipin standard output lamps with a rated 

wattage of 26W or more and an input voltage at or between 120V and 277V; 

(6) ballasts that operate 4-foot miniature bipin high output lamps with a rated wattage 

of 49W or more and an input voltage at or between 120V and 277V; 

(7) ballasts that operate 4-foot medium bipin lamps with a rated wattage of 25W or 

more, an input voltage at or between 120V and 277V, a power factor (PF) of less 

than 0.90, and that are designed and labeled for use in residential applications; 

and

(8) ballasts that operate 8-foot high output lamps with an input voltage at or between 

120V and 277V, that operate at ambient temperatures of 20 °F or less and are 

used in outdoor signs. 

DOE is not proposing to expand the scope of coverage to include dimming ballasts 

beyond those which are already covered. The Energy Policy Act of 2005 (EPACT 2005) 

promulgated standards for dimming ballasts that operate certain energy saver lamps (one or two 

F34T12, two F96T12/ES, or two F96T12HO/ES).d

 

3.1.2 Replacement Ballast

Replacement ballast means a ballast that 

 

b

 The 2009 Lamps Rule was published in the Federal Register on July 14, 2009 and is available at

http://www1.eere.energy.gov/buildings/appliance_standards/residential/incandescent_lamps.html c The 2009 Lamps Rule adopted a new definition for rated wattage that can be found in 10 CFR 430.2.

d The standards promulgated by EPACT 2005 contained exemptions for ballasts designed for dimming to 50 percent 

or less of its maximum output. However, these exemptions expired for ballasts manufactured after July 1, 2010 and 

sold by the manufacturer on or after October 1, 2010. 10 CFR 430.32(m)(6) and (m)(7). 
3-4 

(1) is designed for use to replace an existing fluorescent lamp ballast in a previously 

installed luminaire;

(2) is marked “FOR REPLACEMENT USE ONLY”;

(3) is shipped by the manufacturer in packages containing not more than 10 

fluorescent lamp ballasts; and

(4) has output leads that when fully extended are a total length that is less than the 

length of the lamp with which the ballast is intended to be operated. 

3.2 MARKET ASSESSMENT

The following market assessment identifies the manufacturer trade association and 

domestic manufacturers of fluorescent lamp ballasts; discusses manufacturer market share, 

regulatory programs, and non-regulatory initiatives; defines product classes; provides historical 

shipment data, shipment projections, and equipment lifetime estimates; and summarizes market 

performance data.

3.2.1 Trade Associations 

The National Electrical Manufacturers Association (NEMA) is the trade association for 

fluorescent lamp ballasts. NEMA’s Lighting Systems Division is one of eight product divisions. 

The division’s 47 member companies comprise 85-95 percent of the U.S. commercial and 

industrial market, as well as large portions of the institutional and educational markets.1 In 

addition to ballasts, NEMA’s Lighting Systems Division also oversees products such as 

fluorescent lamps, emergency lighting, lighting controls, luminaires, solid state lighting, and 

other emerging lighting technologies. NEMA provides an organization through which 

manufacturers of lighting equipment can work together on projects that affect their industry and 

business. NEMA’s activities relating to energy efficiency include2

• “[a]dvising the DOE and executive agencies on lighting research and market 

transformation needs; 

• engaging in legislative work on energy and lighting issues;

• monitoring energy-efficiency rulemakings and standards affecting lighting products by 

federal and state agencies;

• promoting the national voluntary luminaire rating and information program under the 

National Lighting Collaborative; 

• supporting adoption of 1999 ASHRAE/IESNA 90.1 lighting provisions; 

• working with market transformation and environmental groups to advance market use of 

energy-efficient lighting technologies; 

• advising DOE and the U.S. Environmental Protection Agency (EPA) on ENERGY STAR 

Buildings and ENERGY STAR voluntary product labeling programs; and 
3-5 

• advocating market-based approaches to enhance the use and penetration of energyefficient technologies.”

3.2.2 Manufacturers and Market Share

The following list contains the names of manufacturers that produce fluorescent lamp ballasts: 

• Acuity Brands 

Lighting 

• Advance Transformer

• American Ballast

• Antron Compact 

Electronics

• Axis Technologies 

• Ballast Wise

• Bodine 

• CEW

• Cooper Lighting

• EBW Electronics

• Espen Technology, 

Inc.

• Etlin-Daniels

• Fulham 

• France

• General Electric 

Consumer & 

Industrial 

• Hatch Transformer

• Holophane 

• Howard Industries

• Iota Engineering

• Keystone 

Technologies

• Lamar Lighting

• SOLA Ballasts

• Lighting Components 

• Lightolier

• Lutron Electronics 

Company, Inc.

• MaxLite

• OSRAM Sylvania

• Pacific Lighting and 

Electric

• PQL

• Radionic 

• Robertson Worldwide 

• Sage Lighting Ltd.

• SLI Lighting

• Sunpark Electronics 

Corp. 

• Superior Lamps, Inc.

• TCP

• Ultrasave Lighting 

Ltd.

• Universal Lighting 

Technologies

• Ventex

• Venture Lighting 

International 

• Wide-Lite

Four manufacturers hold the majority of the domestic market share of fluorescent lamp ballasts 

• GE Consumer and Industrial of General Electric, Inc. (hereafter, “GE”)

• OSRAM Sylvania of Siemens AG (hereafter “Osram Sylvania”)

• Advance Transformer of Philips Lighting (hereafter “Philips”)

• Universal Lighting Technologies (hereafter “Universal”).

 The lighting divisions of some of these companies also manufacture other products, such 

as fluorescent lamps, high intensity discharge lamps, light emitting diodes (LEDs), and compact 

fluorescent lamps (CFLs). 

3.2.2.1 Small Businesses

Small businesses may be particularly affected by the promulgation of minimum energy 

conservation standards for fluorescent lamp ballasts. The Small Business Administration (SBA) 

lists small business size standards that are matched to industries as they are described in the 

North American Industry Classification System (NAICS). A size standard is the largest that a 

for-profit concern can be and still qualify as a small business for Federal Government programs. 

These size standards are generally the average annual receipts or the average employment of a 

firm. For fluorescent lamp ballasts, the size standard is matched to NAICS code 335311, Power, 
3-6 

Distribution, & Specialty Transformer Manufacturing, which has a size standard of 750 

employees or fewer.3

DOE studies the potential impacts on these small businesses in detail as part of the 

manufacturer impact analysis.

3.2.3 Regulatory Programs

Several Federal and international regulatory programs affect the markets for fluorescent 

lamp ballasts. The following section summarizes U.S., Canadian, and European regulatory 

initiatives relevant to the ballasts covered by this rulemaking. While the following discussion is 

not exhaustive in describing all regulatory action related to fluorescent lamp ballasts, it provides 

detail on some notable initiatives that characterize recent developments in the lighting market.

3.2.3.1 Federal Energy Conservation Standards 

EPCA (42 U.S.C. 6291–6309) established an energy conservation program for major 

household appliances. Additional amendments to EPCA gave DOE the authority to regulate the 

energy efficiency of several products, including certain fluorescent lamp ballasts. Amendments 

to EPCA in the National Appliance Energy Conservation Amendments of 1988 (NAECA 1988), 

Pub. L.100357, established energy conservation standards for fluorescent lamp ballasts.e

 (42 

U.S.C. 6295(g)(5)) The standards promulgated by NAECA 1988 can be found in Table 3.2.1. 

These amendments also required that DOE (1) conduct two rulemaking cycles to determine 

whether these standards should be amended; and (2) for each rulemaking cycle, determine 

whether the standards in effect for fluorescent lamp ballasts should be amended so that they 

would be applicable to additional fluorescent lamp ballasts. (42 U.S.C. 6295(g)(7)(A)(B)) 

Table 3.2.1 EPCA Standards for Fluorescent Lamp Ballasts 

Application for Operation of

Ballast Input 

Voltage

V

Total Nominal 

Lamp Watts

W

Ballast Efficacy 

Factor

One F40T12 Lamp 120 40 1.805

277 40 1.805

Two F40T12 Lamps 120 80 1.060

277 80 1.050

Two F96T12 Lamps 120 150 0.570

277 150 0.570

Two F96 T12 High Output 

(HO) Lamps

120 220 0.390

277 220 0.390

 

e

 Ballasts are used primarily in the commercial and industrial sectors. While Part B includes a range of consumer 

products that are used primarily in the residential sector, such as refrigerators, dishwashers, and clothes washers, 

Part B also includes several products used primarily in the commercial sector, including fluorescent lamp ballasts. 

(Part C of Title III – Certain Industrial Equipment, codified in the U.S. Code as Part A-1, concerns products used 

primarily in the commercial and industrial sectors, such as electric motors and pumps, commercial refrigeration 

equipment, and packaged terminal air conditioners and heat pumps.) 
3-7 

On September 19, 2000, DOE published a final rule in the Federal Register that 

completed the first of the two rulemaking cycles to evaluate and amend the energy conservation 

standards for fluorescent lamp ballasts (hereafter “the 2000 Ballast Rule”). 65 FR 56740. This 

rulemaking established a consensus standard, representing an agreement between the fluorescent 

lamp ballast industry and energy-efficiency advocacy organizations. The standard levels DOE 

adopted replaced the ballast efficacy factors promulgated in NAECA 1988 for certain fluorescent 

lamp ballasts. The standard levels were intended to eliminate certain magnetic ballasts, which 

operate lamps at a line frequency of 60 Hertz (Hz), and are less efficient than electronic ballasts, 

which operate lamps at high frequency for ballasts that operate F40T12 and F96T12 lamps.f

Table 3.2.2 shows the standards codified by DOE. 10 CFR 430.32(m)(3) 

Table 3.2.2 2000 Ballast Rule Standards for Fluorescent Lamp Ballasts

Application for Operation of

Ballast Input 

Voltage

V

Total Nominal 

Lamp Watts

W

Ballast Efficacy 

Factor

One F40T12 Lamp 120 40 2.29

277 40 2.29

Two F40T12 Lamps 120 80 1.17

277 80 1.17

Two F96T12 Lamps 120 150 0.63

277 150 0.63

Two F96 T12 HO Lamps 120 220 0.39

277 220 0.39

Due to the language in the consensus standard that DOE adopted in the 2000 Ballast 

Rule, it was still be possible for manufacturers to produce and sell magnetic ballasts for certain 

types of fluorescent lamps. In response, Congress promulgated new energy conservation 

standards for certain fluorescent lamp ballasts under the EPACT 2005, Pub. L. 10958. (EPACT 

section 135(c)(2); codified at 42 U.S.C. 6295(g)(8)(A)). On October 18, 2005, DOE published a 

final rule in the Federal Register codifying those new fluorescent lamp ballast standards into the 

Code of Federal Regulations at 10 CFR 430.32(m). 70 FR 60407. These standards established 

minimum ballast efficacy requirements for “energy saver” versions of full-wattage ballasts, such

as the F34T12 ballast. Table 3.2.3 shows the standards prescribed by EPACT 2005. 10 CFR 

430.32(m)(5) 

 

f The standard level was intended to eliminate magnetic ballasts that operate one and two nominally 40W medium 

bipin lamps (F40T12) and two nominally 75W 8-foot T12 single pin slimline lamps (F96T12).
3-8 

Table 3.2.3 EPACT 2005 Standards for Fluorescent Lamp Ballasts 

Application for Operation of

Ballast Input 

Voltage

V

Total Nominal 

Lamp Watts

W

Ballast Efficacy 

Factor

One F34T12 Lamp 120 34 2.61

277 34 2.61

Two F34T12 Lamps 120 68 1.35

277 68 1.35

Two F96T12/ES Lamps 120 120 0.77

277 120 0.77

Two F96 T12 HO/ES Lamps 120 190 0.42

277 190 0.42

In summary, fluorescent lamp ballasts that are currently regulated under EPCA, as 

amended, include ballasts that are designed to operate one and two nominally 40W and 34W 4-

foot T12 medium bipin lamps (F40T12 and F34T12), two nominally 75W and 60W 8-foot T12 

single pin slimline lamps (F96T12 and F96T12/ES), and two nominally 110W and 95W 8-foot 

T12 RDC high output lamps (F96T12 and F96T12/ES) at nominal input voltages of 120 or 277 

volts with an input current frequency of 60 Hz and a power factor of 0.90 or greater. 10 CFR 

430.32(m). Ballasts that are excluded from regulation include (1) ballasts designed for dimming 

to 50 percent or less of its maximum output, (2) ballasts designed for use with two F96T12 high 

output (HO) lamps at ambient temperatures of 20 °F or less and for use in an outdoor sign or 

ballasts designed for use with two F96T12 HO/ES lamps at ambient temperatures of 20 °F or 

less and for use in an outdoor sign,g

 (3) ballasts with a power factor of less than 0.90 and 

designed and labeled for use only in residential building applications, and (4) replacement 

ballasts as defined in paragraph (m)(4)(ii).h These exemptions expired for ballasts designed to 

operate one or two F34T12, two F96T12/ES, or two F96T12HO/ES lamps for ballasts 

manufactured after July 1, 2010 and sold by the manufacturer on or after October 1, 2010. 10 

CFR 430.32(m)(2), (m)(4), and (m)(7). 

On December 19, 2007, the President signed the Energy Independence and Security Act 

of 2007 (EISA 2007) (Pub. L. 110140), which makes numerous amendments to EPCA and 

directs DOE to undertake several new rulemakings for appliance energy efficiency standards. 

EISA 2007 did not amend standards for fluorescent lamp ballasts, but instead directed DOE to 

amend its test procedure for fluorescent lamp ballasts to incorporate a measure of standby mode 

and off mode energy consumption by March 31, 2009. (42 U.S.C. 6295(gg)(2)(B)(ii)) In 

addition, pursuant to 42 U.S.C. 6295(o), DOE is directed to incorporate standby mode and off 

 

g In 10 CFR 430.32(m)(7), the temperature exemption granted under EPACT 2005 is slightly different than that 

contained in sections (m)(2) and (m)(4). In subsection (m)(7), ballasts designed for use with two F96T12HO/ES 

lamps at ambient temperatures “of 20°F or less” and designated for use in an outdoor sign are exempt from the 

standards in paragraph (m)(5). The other sections require the ballast to be for ambient temperatures of negative 20°F 

or less.

h The exclusion provided for replacement ballasts requires that they meet certain criteria to be considered a 

replacement ballast, such as being designed to replace an existing ballast in a previously installed luminaire and 

being marked “FOR REPLACEMENT USE ONLY.” This exclusion only applies to replacement ballasts 

manufactured on or before June 30, 2010. After that date, replacement ballasts will no longer be excluded. (10 CFR 

430.32(m)(4)(ii)(A)) See appendix A of this TSD for the exact language of the exclusion for replacement ballasts.
3-9 

mode energy use in any amended or new standard adopted after July 1, 2010. Because this 

energy conservation standards rulemaking for fluorescent lamp ballasts will be completed in 

2011, the requirement to incorporate standby mode energy use into the energy conservation 

standards analysis is applicable.

DOE published a final rule test procedure to comply with the standby mode and off mode 

energy use provisions from EISA 2007 that apply to fluorescent lamp ballasts that are (or could 

be) covered by this rulemaking. DOE stated in that final rule that standby mode energy use, as 

defined in EISA 2007,i

 is nonexistent for typical ballasts that operate on a switch or a motion 

sensor. DOE also stated that standby mode energy use is only applicable to ballasts with a 

lighting control system. One example of these new ballast designs is a DALIj-enabled ballast. 

DALI-enabled ballasts exhibit standby power, as they have internal circuitry that is integral to 

the design of the ballast that remains on and active, even when the ballast is not driving any 

lamps. DOE noted that fluorescent lamp ballasts never meet the definition of “off mode.” 

Pursuant to EPCA section 325(gg)(2)(A), 42 U.S.C. 6295(gg)(2)(A), DOE has 

considered whether to incorporate standby mode into a single amended or new metric. DOE is 

not proposing to include standby mode standards in this rulemaking. For more information, see 

the NOPR Federal Register notice.

3.2.3.2 California Energy Commission 

The California Energy Commission (CEC) specifies appliance standards that are 

“applicable as state law to the sale and offering for sale of appliances in California.”4 The current 

standards took effect on August 9, 2009. The new regulations updated standards to match the 

current federal energy conservation standards with one exception. The CEC regulations maintain 

the exemption for ballasts designed to operate one or two F34T12, two F96T12/ES, or two 

F96T12HO/ES lamps that: (1) ballasts designed for dimming to 50 percent or less of its 

maximum output, (2) ballasts designed for use with two F96T12 high output (HO) lamps at 

ambient temperatures of 20 °F or less and for use in an outdoor sign, and (3) ballasts with a 

power factor of less than 0.90 and designed and labeled for use only in residential building 

applications. 

3.2.3.3 Canadian Energy Efficiency Standards 

 

i

In amending 42 U.S.C. 6295(gg)(1)(a)(i), (ii), and (iii), section 310 of EISA 2007 defines “active mode,” “off 

mode,” and “standby mode” as follows: “The term ‘active mode’ means the condition in which an energy-using

product—(I) is connected to a main power source; (II) has been activated; and (III) provides 1 or more main 

functions.” “The term ‘off mode’ means the condition in which an energy-using product— (I) is connected to a main 

power source; and (II) is not providing any standby or active mode function.” “The term ‘standby mode’ means the 

condition in which an energy-using product (I) is connected to a main power source; and (II) offers 1 or more of the 

following user-oriented or protective functions: (aa) To facilitate the activation or deactivation of other functions 

(including active mode) by remote switch (including remote control), internal sensor, or timer. (bb) Continuous 

functions including information or status displays (including clocks) or sensor-based functions.”

j

DALI stands for Digital Addressable Lighting Interface, which is a system that enables communication between a 

central lighting controls system and the individual components, including the ballasts.
3-10 

The Natural Resources Canada (NRCan) Office of Energy Efficiency regulates the 

energy efficiency of fluorescent lamp ballasts in Canada. In 1992, Parliament passed the Energy 

Efficiency Act (S.C. 1992, c. 36), which concerns minimum performance levels for energy-using 

products, effective in February 1995. Fluorescent lamp ballasts were included in the first set of 

energy efficiency regulations, published in November 1994.5 An amendment published in April 

2003 updated Canada’s regulations to the minimum levels put forth in the 2000 Ballast Rule. It 

also proposed two effective dates: April 1, 2005 for new installations and April 1, 2010 for 

existing installations (replacement ballasts).6 Amendment 9, published in the Canadian Gazette

Part II on November 15, 2006, introduced standards for ballasts that operate energy-saving lamps 

and F32T8 lamps, modified the criteria for exempted ballasts, and repealed the effective date for 

fluorescent lamp ballasts.7 Table 3.2.48

 shows the current Canadian standards for fluorescent 

lamp ballasts. 

Table 3.2.4 Canadian Standards for Fluorescent Lamp Ballasts 

Application for Operation of

Ballast Input 

Voltage

V

Total Nominal 

Lamp Wattage |

W

Minimum Ballast 

Efficacy Factor

One F40T12 Lamp*

120 40 2.29

277 40 2.29

347 40 2.22

One F34T12 Lamp

120 34 2.61

277 34 2.61

347 34 2.53

Two F40T12 Lamps

120 80 1.17

277 80 1.17

347 80 1.12

Two F34T12 Lamps

120 68 1.35

277 68 1.35

347 68 1.29

Two F96T12(IS) Lamps**

120 150 0.63

277 150 0.63

347 150 0.62

Two F96T12(ES) Lamps

120 120 0.77

277 120 0.77

347 120 0.76

Two 110W F96T12 HO Lamps

120 220 0.390

277 220 0.390

347 220 0.380

Two F96T12 HO(ES) Lamps

120 190 0.42

277 190 0.42

347 190 0.41

Two F32T8 Lamps

120 64 1.250

277 64 1.230

347 64 1.200

*Also for use on 40W/48T10/RS lamps

**Also for use on 60W/96T12/IS lamps

The Canadian standards listed above apply to residential as well as commercial ballasts. 

Canadian standards consider an input voltage of 347V in addition to 120V and 277V, which is 

consistent with the Canadian electrical distribution network. Canadian standards also require a 
3-11 

minimum power factor of 0.9 (consistent with U.S. standards) for all ballasts except residential 

ballasts.

3.2.3.4 European Energy Efficiency Standards

Directive 2005/32/EC of the European Parliament and the Council of the European Union 

amended Council Directive 92/42/EEC and Directives 96/57/EC and 2000/55/EC to establish a 

framework for setting energy efficiency requirements for energy-using products. Energy 

efficiency standards for fluorescent lamp ballasts have yet to be published. 

3.2.4 Non-Regulatory Initiatives 

DOE reviewed several national, regional, and local voluntary programs that promote the 

use of energy efficient lighting in the United States. These include the Federal Energy 

Management Program’s (FEMP’s) program for energy efficient lighting, the Consortium for 

Energy Efficiency’s (CEE’s) High Performance Commercial Lighting Initiative, the ENERGY 

STAR Program, and the Northeast Energy Efficiency Partnership (NEEP). The following section 

summarizes some of these programs for the ballasts covered by this rulemaking. While it is not 

an exhaustive list, the discussion provides detail on some notable initiatives that characterize 

recent developments in the lighting market.

3.2.4.1 Federal Energy Management Program

FEMP helps Federal buyers identify and purchase energy efficient products including 

certain fluorescent ballasts. Section 161 of EPACT 1992 encourages energy efficient Federal 

procurement. Section 104 of EPACT 2005 requires that each agency incorporate energy 

efficiency criteria consistent with ENERGY STAR and FEMP-designated products for “...all 

procurements involving energy consuming products and systems, including guides 

specifications, project specifications, and construction, renovation, and service contracts that 

include provision of energy consuming products and systems, and into the factors for the 

evaluation of offers received for the procurement.” Executive Order 13123 and Federal 

Acquisition Regulation (FAR) section 23.704 direct agencies to purchase products in the upper 

25 percent of energy efficiency, including all models that qualify for the ENERGY STAR 

product labeling program. 64 FR 30851, 30854 (June 8, 1999). FEMP provides 

recommendations for how to buy energy efficient fluorescent ballasts, including the products 

shown in Table 3.2.5.

9

 FEMP offers buyers support tools such as efficiency guidelines, costeffectiveness examples, and a cost calculator. FEMP also offers training, on-site audits, 

demonstrations, and design assistance. 
3-12 

Table 3.2.5 Federal Energy Management Program Efficiency Recommendation

Lamp Type Number of 

Lamps Recommended BEF Best Available BEF

Four-Foot and U-Tube Lamps

T8, 32 Watts

1 2.54 or higher 3.00

2 1.44 or higher 1.54

3 0.93 or higher 1.06

4 0.73 or higher 0.79

T12, 34 Watts

1 2.64 or higher 3.05

2 1.41 or higher 1.53

3 0.93 or higher 0.95

Eight-Foot Lamps

T8, 59 Watts 2 0.80 or higher 0.81

T12, 60 Watts 2 0.80 or higher 0.80

3.2.4.2 Consortium for Energy Efficiency

CEE has both a Residential Lighting Initiative and a High-Performance Commercial 

Lighting Initiative. CEE launched its commercial lighting initiative in November 2004 to help 

identify and select energy efficient commercial lighting products and practices. Initial efforts 

focused on designating high-performance T8 lighting products. In January 2007, the initiative 

was expanded to include reduced-wattage T8 products. Table 3.2.6 and Table 3.2.7 summarize 

CEE’s specifications for high-performance and reduced-wattage T8 ballasts.

Table 3.2.6 CEE High-Performance T8 Ballast Specifications10

Instant Start Ballast

Lamps Low BF

BF≤ 0.85

Normal BF

0.85<BF<1.0

High BF

BF≥1.01

1 ≥ 3.08 ≥ 3.11 ≥ 3.03

2 ≥ 1.60 ≥ 1.58 ≥ 1.55

3 ≥ 1.04 ≥ 1.05 ≥ 1.04

4 ≥ 0.79 ≥ 0.80 ≥ 0.77

6 N/A N/A ≥ 0.52

Programmed Rapid Start Ballast

1 ≥ 2.84 ≥ 2.84 ≥ 2.95

2 ≥ 1.48 ≥ 1.47 ≥ 1.51

3 ≥ 0.97 ≥ 1.00 ≥ 1.00

4 ≥ 0.76 ≥ 0.75 ≥ 0.75

6 N/A N/A ≥ 0.50

Ballast Frequency 20 to 33 kHz or ≥ 40 kHz, Power Factor ≥ 0.90, Total Harmonic Distortion ≤ 

20%

 
3-13 

Table 3.2.7 CEE Reduced Wattage T8 Ballast Specifications11

Instant Start Ballast, 28W Systems

Lamps All BF Ranges

1 ≥ 3.52

2 ≥ 1.76

3 ≥ 1.16

4 ≥ 0.88

Instant Start Ballast, 25W Systems

1 ≥ 3.95

2 ≥ 1.98

3 ≥ 1.32

4 ≥ 0.99

Ballast Frequency 20 to 33 kHz or ≥ 40 kHz, Power Factor ≥ 0.90, Total 

Harmonic Distortion ≤ 20%

CEE created separate standards for normal wattage T8 ballasts based on ballast factor, 

which compares the ratio of light output of lamps operated by a specific ballast to the light 

output of the same lamps operated by a standard reference ballast. However, CEE chose not to 

create standards by ballast factor for reduced-wattage ballasts. Additionally, CEE did not specify 

performance based on input voltage. CEE’s specifications state that multi-voltage ballasts must 

meet or exceed the listed BEF when operating on at least one of the intended operating voltages. 

3.2.4.3 NEMA Premium

NEMA maintains a labeling program for “NEMA Premium” ballasts based on CEE’s 

specifications for high-efficiency 4-foot T8 ballasts. The program is intended to promote energy 

efficiency and assist end-users in identifying the most efficient ballasts on the market.12 As of 

July 2010, NEMA’s website indicates that fluorescent lamp ballasts manufactured by Acuity 

Brands Lighting, Cooper Lighting,, Espen Technologies, GE, Hatch Transformers Inc., 

Holophane an Acuity Brands Company, Keystone Technologies, Philips Lighting Electronics 

North America, Osram Sylvania, Robertson Worldwide, Sunpark Electronics Corp., and 

Universal Lighting Technologies all qualify for the NEMA Premium label.

The NEMA Premium label for fluorescent lamp ballasts is similar to NEMA’s existing 

program for motors. In November 2004, NEMA released state-level shipment data that showed 

an increase in NEMA Premium motor shipments of 30 percent between 2001 and 2002 and 14 

percent between 2002 and 2003.13

3.2.4.4 ENERGY STAR

ENERGY STAR is a joint program of DOE and the Environmental Protection Agency 

(EPA) designed to protect the environment by promoting energy efficient products and 

practices.14 ENERGY STAR specifies criteria for residential lighting fixtures, which contain 

three parts: a lamp, a ballast, and the fixture that holds the lamp and ballast. Products that qualify 

for the ENERGY STAR label may not use magnetic ballasts in indoor fixtures. The ENERGY 

STAR specifications also define criteria for lamp start time, power factor, lamp current crest 

factor, ballast operating temperature, electromagnetic interference, frequency, transient 

protection, end of life protection, dimming, and safety.15
3-14 

3.2.4.5 Energy Efficient Commercial Building Deduction

EPACT 2005 created the Energy Efficient Commercial Buildings Deduction (26 U.S.C 

179D), which established a tax deduction for building owners who incur expenses for energy 

efficiency upgrades. Effective for property in service from January 1, 2006 through December 

31, 2008, the deduction allows partial deductions for improvements in interior lighting. Though 

the statute does not specify required lamp types or efficacies, it does call for an overall reduction 

in lighting power density (to qualify the lighting power density must be below the minimum 

required by the ASHRAE/IES 90.1), and specifically, encourages the use of higher-performance 

and reduced-wattage fluorescent lamps. The Emergency Economic Stabilization Act of 2008 

(HR-1424), approved and signed on October 3, 2008, extends the benefits of EPACT 2005 

through December 31, 2013. 

3.2.4.6 Northeast Energy Efficiency Partnerships

NEEP is a regional nonprofit organization that promotes energy efficiency in the 

Northeast. NEEP runs a High Efficiency Commercial Lighting Initiative to “achieve costeffective energy and demand by overcoming market barriers to the availability and widespread 

market adoption of advanced T8 fluorescent lighting systems.”16 NEEP coordinates with 

multiple local and state governments, utilities, and other initiatives, such as Efficiency Vermontk

and the Long Island Power Authority, to promote efficient lighting products.17, 18 

3.2.5 Historical Shipments

Awareness of annual product shipment trends is an important aspect of the market 

assessment and the development of the standards rulemaking. For this rulemaking, DOE used 

publicly available ballast shipments from the U.S. Census from 1990 to 2005.19 DOE also 

obtained confidential shipments from NEMA for 2007. 

DOE used this data for three main purposes. First, the shipment data and market trend 

information contributed to the shipments analysis and base-case forecast for ballasts (chapter 10 

of the NOPR TSD). By using historical shipment data and expert opinion on market trends and 

calibrating forecast assumptions with recent data, DOE believes it has based the shipments 

model and base-case forecasts on a sound dataset. Second, DOE used the data to select the 

representative product classes and representative units for analysis. Generally, DOE selected 

product classes and units to reflect the highest volume, most common ballast types used in the 

United States today (chapter 5 of the NOPR TSD). Third, DOE used the data to develop the 

installed stock of ballasts for the national impact analysis (chapter 11 of the NOPR TSD). Based 

on its understanding of trends in the market, DOE estimated how the market would respond to 

various efficiency levels.

The historical shipment data for ballasts is broken down into many subcategories 

beginning with magnetic versus electronic type ballasts. Under each technology type, the 

 

k Efficiency Vermont offers technical assistance and financial incentives to encourage energy efficiency in Vermont. 

This organization offers rebates of $10 for the upgrade to or installation of High Performance T8 systems.
3-15 

shipments are categorized by a variety of characteristics. Commercial and residential ballasts are 

delineated by corrected versus uncorrected power factor (section 3.3.3.5). Ballasts are also 

defined by starting method (section 3.3.3.1), maximum number of lamps driven (one, two, three, 

or four), lamp wattage, lamp diameter, and a few additional specific characteristics. Based on 

interviews with ballast manufacturers, DOE learned that the U.S. Census data represents about 

90 percent of T8 and T5 shipments and about 70 percent of T12 electronic shipments. DOE also 

learned that the U.S. Census does not include shipment data for major residential ballasts or 

dimming ballasts. The Census data also does not provide shipments for every permutation of 

ballast performance characteristics, but does provide data for establishing trends for the major 

categories. Ballasts that operate T8 lamps comprised the majority of shipments in 2005. These 

are followed (in order of 2005 unit sales) by T12 ballasts, compact fluorescent lamp ballasts, T5 

ballasts, and other small subsets. 

Figure 3.2.1 depicts the ballast market based on shipments reported to the U.S. Census in 

2005. 

Figure 3.2.1 2005 Ballast Market Share

In 2005, corrected power-factor (commercial) magnetic ballasts were not broken out into 

smaller categories for shipments reporting. DOE used subcategory unit shipment proportions 

from the 2000 corrected power-factor magnetic ballast category to extrapolate the disaggregation 

of shipments for 2005. This estimation provided data points for 4- and 8-foot magnetic T12 

ballasts as well as 8-foot HO magnetic T12 ballasts. The 2005 U.S. Census Data also did not 

report magnetic residential and linear dimming ballast shipments. To estimate magnetic 

residential ballast shipments, DOE extended the linear decline in magnetic residential ballasts 

from 2002-2004 to extrapolate a value for 2005. DOE used a similar approach to estimate linear 

dimming ballast shipments.
3-16 

Electronic ballasts have slowly replaced magnetic ballasts, as seen in Figure 3.2.2. In 1990, 

magnetic ballasts represented about 96 percent of shipments, while the 2005 magnetic ballast 

market share dropped to 27 percent. This trend was in part due to energy conservation standards 

for T12 ballasts. The most recent energy conservation standards for fluorescent lamp ballasts 

effectively eliminated the sale of 4-foot T12 medium bipin (MBP), 2-foot T12 U-shaped, and 8-

foot T12 slimline magnetic ballasts. The standard began to go into effect for certain 4-foot T12 

MBP, 8-foot T12 slimline ballasts, and 8-foot HO ballasts in 2005. The final phase of the 

standard became effective in 2010, when replacement 4-foot T12 MBP, 8-foot T12 single pin 

(SP) slimline, and 8-foot HO magnetic ballasts will no longer be sold. (10 CFR 430.32(m)(4)(ii) 

and 430.32(m)(5)-(6)) 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

1989 1991 1993 1995 1997 1999 2001 2003 2005

Market Share

Year

Magnetic

Electronic

Figure 3.2.2 Magnetic and Electronic Ballast Market Share

The vast majority of 4-foot T12 MBP and 2-foot T12 U-shaped ballasts are magnetic 

(about 77 percent of the T12 market in 2005), and the vast majority of 4-foot T8 MBP and 2-foot 

T8 U-shaped ballasts are electronic (about 97 percent of T8 ballast shipments in 2005). 

Therefore, the decline in magnetic ballasts mirrors a decline in T12 ballast shipments. Similarly, 

the increase in electronic ballasts mirrors an increase in 4-foot T8 MBP and 2-foot T8 U-shaped 

ballast shipments. Figure 3.2.3 and Table 3.2.8 show these shipment trends. The trend in ballast 

shipments is followed by similar trends in 4-foot T8 MBP and 2-foot T8 U-shaped lamp 

shipments and 4-foot T12 MBP and 2-foot T12 U-shaped lamp shipments. DOE received general 

service fluorescent lamp historical shipments from NEMA from 2001 to 2005.20 Based on 

conversations with manufacturers, DOE believes these trends continue beyond 2005. 
3-17 

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

45,000

50,000

1994 1996 1998 2000 2002 2004 2006

Shipments

Year

T8s

T12s

Figure 3.2.3 Shipments of Ballasts that Operate Four-Foot MBP Lamps

Table 3.2.8 Shipments of Four-Foot T8 MBP and Two-Foot T8 U-Shaped Ballasts and 

Lamps and Four-Foot T12 MBP and Two-Foot U-Shaped Ballasts and Lamps

Unit Sales by Year

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005

Four-Foot 

T12 

Ballast

(D) (D) 27,227 27,704 26,395 24,463 (D) (D) (D) (D) 11,218

Four-Foot 

T8 Ballast 23,965 22,317 28,032 30,883 32,488 40,179 44,700 44,215 43,219 45,727 45,951

Four-Foot 

T8 Lamp (D) (D) (D) (D) (D) (D) 172,143 170,416 179,312 204,922 224,189

Four-Foot 

T12 Lamp (D) (D) (D) (D) (D) (D) 222,236 215,312 191,391 182,864 171,503

(D) indicates data not made public. 

Table 3.2.9 shows similar trends for 8-foot T12 and T8 SP slimline ballasts and lamps. In 

general, 8-foot SP slimline T12 ballasts and lamps are experiencing a decrease in shipments, 

whereas 8-foot SP slimline T8 ballasts and lamps are experiencing an increase in shipments. The 

increase in shipments for 8-foot SP slimline T8 lamps is smaller than for 4-foot T8 shipments. 

According to manufacturers and lighting experts, this is because a portion of the 8-foot T12 SP 

slimline ballast market is being transferred to the 4-foot T8 ballast market.
3-18 

Figure 3.2.4 Shipments of Eight-Foot Slimline T8 and Eight-Foot SP Slimline T12 Ballasts 

Table 3.2.9 Shipments of Eight-Foot Slimline T8 and Eight-Foot SP Slimline T12 Ballasts 

and Lamps

Unit Sales by Year

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005

Eight-Foot 

Slimline T12 

Ballast

7,394 6,612 6,268 6,601 6,638 5,813 (D) (D) (D) (D) 2,599

Eight -Foot 

Slimline T8 

Ballast

932 847 961 959 1,020 1,160 1,547 1,560 1,218 1,214 1,224

Eight -Foot 

Slimline T12 

Lamp

(D) (D) (D) (D) (D) (D) 43,265 41,443 37,170 36,263 33,636

Eight -Foot 

Slimline T8 

Lamp

(D) (D) (D) (D) (D) (D) 4,405 5,300 5,183 5,727 5,176

(D) indicates data not made public.

Table 3.2.10 shows that T12 high-output ballast shipments decreased from 1995 to 2005. 

Data for high output ballasts were not reported in 1997 or from 2001 to 2005. DOE estimated the 

2005 market share using the method described earlier. A portion of the ballasts listed in Table 

3.2.10 are rated for cold-temperature outdoor signage applications, which were excluded from 

previous energy conservation standards. The Census data for high output ballasts are not 

exclusive to ballasts that operate 8-foot RDC HO lamps, but information from manufacturers 

indicates these ballasts represent most of the high output market. Discussions with lighting 

experts and lamp manufacturers indicate that they expect any migration of the 8-foot RDC HO 

market to go toward T5 HO fluorescent systems and metal halide systems. High output ballast 

shipments likely follow a similar trend to the 8-foot HO lamp shipments. Both ballast and lamp 
3-19 

shipments show the high output market share is much smaller than for 8-foot slimline T8 and 

T12 ballasts and lamps. 

Table 3.2.10 T12 High-Output Ballast Market Share

Unit Sales by Year*

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005

Eight-Foot 

T12 RDC 

HO Ballast

3,538 3,322 (D) 2,305 3,089 2,682 (D) (D) (D) (D) 1,199

Eight-Foot 

T12 RDC 

HO Lamp

23,887 24,398 24,206 24,591 25,442

Eight-Foot 

T8 RDC 

HO Lamp

691 647 467 674 420

(D) indicates data not made public. *

Data from 1995 and 1996 include electronic and magnetic ballast shipments. Data from 1997-2005 include only 

magnetic shipments. Lamps shipments are available for 2001-2005 only. 

Based on public data, Figure 3.2.5 shows magnetic residential ballast shipments have 

decreased from 1995 to 2004.l

 Shipments data for this category were unavailable for 2005. 

Because the major manufacturers in the residential sector are not members of NEMA, shipments 

in the residential sector are likely larger than those reported in the U.S. Census data. Residential 

ballasts have been excluded from energy conservation standards until the expiration of the 

exemption imposed by EPACT 2005. 

 

l

U.S. Census data does not report shipments of electronic residential (low-power-factor) ballasts.
3-20 

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

1988 1990 1992 1994 1996 1998 2000 2002 2004 2006

Shipments

Year

Figure 3.2.5 Shipments of Residential Ballasts 

T5 ballasts have been growing steadily since reported shipments began in 2002 (Figure 

3.2.6). T5 normal output ballast shipments were not reported in the U.S. Census data. 

Conversations with ballast manufacturers indicated some growth in normal output T5 ballasts 

due to replacements of 4-foot electronic T8 ballasts. In addition, manufacturers indicated that 

significant growth in T5 ballast shipments has been driven by 4-lamp T5 high output ballast 

systems replacing high-bay metal halide systems in the industrial sector. Based on information 

from ballast manufacturers, DOE believes these trends continued beyond 2005. 
3-21 

Figure 3.2.6 Shipments of T5 High-Output Ballasts

3.3 TECHNOLOGY ASSESSMENT

The purpose of the technology assessment is to develop a list of technologies that can be 

used to improve the efficiency of fluorescent lamp ballasts. The following assessment provides a 

description of the basic construction and operation of the fluorescent lamp and fluorescent lamp 

ballast, followed by technology options to improve efficiency. 

3.3.1 Basic Structure of Fluorescent Lamps

The fluorescent lamp is a low-pressure gas discharge source. The lamps are tubular in 

shape and available in a variety of lengths, diameters, and wattages. 

Lamp types are designated by a series of letters and numbers. The letter “F” is used to 

designate a fluorescent lamp. It is followed by a two-digit number that identifies either the 

nominal lamp wattage for nominally 4-foot lamps or the lamp length in inches for 8-foot lamps. 

These digits are followed by the letter “T,” for tubular, which is followed by the lamp diameter 

in eighths of an inch. Additional designations are sometimes used: for example, “HO” if the 

lamp is high output or “/ES” if the lamp is an energy saver or reduced-wattage lamp. Table 3.3.1

shows the nomenclature that defines the diameter, lamp length, and lamp wattage for some 

common fluorescent lamps. 
3-22 

Table 3.3.1 Common Linear Fluorescent Lamp Nomenclature

Lamp Nomenclature Nominal Lamp Length

feet

Nominal Lamp Wattage

W 

Lamp Diameter

inches

F32T8 4 32 1

F40T12 4 40 1 1⁄2 

F54T5 HO 4 54 5/8 

F96T12 8 75 1 1⁄2 

F96T12 HO 8 110 1 1⁄2 

F96T12 HO/ES 8 95 1 1⁄2 

The fluorescent lamp consists of a glass bulb or tube, filled with low pressure mercury 

vapor and inert gas, with electrodes sealed onto both ends of the tube. The fluorescent lamp has 

five major components: bulb, electrodes, base, gas fill, and phosphors. Two electrodes are 

hermetically sealed to both ends of the bulb. The electrodes are usually constructed from coiled 

tungsten wires coated with a mixture of alkaline oxides. A base provides an electrical connection 

to these electrodes and also supports the lamp. Depending on the start method and operational 

properties of the lamp (e.g., dimming, wattage, etc.), lamp designs may use different bases such 

as single pin, medium bipin, and recessed double contact. Once voltage is applied to the 

electrodes, the tungsten coil and coatings emit large quantities of electrons when the coating is at 

the proper temperature (1,000–1,300 K). These electrons then collide with gaseous mercury 

atoms, exciting electrons within those atoms. As the electrons decay to their stable or ground 

state, they emit UV radiation primarily at 254 nanometers (nm). In addition to the mercury 

vapor, an inert gas or a combination of gases is added to the lamp primarily to moderate the 

collisions of mercury ions and minimize evaporation of the electrode coating. The UV radiation 

is then absorbed by the phosphors and reemitted as light. 

3.3.2 Electrical Characteristics of a Fluorescent Discharge Lamp

Regardless of shape, size, or type, all fluorescent lamps require a ballast to initiate and 

maintain the arc discharge.

To achieve arc formation, the gas plasma has to be excited, ionized, and broken down (to 

become a virtual negative resistance, almost a short circuit). This requires an initial high cathode 

emission and a high electric field (i.e., voltage). Once the arc is achieved, current limiting has to 

be involved to prevent run-away and almost immediate lamp burnout. These two phenomena, 

i.e., ignition and current limiting/control, are required in all fluorescent lamps, regardless of 

shape, size, or type. Both functions constitute the major function of a ballast. Figure 3.3.1 shows 

a graphical representation of this relationship from ignition (Townsend, glow, and abnormal 

glow) through arc discharge.
3-23 

Current (I)

Voltage (V)

Arc

Abnormal Glow

Glow

Townsend

Target

Region

Undesirable

Region

Current (I)

Voltage (V)

Arc

Abnormal Glow

Glow

Townsend

Target

Region

Undesirable

Region

Figure 3.3.1 Electrical Characteristic of a Gas Discharge Lamp

Source: Adapted from Murdoch, Illuminating Engineering: From Edison’s Lamp to the LED, 2nd Edition, 2003.

A voltage pulse several times that of the lamp operating voltage may be required to 

initiate the arc discharge. During this process, the lamp’s operating point must pass through the 

Townsend, glow, and abnormal-glow as quickly as possible. Rapid start (RS) and programmed 

start (PS) systems use tertiary cathode heating to catalyze this process, while instant start (IS) 

operation simply uses a higher starting voltage. 

In general, tertiary cathode heating is believed to have a positive impact on lamp life. The 

reduction in filament heating caused by instant start operation increases the rate of loss of the 

low–work function coating due to reduced ion bombardment at the cathode (also known as 

sputtering). This causes the tungsten wire coating to deteriorate more rapidly over time, which 

contributes to higher failure rates. Therefore, lamps that operate on RS or PS ballasts can have 

longer lifetimes than lamps that operate on IS ballasts. Lamp life not only depends on the starting 

method of the ballast, but can also depend on the lamp current crest factor. For more information 

on starting method and lamp current crest factor, see section 3.3.3. 

3.3.3 Fluorescent Lamp Ballast Overview

Fluorescent lamp ballasts are devices that by means of resistance, inductance, 

capacitance, or electronic elements, singly or in combination, control the current, voltage, and 

waveform to properly start and safely operate fluorescent lamps (ANSI C82.13-2002). The 

following sections discuss basic ballast operation and the two main ballast technologies: 

magnetic and electronic.

A ballast has four critical functions: 

1. provide controlled cathode heating to aid in starting and maintaining the arc 

discharge, 

2. deliver high voltage to start and ignite the lamp, 
3-24 

3. regulate (limit) electric current flowing through the lamp after ignition to avoid 

current run-away and self-destruction, and 

4. regulate (compensate) for variations in line voltage. Good regulation ensures that 

small variations in line voltage result in even smaller variations in lamp lumen output.

Ballast types can be subdivided into two main groups: magnetic (low frequency) and 

electronic (high frequency). Magnetic ballasts were the first technology used to operate ballasts. 

Electronic ballasts were developed later in the 1980s because of their high efficiency. Section 

3.3.4 provides additional discussion on these and other technology options that can be used to 

increase the efficiency of fluorescent lamp ballasts.

There are many performance parameters used to describe the operation of a fluorescent 

lamp ballast. These include starting method, ballast factor, ballast efficacy factor, ballast 

luminous efficiency, power factor, total harmonic distortion (THD), electromagnetic interference 

(EMI), and fluorescent system safety requirements. These performance parameters are briefly 

discussed below. 

3.3.3.1 Starting Method

Fluorescent ballasts can be categorized by the manner in which they operate the lamp, or 

more specifically, how the lamp is started. The most common ballasts use three different 

methods to start a fluorescent lamp: rapid start, programmed start, and instant start. These 

methods are all defined in ANSI C82.11-2002. The starting method primarily affects the ballast’s 

switching cycle capability (i.e., the number of times one can switch the lamp on and off before it 

expires) and the power consumption of the ballast. 

Rapid start ballasts heat the electrodes for a set amount of time before lamp ignition. The 

coil heating reduces the open circuit voltage required to start the lamp, but coil heat remains 

constant after starting and consumes additional power.21 The major benefit of this starting 

technique is that it leads to a longer lamp life than the starting technique of an IS ballast. For 

example, if the lamp is switched on and off every 3 hours, the fluorescent lamp life would be 

approximately 25 percent lower for an IS ballast than for a RS ballast. However, when the lamp 

is frequently switched on and off (e.g., every 15 or 30 minutes), the lamp life on instant start and 

rapid start ballasts can be similar.23 In general, RS ballasts provide between 15,000 and 17,000 

switching cycles.22, 23

A more recent and advanced version of the RS ballast is the PS ballast. Like the RS 

ballast, the PS ballast heats the lamp filaments to a certain temperature for a prescribed amount 

of time before applying a high-voltage pulse to ignite the lamp. Some programmed start ballasts 

remove all power to the electrodes after ignition (also known as cathode cut-out), resulting in 

some energy savings over other PS systems. However, due to added internal circuitry, PS 

ballasts cannot be as efficient as IS ballasts. PS ballasts can provide between 50,000 to 100,000 

switching cycles depending on ballast design.22, 24 A lamp operating on a PS ballast can last more 

than three times longer than it would on a RS or IS ballast.22

Instant start ballasts rely on higher voltage to initiate the discharge rather than applying a 

steady filament voltage. These ballasts apply a very high voltage pulse to the lamp to rapidly 
3-25 

ionize the gas in the lamp and initiate the arc instantly, without the need for heating the 

electrodes. Because IS electronic ballasts do not provide lamp electrode heating, these ballasts 

are inherently more efficient, saving approximately 2 watts of energy per lamp compared to RS 

ballasts. However, due to the high applied voltage necessary to start the lamp, the electrodes of a 

lamp operated by an IS ballast deteriorate more quickly than the heated electrodes of a lamp 

operated by a RS or PS ballast, resulting in decreased lamp life. IS ballasts can provide between 

10,000 and 15,000 switching cycles depending on the ballast design.22, 23

3.3.3.2 Ballast Factor 

The ballast factor is defined as the output of a ballast delivered to a reference lamp in 

terms of power or light divided by the output of the relevant reference ballast delivered to the 

same lamp (ANSI C82.13-2002). To calculate the light output of a lamp-and-ballast system, one 

would multiply the light output of the lamp by both the number of lamps operated by the ballast 

and its ballast factor. Because ballast factor affects the light output of the system, manufacturers 

design ballasts with a range of ballast factors to allow consumers to vary the light output (and 

thus power consumed) of a fluorescent system. In general, ballasts that operate 4-foot MBP 

lamps and designed with a ballast factor of around 0.88 are deemed normal ballast factor. Low 

ballast factor ballasts have a ballast factor of 0.78 or less; high ballast factor ballasts typically 

have a ballast factor of 1.10 or higher.

In the ongoing active mode test procedure rulemaking, DOE has proposed to change the 

definition of ballast factor be total measured lamp arc power divided by the total reference lamp 

arc power. In this NOPR, DOE has used this method to calculate ballast factor.

3.3.3.3 Ballast Efficacy Factor 

Ballast efficacy factor (BEF) is a measure of ballast system performance or efficacy. 

According to Appendix Q to Subpart B of Part 430 in the CFR, this factor is defined as: 

 Input Power

Relative Light Output BEF = Equation 3.1

Where:

BEF = ballast efficacy factor; 

Relative Light Output = the light output delivered through the use of a ballast divided by the 

light output delivered through the use of a reference ballast, expressed as a percent; and

nputPowerI = the power consumption in watts of a ballast and fluorescent lamp or lamps. 

3.3.3.4 Ballast Luminous Efficiency

Ballast luminous efficiency means the total fluorescent lamp arc power divided by the 

fluorescent lamp ballast input power multiplied by the appropriate frequency adjustment factor. 

BLE describes the percentage of ballast input power that is used in the lamp column to produce 

light. Power delivered to the lamp cathodes (filaments) is not included in the output 

measurement and is considered a ballast loss. This percentage is then multiplied by an 
3-26 

adjustment factor depending on the frequency at which a ballast operates a lamp. Low-frequency 

operation of a lamp produces fewer lumens per lamp arc watt than high-frequency operation, so 

DOE uses a frequency adjustment factor to account for the decrease in system efficacy. In 

general, the BLE metric results in reduced measurement variation, reduced testing burden, and a 

more straightforward efficiency metric than the existing BEF metric and test procedure. In this 

NOPR, DOE evaluated ballast performance in terms of the ballast luminous efficiency metric.

3.3.3.5 Power Factor

The power factor is calculated by determining the ratio of the active power to the 

apparent power. PF depends on the current’s wave shape as well as the phase relationship 

between the current and the voltage. The power input is measured with a wattmeter capable of 

indicating the average power in watts. The ballast input voltage multiplied by the ballast input 

current is the ballast’s apparent power (ANSI C82.13-2002). 

Current Input Ballast Voltage Input Ballast

Power Input Power Factor 

∗ = Equation 3.2

Where: 

PowerFactor = power factor, 

PowerInput = input power in watts to ballast, 

BallastInputVoltage = input voltage in volts to ballast, and 

BallastInputCurrent = input current in amps to ballast. 

Power factors range between 0 and 1. A power factor of 1 indicates that the voltage and 

current wave forms are in phase and not distorted. Fluorescent ballasts can be characterized by 

two classes of power factor: high power factor (HPF) of 0.9 or greater, and normal power factor 

(NPF) of 0.6 or greater. HPF ballasts use about one-half the current of NPF ballasts. The primary 

cause of low power factor in magnetic ballasts is the inductance of the ballast transformers. It 

can be corrected with the addition of the proper capacitor. In electronic ballasts, the primary 

cause of low power factor is due to total harmonic distortion (defined below) caused by a nonlinear load. According to ANSI C82.77-2002, commercial ballasts must have a HPF while 

residential fluorescent ballasts (with an input power below 120W) must have a power factor of 

0.5 or greater. 

3.3.3.6 Total Harmonic Distortion 

Another important performance parameter is harmonic distortion. Line current harmonics 

are the components of the line current that oscillate at integer multiples of the fundamental 

frequency of the power supply, e.g., 60 Hz, 120 Hz, 180 Hz, etc. Harmonics of a fundamental 

frequency are an undesirable byproduct of any non-linear system operation, generating noise and 

wasted power. Total harmonic distortion refers to the ratio of the root mean square (rms) values 

of the harmonic content to that of the fundamental current, expressed as a percentage. It may also 

be called harmonic factor:
3-27 

2

1

2

4

2

3

2

2 ... )(

I

III

THD fund

+++ =

 Equation 3.3

Where: 

THD = total harmonic distortion; and 

I n =the rms current of harmonic n, where n=1 is the fundamental harmonic. 

High THD figures are not acceptable and are detrimental to many kinds of electronic devices 

connected to the power line. They are also considered a “pollutant” to the environment because 

of radio frequency noise. Therefore, ANSI C82.11-2002 requires that the THD of electronic 

ballasts not exceed 32 percent. Electronic ballasts today are typically rated at less than 20 percent 

THD. Magnetic ballasts are typically rated in the 20 to 28 percent range.

3.3.3.7 Electromagnetic Interference

Many devices found in office environments, such as computers, photocopiers, facsimile 

machines, and fluorescent lighting systems, can generate electromagnetic waves. The effects of 

these waves vary based on their strength and the susceptibility of nearby equipment. Alternating 

current in electronic devices produces a magnetic field, which in turn induces an AC voltage in a 

nearby electronic device. Electromagnetic interference (EMI) takes two forms: conducted or 

radiated. Conducted EMI occurs when electronic devices induce currents in the local power 

network that in turn negatively affect other devices on that network. Radiated EMI is associated 

with the electric and magnetic field inherent in electronic devices. EMI can be minimized with 

proper grounding and wiring techniques.25 EMI limits for both consumer and non-consumer 

lighting products sold in the United States are listed in 47 CFR 18 subpart C. These regulations 

require that consumer/residential (Class B) ballasts have lower maximum EMI requirements than 

non-consumer (Class A) products. The International Committee on Radio Interference has more 

stringent regulations concerning EMI. However, fluorescent lamp ballasts sold in the United 

States currently do not have to meet these regulations. More detail on electromagnetic 

interference can be found in appendix 5E. 

3.3.3.8 Safety

A ballast will continue to drive or reignite a lamp when the lamp reaches the end of its 

life. Usually, the failure of the lamp will have no adverse consequences. Occasionally, the ballast 

will continue to try to drive a failed lamp repeatedly until the temperature in the region of the 

electrode increases rapidly and causes overheating of the lamp electrodes. This can be avoided 

through additional circuitry that provides end-of-life (EOL) protection. Some ballasts in the 

United States are required to have EOL protection (e.g., ballasts that operate T5 lamps). 

However, the most popular T8 ballasts are not. International standards (IEC 600797-1 Ed. 4) 

require all fluorescent lamp ballasts regardless of lamp diameter to have EOL protection. 

Another safety issue arises when a lamp is not inserted properly into the lamp holder, 

which can cause arcing. This problem can either be addressed through better design of the lamp 
3-28 

holders, or by adding circuitry to the ballast that detects arcing and reduces the output voltage so 

that the arc cannot be sustained.

3.3.4 Fluorescent Lamp Ballast Technology Options 

The following section discusses the two major technologies used in fluorescent lamp 

ballast design—magnetic ballasts and electronic ballasts—and additional technology options 

(improved components and improved circuit design) that can incrementally improve the 

efficiencies of a magnetic or electronic ballast.

3.3.4.1 Magnetic Ballasts 

The main components of a magnetic ballast are a magnetic choke to limit the current, a 

step-up transformer to obtain a high starting voltage, and a capacitor that corrects for the ballast’s 

low power factor. Multi-lamp magnetic ballasts also have one or more additional capacitors to 

sequence the starting of the lamps. Magnetic ballasts operate at an input frequency of 60 Hz and 

operate the lamp(s) at the same frequency.

The main core-and-coil assembly consists of a capacitor and laminated transformer steel 

wound with copper or aluminum magnet wire. The assembly is infused with a potting material 

(e.g., hot asphalt) containing fiber such as silica and housed in a steel case. Figure 3.3.2 presents 

a labeled graphic of the interior of a standard magnetic ballast.

Figure 3.3.2 Cutaway View of a Typical Magnetic Fluorescent Ballast 

The core and coil assembly functions as a voltage transformer and a current limiter 

(choke). A capacitor enables the ballast to use energy from the alternating current power line 

more efficiently, which is then referred to as a HPF or PF corrected ballast. The purpose of the 

insulating material is to conduct heat away from the transformer coils and ensure tightness of 

transformer coils to eliminate vibrational noise. 

Because of their low frequency operation, magnetic ballasts are less energy efficient than 

electronic ballasts (Figure 3.3.3). Magnetic ballasts fail to optimize lumen output for a given 

wattage. These ballasts also release the energy not used to operate the lamp as heat in the 

transformer windings. This heat is dissipated to the environment by the ballast potting material 

and its metal or plastic enclosures. 
3-29 

3.3.4.2 Electronic Ballasts

For equivalent light output, electronic ballasts consume about 10 percent less energy than 

magnetic ballasts. An electronic ballast starts and operates fluorescent lamps at frequencies 

typically greater than 20 kHz using electronic components rather than the traditional core and 

coil assembly. The electronic ballast takes the input 60 Hz power, rectifies it, and converts it into 

a high frequency using an oscillator circuit. 

Higher operating frequency generates greater lumen output. Figure 3.3.3 shows the 

increase in lumen output relative to 60 Hz operation as a function of frequency. The gain in light 

output by increasing operating frequency begins to plateau around 20 kHz. Therefore, electronic 

ballasts typically operate at frequencies above 20 kHz.

Figure 3.3.3 Fluorescent Lamp Efficacy vs. Operating Frequency of Lamp

Source: Adapted from IESNA, 2002.

Not only is the lamp more efficient at higher frequencies but the ballasting action 

(current-limiting) at high frequency requires smaller components. This reduces ballast losses and 

makes the ballast more efficient. In addition, the ballast noise becomes inaudible at higher 

frequencies and there is no 60-cycle flicker like that associated with fluorescent lamps that 

operate with magnetic ballasts. 

Whereas typical magnetic ballasts generally have three components (i.e., core, coil, and 

capacitor), electronic ballasts have additional blocks of electronic components. Figure 3.3.4

shows the interior of an electronic ballast.
3-30 

Figure 3.3.4 Cutaway View of an Electronic Fluorescent Ballast

Figure 3.3.5 presents an example of a functional block diagram of a fixed-light output 

electronic ballast. Auxiliary functions performed by a typical electronic ballast include 

electromagnetic interference filtering to block ballast-generated noise, input rectification, PF 

correction for sinusoidal input current, a direct-current (DC) filter, a direct-current to alternatingcurrent (DC-AC) inverter, a feedback/controller for high-frequency operation, and a final output 

stage to power the lamp.

Figure 3.3.5 Fixed-Light Output Electronic Fluorescent Ballast Block Diagram

Source: T. Ribarich, A Systems Approach to Ballast IC Design, El Segundo, CA, 1999, and Philips Semiconductor, 

Power Semiconductor Applications, 1994.

Table 3.3.2 provides a description of each component in a typical electronic ballast, the 

efficiency impact of these components, and the waveform at each stage of the fluorescent lamp 

ballast circuit.

Table 3.3.2 Basic Building Blocks of a Fixed-Light Output Fluorescent Lamp Ballast and 

Associated Characteristics

Circuit Stage Function Efficiency 

Impact

Waveform (not to 

scale)
3-31 

EMI Filter

Impedes EMI by providing a high impedance 

path to EMI and a low impedance path to the 

desired input. The circuit also protects against 

high voltage pikes.

Very Low

t

V

Input Rectifier

Begins to convert incoming AC to DC using 

diodes. A full-bridge rectifier, one type of 

input rectifier, is composed of four diodes, 

which “rectify” the full AC waveform as 

shown in the waveform on the right. The 

current is not in phase with the voltage.

Low

t

V, I

Power Factor 

Correction

Corrects the current so it is in phase with the 

voltage. Power factor correction can be 

achieved through a buck or boost-converter 

circuit topology.

Low-Medium

t

V, I

DC Filter

Reduces “ripple” of the DC current waveform 

using capacitors. The most common type of 

capacitor used is the electrolytic capacitor.

Low

t

V

DC-AC Inverter

Converts incoming DC to high-frequency AC. 

The resonant half-bridge self-oscillating 

circuit is one type of circuit topology that can 

be used to accomplish this task.

MediumHigh

t

V

When the lamp is not started, the circuit 

operates in resonance to increase output 

voltage to start the lamp. Once the lamp is 

started, the circuit operates at a frequency off 

of resonance to continue operating the lamp. 

High Starting:
3-32 

Output Stage

A resonant filter topology is one type of 

circuit topology used in the output stage.

t

V

Operation:

t

V

Feedback/Controller

An integrated circuit (IC) that controls the 

frequency output of the DC-AC inverter. It 

can also protect against under voltage lockout 

and lamp faults.

Low N/A

3.3.4.3 Improved Components

A common way to increase the efficiency of both magnetic and electronic ballasts is to 

improve the quality of their components. Magnetics (transformers and inductors), diodes, 

capacitors, and transistors are the main components that affect efficiency. 

Magnetics (transformers and inductors): In electronic ballasts, magnetics influence the

efficiency of the EMI, power factor correction (PFC), and output stage of the ballast. In magnetic 

ballasts, magnetics influence the efficiency of the output stage and current-limiting portion of the 

ballast. 

There are two loss mechanisms associated with magnetics: core losses and winding 

losses. Core losses involve the magnetic properties of the core material, which exhibits power 

losses in the form of hysteresis and eddy currents within the core itself. Winding losses come 

from the resistance in the winding, typically copper. There are several technology options that 

can improve the efficiency of a magnetic component’s core losses. These include improved 

silicon steel, amorphous steel, or increased amounts of amorphous steel. Litz wire can be used as 

a technology option to improve a magnetic component’s winding losses. 

One way to reduce magnetic component power loss at light loads is to select magnetics 

with higher quality core materials. There are two types of core materials that ballasts can use: 

silicon steel (thinly laminated steel alloyed with silicon) and amorphous steel. Core performance 

of silicon steel can be enhanced by magnetically orienting the grain structure in the metal. Even 

larger gains in efficiency can be achieved using amorphous materials. To further increase the 

efficiency of the ballast using amorphous materials, one can create the core of the inductor from 

laminated sheets of amorphous steel, insulated from each other. However, this method can 

increase the size and weight of the ballast.
3-33 

Another way to reduce the magnetic component’s power loss is to select materials with 

lower winding losses. High-frequency operation (typical of electronic ballasts) can increase 

winding losses as two additional loss mechanisms, skin effect and proximity effect, become 

more prominent. One way to reduce both the skin effect and proximity effect is to use litz wire, 

which consists of a number of individually insulated magnet wires twisted or braided into a 

uniform pattern. Skin effect refers to the tendency of AC current to flow through a conductor’s 

surface or “skin” rather than a conductor’s core. Because litz wire increases the amount of 

surface area current can flow through, overall winding losses can be reduced as the effective wire 

resistance is decreased. When conductors are close together, the magnetic field of one conductor 

will reduce the area that the current flows through in another conductor, increasing its winding 

losses. This effect, called the proximity effect, can be also be improved by using litz wire.

 Diodes: In electronic ballasts, the input rectifier inverts the negative half of the AC sine 

wave and makes it positive. Several technology options can be used to improve the efficiency of 

this portion of the circuit. The power consumed by a diode is the product of the current flowing 

through the diode multiplied by the voltage drop across it. Conventional diodes have a voltage 

drop of about 0.6 V. Use of a Schottky diodem would reduce the voltage drop across the diodes 

by about 0.3 V to 0.4 V. However, as discussed in Appendix 5D, DOE was unable to identify a 

Schottky diode that could be used as a direct replacement for the conventional diodes typically 

used in ballasts. 

Capacitors: In both magnetic and electronic ballasts, capacitors are used in the PFC and 

output stage of the circuit design. In electronic ballasts, capacitors are also used in the DC Filter 

stage of the electronic circuit. One way to improve the efficiency of each portion of the circuit is 

to use capacitors with low effective series resistance (ESR). Capacitors with a low ESR are also 

more reliable because they are cooler than capacitors with a higher ESR.

Transistors: In electronic ballasts, transistors are used in both the power factor correction 

and the DC-AC inverter portion of the circuit. The transistor dissipates energy due to its drain-tosource resistance (RDS_ON) when the current flows through the transistor to the transformer. 

Using transistors with low RDS_ON can reduce this loss. For example, the efficiency of electronic 

ballast’s bipolar transistors can be improved by using metal-oxide-semiconductor field-effect 

transistors (MOSFETs), a transistor with a lower drain-to-source resistance.

3.3.4.4 Improved Circuit Design

Another method of increasing the efficiency of both magnetic and electronic ballasts is to 

improve the ballast’s circuit design. Examples of improved circuit design include cathode cutout 

technology, integrated circuits, improved starting method, and synchronous rectification. 

Cathode Cutout: Both rapid start and programmed start ballasts provide heat to the 

filament while starting a lamp. As discussed in section 3.3.3.1, providing filament power while 

 

m A Schottky diode is a metal semiconductor diode with a smaller voltage drop than a conventional diode. Schottky 

diodes therefore consume less power. 
3-34 

starting the lamp can increase its lifetime. Removing the power provided to the filament after the 

lamp has been started using an electronic circuit will increase the efficiency of both programmed 

start and rapid start ballasts. Removing this power can reduce the power the ballast consumes by 

as much as 2 watts per lamp. 

Integrated Circuits: In certain cases, a ballast’s efficiency can be improved by 

substituting integrated circuits for discrete components. For example, some ballasts use bipolar 

transistors in a resonant half-bridge self-oscillating circuit to convert incoming DC to AC. The 

efficiency of this circuit can be improved by substituting the components in that circuit with an 

integrated circuit.26

Starting Method: RS and PS ballasts are inherently less efficient than IS ballasts, which 

use extra power to provide filament power to the ballast to increase its lifetime. Although these 

ballasts can cut out the filament power during lamp operation (using the cathode cutout 

technology option discussed above), the extra circuit to remove this power uses some amount of 

power. 

DOE only considered starting method as a technology option in case of the migration 

from RS to IS ballasts. DOE’s research indicates that IS ballasts are common replacements for 

RS ballasts, and though the lamp lifetime is sometimes lower in IS ballasts than RS ballasts, it 

does not seem to be significant enough to affect consumer utility. As discussed in section 3.3.3.1, 

lamp lifetime in IS ballasts is approximately 25 percent less compared to RS ballasts when 

operated on a 3-hour start. However, lamps operated on RS ballasts have the same lifetime as 

lamps operated on IS ballasts when operated on short start cycles. This is typical when ballasts 

are used with occupancy sensors to save energy. Conversely, the lifetime of a lamp that operates 

on a PS ballast with occupancy sensors can be as much as three times longer than the lifetime of 

a lamp that operates on an IS or RS ballasts. Because IS ballasts have more limited utility as 

replacements for PS ballasts, IS ballasts are not considered a technology option for improving 

the efficiency of PS ballasts.

3.4 PRODUCT CLASSES

When evaluating and establishing energy conservation standards, DOE divides covered 

products into classes by the type of energy used, capacity, or other performance-related features 

that affect efficiency, and factors such as the utility of the product to users. (See 42 U.S.C. 

6295(q)) DOE then conducts its analysis and considers establishing or amending standards to 

provide separate standard levels for each product class. DOE applied the criteria of 42 U.S.C. 

6295(q) to fluorescent lamp ballasts to develop product classes for this NOPR TSD. This section 

describes the product classes DOE considers for this rulemaking. 

In amending EPCA, NAECA 1988 established eight product classes for fluorescent lamp 

ballasts (Table 3.4.1).
3-35 

Table 3.4.1 EPCA Product Classes Established by NAECA 1988 for Fluorescent Lamp 

Ballasts 

Application for Operation of Ballast Input Voltage Total Nominal Lamp Watts

One F40T12 Lamp 120 40

277 40

Two F40T12 Lamps 120 80

277 80

Two F96T12 Lamps 120 150

277 150

Two F96T12 HO Lamps 120 220

277 220

In further amendments to EPCA, EPACT 2005 established an additional eight product 

classes for fluorescent lamp ballasts (Table 3.4.2).

Table 3.4.2 EPCA Product Classes Established by EPACT 2005 for Fluorescent Lamp 

Ballasts 

Application for Operation of Ballast Input Voltage Total Nominal Lamp Watts

One F34T12 Lamp 120 34

277 34

Two F34T12 Lamps 120 68

277 68

Two F96T12/ES Lamps 120 120

277 120

Two F96T12 HO/ES Lamps 120 190

277 190

In addition to the lamps and lamp ballasts identified in Table 3.4.1 and Table 3.4.2, the 

fluorescent lamp ballast market today includes ballasts that operate smaller diameter lamps such 

as T8 and T5 lamps (section 3.3.1). These fluorescent lamp-and-ballast systems are gaining in 

market share, whereas T12 systems are becoming less popular and losing market share. This 

market shift is expected to accelerate in 2010, when the exclusion from the standard levels 

established by the 2000 Ballast Rule and EPACT 2005 for replacement ballasts will expire. The 

standard levels established by the 2000 Ballast Rule and EPACT 2005 for fluorescent lamp 

ballasts are difficult to meet using magnetic ballast technology. Because magnetic ballasts 

comprise the large majority of T12 ballast sales, DOE believes that when the standards take 

effect, there will be an increase in shipments of electronic ballasts that operate T8 and T5 lamps.

Because of these market changes and because DOE is anticipating expanding its scope of 

covered product for fluorescent lamp ballasts, DOE is proposing to amend the product classes for 

these ballasts. The following sections summarize all of the factors that DOE considered as 

potential determinants of product class. In general, when considering the characteristics below, 

DOE considered three main factors as affecting consumer utility: (1) the lumen package of the 

lamp-and-ballast system; (2) the physical constraints of the lamp-and-ballast system; and (3) the 

use of the ballast in an application for which other ballasts are not suitable. When referring to 

efficiency, DOE is referring to BLE.

3.4.1 Power versus Efficiency Relationship
3-36 

DOE believes that there are both fixed and variable losses in any fluorescent ballast. 

Fixed losses consist of switching losses, due to components such as transistors, and fixed voltage 

drops across certain components, such as diodes. These components are necessary for proper 

ballast operation but will always contribute some amount to overall ballast losses. In ballasts that 

operate low powers, fixed losses comprise a significant amount of the power lost. Variable losses 

consist primarily of resistive losses (also referred to as I2R losses) which increase as current 

increases. Ballasts that operate higher powers also operate at a higher current and therefore have 

greater resistive losses. At a certain power level, resistive losses will be greater than fixed losses, 

as these losses continue to increase as power increases.

Using test data, DOE empirically found a relationship between the BLE metric and the 

natural log of lamp arc power. In general, as lamp arc power increases, BLE increases as well. 

DOE believes this is because the fixed losses of a ballast become proportionally less significant 

at higher lamp arc powers. Because this power-efficiency relationship exists, DOE is able to set 

efficiency levels as a function of lamp arc power. Thus, several factors that affect the total 

wattage operated by a ballast (such as lamp length, ballast factor, and number of lamps operated) 

do not necessarily require separate product classes.

3.4.2 Starting Method

DOE found RS and PS ballasts to be inherently less efficient than IS ballasts because RS 

and PS ballasts provide filament power to the lamp. Although some PS ballasts cut out the 

filament power during normal operation (using the cathode cutout technology option discussed 

above), the extra circuitry to remove this power still consumes some amount of power. In the 

BLE metric, cathode heating is counted as a loss because it does not directly contribute to the 

creation of light. Therefore, RS and PS ballasts will have lower BLEs than comparable IS 

ballasts.

Whereas RS and IS ballasts are commonly used as substitutes for each other, PS ballasts 

are not. Programmed start ballasts are commonly used in conjunction with occupancy sensors 

because of their ability to maintain the lifetime of the fluorescent lamp. The lifetime of a lamp 

operated on a PS ballast with occupancy sensors can be as much as three times longer than the 

lifetime of a lamp operated on an IS or RS ballast in the same application. Thus, DOE’s research 

indicates that use of instant start ballasts with occupancy sensors can result in a significant 

reduction in lamp lifetime. Because the application in which they are used greatly affects lamp 

lifetime, programmed start ballasts offer the user a distinct utility. In consideration of their affect 

on both BLE and utility, DOE established separate product classes for programmed start ballasts.

3.4.3 Lumen Package

Lumen package refers to the quantity of light that a lamp-and-ballast system provides to a 

consumer. To obtain a high lumen package, certain lamps are designed to operate with ballasts 

that run the lamps at high currents. For example, 8-foot HO lamps and 4-foot MiniBP HO lamps

tend to operate at higher currents than 8-foot slimline lamps and 4-foot MiniBP SO lamps, 

respectively. This difference in operating design increases the quantity of light per unit of lamp 

length. Consumers tend to use systems with different lumen packages for different applications. 

For example, high-lumen-output systems may be installed in certain high-ceiling or outdoor 
3-37 

applications where large quantities of light are needed. Alternatively, standard-lumen-output 

systems might be installed in lower-ceiling applications such as offices or hospitals, where the 

distance between the light source and the illuminated surface is not as large. Notable differences 

in the application of ballasts designed to operate SO lamps versus HO lamps indicate a 

difference in utility.

However, BLE is not dependent on system light output, but rather on the total power 

operated by the ballast. As HO lamps have higher rated powers than comparable (same length, 

diameter) SO lamps, DOE believed ballasts that operate HO lamps would be more efficient than 

comparable ballasts that operate SO lamps. An analysis of test data generally confirmed this 

prediction. Therefore, because the power-efficiency equation accounts for HO versus SO lamp 

operation, DOE is not establishing separate product classes for ballasts that operate HO lamps, 

with one exception as explained in the following paragraph. 

DOE found that ballasts that operate 8-foot HO lamps did not follow the expected 

relationship. Compared to 8-foot slimline ballasts, DOE found that 8-foot HO ballasts exhibited 

lower BLEs although they operated higher lamp powers. This may be because this ballast type 

has a different topology, or circuit design, than other ballast types (e.g. 4-foot MBP and 8-foot 

slimline ballasts). Because DOE has established that lumen package offers a unique utility, and 

in this case a change in lumen package is accompanied by a change in BLE from what the 

efficiency equation would predict, DOE established a separate product class for ballasts that 

operate 8-foot HO lamps. 

3.4.4 Sign Ballasts 

Ballasts that are designed for use in cold temperature outdoor signs have slightly different 

characteristics than those ballasts that operate in the commercial sector. First, sign ballasts are 

designed to operate in cold temperature environments – as low as negative 20 degrees 

Fahrenheit. Second, sign ballasts are classified by the total length (in feet) of lamps they can 

operate as well as the total number of lamps. To operate in cold temperature environments and to 

be able to handle numerous lamp combinations, sign ballasts contain more robust components 

compared to regular 8-foot HO ballasts in the commercial sector. Thus, sign ballasts are 

inherently less efficient. For this reason, sign ballasts did not achieve the expected BLE predicted 

by the power-efficiency relationship. 

Although regular 8-foot HO ballasts are also rated for operation in cold temperature 

environments, they cannot always serve as substitutes for sign ballasts due to their lack of 

moisture seals and more limited load specifications. For these reasons, and the associated 

differences in BLE compared to ballasts of similar lamp arc power, DOE established separate 

product classes for sign ballasts.

3.4.5 Product Classes

For all the reasons discussed above, DOE is considering the ballast product classes listed 

in Table 3.4.3. 
3-38 

Table 3.4.3 Product Classes for Fluorescent Lamp Ballasts

Description Product Class Number**

IS and RS ballasts that operate

 4-foot MBP lamps* 

 8-foot slimline lamps 

1 

PS ballasts that operate

 4-foot MBP lamps* 

 4-foot MiniBP SO lamps

 4-foot MiniBP HO lamps

2 

IS and RS ballasts that operate

 8-foot HO lamps 3 

PS ballasts that operate

 8-foot HO lamps

4 

Ballasts that operate

 8-foot HO lamps in cold 

 temperature outdoor signs

5 

*Includes both commercial and residential ballasts

**Efficiency levels for all product classes are based on an equation
3-39 

REFERENCES

1

 Ron Runkles. NEMA Premium Efficiency Electronic Ballast Program. NEMA Lighting Systems 

Division. 2007. (Last accessed April 4, 2011). <http://www.cee1.org/cee/mtg/09-

07ppt/Wednesday/9%20NEMA_CEE%20Presentation.ppt>. 

2 National Electrical Manufacturers Association. Lighting Systems Division. 2002. (Last accessed 

April 4, 2011). <http://www.nema.org/prod/lighting/upload/LightingSystemsDivision.pdf>. 

3 U.S. Small Business Administration. Table of Small Business Size Standards Matched to North 

American Industry Classification System Codes. 2008. (Last accessed April 4, 2011.) 

<http://www.sba.gov/sites/default/files/Size_Standards_Table.pdf>. 

4

 California Energy Commission. 2007 Appliance Efficiency Regulations. 2007. (Last accessed 

April 4, 2011). <http://www.energy.ca.gov/2007publications/CEC-400-2007-016/CEC-400-

2007-016-REV1.PDF>.

5 Natural Resources Canada, Office of Energy Efficiency. Proposed Regulations for Fluorescent 

Lamp Ballasts. 2001. (Last accessed April 4, 2011). 

<http://oee.nrcan.gc.ca/regulations/Fluorescent.cfm?attr=0>.

6 Natural Resources Canada, Office of Energy Efficiency. Recent Amendments. 2009. (Last 

accessed April 4, 2011). <http://oee.nrcan.gc.ca/regulations/amendment6_part2.cfm?attr=0>. 

7 Natural Resources Canada, Office of Energy Efficiency. Regulations Amending the Canada's 

Energy Efficiency Regulations. 2009. (Last accessed April 4, 2011). 

<http://oee.nrcan.gc.ca/regulations/amendment9_part1.cfm?attr=0>. 

8 Natural Resources Canada, Office of Energy Efficiency. Canadian Energy Efficiency 

Regulations for Fluorescent Lamp Ballasts. 2009. (Last accessed April 4, 2011). 

<http://oee.nrcan.gc.ca/regulations/product/fluorescent_lamp_ballasts.cfm?attr=0>. 

9 U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Federal 

Energy Management Program. How to Buy Energy-Efficient Fluorescent Ballasts. 2000. (Last 

accessed April 4, 2011). <http://www1.eere.energy.gov/femp/pdfs/ballast.pdf > 

10 Consortium for Energy Efficiency. CEE High Performance T8 Specification. 2008. (Last 

accessed April 4, 2011). <http://www.cee1.org/com/com-lt/com-lt-specs.pdf>. 

11 Consortium for Energy Efficiency. CEE Reduced-Wattage T8 Specification. 2007. (Last 

accessed April 4, 2011). <http://www.cee1.org/com/com-lt/lw-spec.pdf>.

12 National Electrical Manufacturers Association. NEMA Premium Electronic Ballast Program. 

(Last accessed April 4, 2011). 
3-40 

<http://www.nema.org/gov/energy/efficiency/upload/nema_premium_electronic_ballast_progra

m.pdf>. 

13 Industrial Equipment News. NEMA Premium Motor Results Show Increase In Sales.

November 4, 2004. (Last accessed April 4, 2011.) < http://www.ien.com/article/nema-premiummotor/8468>. 

14 U.S. Environmental Protection Agency and U.S. Department of Energy. About ENERGY 

STAR. (Last accessed April 4, 2011). 

<http://www.energystar.gov/index.cfm?c=about.ab_index>. 

15 U.S. Environmental Protection Agency and U.S. Department of Energy. Residential Light 

Fixtures Key Product Criteria. (Last accessed April 4, 2011). 

<http://www.energystar.gov/index.cfm?c=fixtures.pr_crit_light_fixtures>.

16 Northeast Energy Efficiency Partnership. Commercial Buildings and Technologies Initiative. 

2009 (Last accessed April 4, 2011) <http://neep.org/regional-initiatives/1/56/CommercialBuildings-and-Technology-Initiative> 

17 Efficiency Vermont. High Performance T8 Eligible Products & Fact Sheet. (Last accessed 

April 4, 2011.) < 

http://www.efficiencyvermont.com/stella/filelib/2008_HPT8FactSheet_FINAL1207.pdf>. 

18 Efficiency Vermont. 2010 Rebate Application. 2010. (Last accessed April 4, 2011). <

http://www.efficiencyvermont.com/stella/filelib/2010_LightingRebateApplication_FINAL.pdf >.

19 U.S. Census Bureau. Manufacturing, Mining, and Construction Statistics. Current Industrial 

Reports, Fluorescent Lamp Ballasts, MQ335C. 2008. (Last accessed April 4, 2011). 

<http://www.census.gov/mcd/> 

20 National Electrical Manufacturers Association. 2006. No. 12 at p. 7. This written comment, 

document number 12, is available in Docket # EE–2006–STD–0131. For more information, 

contact Brenda Edwards-Jones at (202) 586-2945. 

21 Illuminating Engineering Society of North America. 2000. The IESNA Lighting Handbook: 

Reference and Application. 9th Edition. M.S. Rea. New York. 2000.

22 Philips. Smart T Bay. (Last accessed April 4, 2011). 

<http://www.smartlightingtechnology.com/pdf/SmarTBay_608.pdf. 

23 Osram Sylvania. Ballast-Lamp Technology Update. 2000. (Last accessed April 4, 2011). 

<http://www.lighthouseconsultingllc.com/Osram_Sylvania/Sylvania%20Ballast%20update.pdf>.
3-41 

24 Osram Sylvania. Ballast Technology Applications and Specifications Guide. 2009. (Last 

accessed April 4, 2011.) <

http://www.sylvania.com/onlinemedia/ihdp/BallastSpecGuide/#?page=4 >.

25 National Lighting Product Information Program. Lighting Answers: Electromagnetic 

Interference Involving Fluorescent Lighting Systems. 1995. (Last accessed April 4, 2011). 

<http://www.lrc.rpi.edu/programs/NLPIP/lightinganswers/pdf/view/LAEMI.pdf>.

26International Rectifier. International Rectifier Introduces Robust Self-Oscillating Electronic 

Ballast Lighting Control IC. 2009. (Last accessed April 4, 2011.) <http://www.irf.com/whatsnew/nr051122.html>.