Legislation + Regulation

New DOE Guidance On GSL & GSIL Backstop Timing and Certification Requirements

On October 28th, the US DOE issued new guidance for the industry to comply with the GSL & GSIL certification requirements and timing. In May of 2022, the DOE issued two final rules for these lamps:

Image: https://appliance-standards.org

  1. Expanded definition of GSL & GSIL that became effective on 7/8/22 (“the Definitions Rule”), and
  2. The prohibition of selling any GSL below 45 lm/W, effective 7/25/22 (“the Backstop Rule”).

These rules changed which lamps have to be certified to DOE CCMS. Although GSLs must comply with the Backstop Rule, manufacturers are not currently required to certify compliance to the efficacy backstop. This may become required at a future date. DOE is only requiring certification to the applicable pre-backstop standard. See the table below.

DOE will pursue penalties for GSLs that do not meet the 45 lm/W requirement, whether they are certified to a pre-backstop standard or not.

Manufacturers of GSLs must also apply the sampling and test methods of 10 CFR 429.57 for determining represented values and ratings for GSLs, including those subject to the FTC lighting labeling rules, even if they are not currently required to certify compliance to DOE.

There are seven categories of lamps that were not GSILs before the Definitions Rule, but now are GSILs and thus also are GSLs. These are: (1) T shape lamps that use not more than 40 watts or has a length of more than 10 inches; (2) B, BA, CA, F, G16-1/2, G-25, G30, S, or M-14 lamps of 40 watts or less; (3) reflector lamps; (4) rough service lamps; (5) shatter-resistant lamps; (6) 3-way lamps; and (7) vibration service lamps. Each manufacturer/importer must certify that each model of these GSILs complies with the applicable maximum wattage standards. The 45 lm/W backstop sales ban applies to these lamps, as they are now GSLs.

DOE began enforcing the certification requirements for these 7 additional lamp categories on November 1, 2022. Each manufacturer/importer must certify all basic models distributed in commerce in the United States no later than November 1. A manufacturer who begins distributing in commerce any of these additional lamps that were manufactured or imported on or after November 1, 2022, must certify that basic model before distribution. Manufacturers who continue to hold inventory that was manufactured before November 1, 2022 do not need to certify compliance for these basic models. The certification provisions require new basic models of GSILs manufactured or imported on or after November 1, 2022 subject to the energy conservation standards to be certified before distribution in commerce, annually thereafter, and when discontinued.

Rough service and vibration service lamps were subject to a wattage limit before the Definitions Rule, and IRLs were subject to standards. Now each manufacturer/importer of rough and vibration service lamps and IRLs must certify compliance according to the requirements for GSILs.

Existing certification requirements continue to apply to medium base compact fluorescent lamps, candelabra and intermediate base incandescent lamps and lamps defined as GSILs before the Definitions Rule. This requires certifying compliance with the applicable standards, using the applicable sampling plan and certification requirements.

The DOE guidance document can be downloaded here.

Source: US DOE 10/31/22 Certification Guidance for GSIL & GSL

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