## Department of Energy Washington, DC.20585

June 26, 1996

Mr. Gary S. Crawford GE Lighting 1975 Noble Road, Nela Park Cleveland, OH 44112-6300 

### Dear Mr. Crawford: Last August Michael McCabe, Director of the Department of Energy Office of Codes and Standards, responded to a request from the National Electrical Manufacturers Association (NEMA) for clarification of several issues relating to energy efficiency standards and test procedures for lamps. Since then questions have continued about whether four-foot T-12 fluorescent lamps rated by manufacturers at 25 watts based on a low power factor ballast are subject to the energy efficiency standards. The Department recognizes the importance of the production of an efficient, low cost fluorescent lamp for the residential market. However, the Department believes that this lamp, while rated by manufacturers below 28 watts, could be. used in 40 watt applications to an extent justifying a determination that it is a covered product under the Energy Policy and Conservation Act (EPCA). The Department believes that four-foot T-12 fluorescent lamps rated at 25 watts when used with a low power factor ballast but having a wattage of 28 watts or more when used with a high power factor ballast are "fluorescent lamps" subject to regulation under EPCA unless they are clearly designed. or marketed exclusively for residential applications. The Department would consider a lamp to be designed exclusively for residential applications if the lamp is designed so as not to function for more than 100 hours with a commercial high power factor ballast. The Department will consider a lamp to be marketed exclusively for residential applications if the lamp has a life span of 6,000 hours or less when used with a commercial high power factor ballast and is marketed and labeled as follows:- 1) The lamp is permanently and clearly etched with a statement that the lamp is for residential applications only or that it is not for use in commercial applications; 2) The lamp is distributed only through consumer/residential channels, and retailers are alerted to the limitations on proper use of the lamps; 3) The lamp is packaged and labeled in a manner which clearly states its applications and other warnings about proper and improper use; 4) The lamp is distributed in packages for retail sale in boxes of 30 lamps or less;

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5) The lamp is listed only in manufacturer's consumer/residential catalogs or price list or., if listed with commercial/industrial lamps, it is listed in a separate. residential section and is clearly marked by notes or warnings about improper use on the same page; and 6) The manufacturer clearly provides that improper use of the lamp voids any warranty, explicit or implied. The Department believes that if these lamps are designed or marketed in this fashion the likelihood of improper use of these lamps will 'be minimized. If the lamp is labeled or represented as a replacement for a 40 watt lamp covered by EPCA, the Department will consider such lamp to be a 40 watt lamp covered under the Act. DOE reserves the right to monitor the sales and distribution of lamps that are labeled as 25 watt lamps and marketed exclusively for residential use. If the Department finds that the 25 watt lamp is being installed in significant numbers in applications where it will perform within the covered range of wattages, the Department will consider such lamps subject to regulation under EPCA. I. believe these options fairly and decisively address the needs of consumers and manufacturers while .meeting the spirit of EPCA to maximize energy efficiency and minimize energy consumption. The Department expects to codify this approach in the final rule on lamp test. procedures which will be published this summer. Lamp manufacturers are expected to conform with this direction as soon as is practicable and not later than 90 days after publication of the final rule. The Department is committed to administering the EPCA standards in a manner that achieves the purposes of the Act. If you have any questions, please contact Mr..Michael McCabe of (202) 586-9127.

.Christine A. Ervin Assistant Secretary Energy Efficiency and Renewable Energy cc: Mr. Malcolm O'Hagan National Electrical Manufacturers Association