In previous LightNOW reporting, I’ve written about EPA’s sunsetting of the ENERGY STAR Lamps and Luminaires specifications, along with the plan to launch a new recessed downlights specification. EPA has now released a second draft of the ENERGY STAR Recessed Downlights Version 1.0 specification (Version 1.0) intended to replace the Luminaires Version 2.2 specification (the existing specification) for recessed downlights and recessed downlight retrofit kits.
Proposed Changes in Draft 2
Product Families (Section 6.1)
Based on feedback from draft 1 related to efficacy and product variations, EPA is proposing that draft 2 include a new approach to certifying product families. Rather than requiring the testing of all variations or worst-case efficacy scenarios, this proposal focuses on the energy used and requires the representative test model for a product family to have the highest input power and highest efficacy. Variations in the product family that reduce light output, and therefore have lower luminous efficacy, are allowed as long as the applicable minimum initial light output requirement is met. The goal of this approach is for certification to represent the same energy savings for any product in the family. The result should be a greater number of models being certified, with less testing. This approach allows for flexibility in serving customer preference while delivering the same benefit to the environment.
Lumen Maintenance and Rated Life Requirements (Section 9)
In response to concerns about more conservative projections highlighted in the 2022 NEMA white paper (NEMA Comments on Updated IES TM-21-22 Calculator), EPA is proposing a single light source life requirement for all products, whether the light source is separable or inseparable, of 25,000 hours instead of maintaining the two thresholds of 25,000 and 50,000 hours respectively. With the official release of the ANSI/IES TM-21 Calculator confirmed, EPA is proposing that all products be re-evaluated using the new calculator so that all ENERGY STAR certified recessed downlights under the new specification can be represented consistently. EPA is also proposing to remove the “Option 2” lumen maintenance compliance path and all associated references to LM-84 testing and TM-28 lifetime projections due to the limited use of this certification pathway over the history of the luminaires program.
Packaging Requirements (Section 15.1)
EPA has updated the packaging requirements in response to stakeholder comments that the current packaging requirements were designed for in-store retail sales, where consumers make purchasing decisions based on information displayed on a package, and are costly and unnecessary for online sales. For models destined exclusively for online sale, EPA proposes that packaging requirements may be fulfilled by providing a supplemental performance summary document for certification and that all online resellers ensure that online marketing claims are consistent with the model’s certification. Additionally, EPA has removed requirements that were redundant with existing safety standards. Note that this does not impact existing luminaires partner/participant commitments regarding the use of ENERGY STAR marks which will carry over.
Additional Changes Proposed
- The scope has been expanded to allow for alternate mounting configurations (Section 1).
- The Downlight, Accent Light, and Downlight Retrofit definitions are further harmonized and a new Wallwash Distribution definition is introduced (Section 4).
- The expectation that colour tunable and multi-output products are to be evaluated at the most consumptive white light setting has been clarified (Section 5.1).
- EPA has clarified that ANSI/IES LM-80-21, IES LM-80-15, or LM-80-08 and its Addendum A are acceptable methods of measurement related to ENERGY STAR lumen and colour maintenance requirements. Additionally, ANSI/IES LM-79-19 and IES LM-79-08 are acceptable methods of measurement where applicable (section 7, 8, and 9) as are ANSI C82.77-10-2021 and C82.77-10-2014 for power factor.
- Light source serviceability and driver replaceability requirements are replaced with recommendations whenever possible based on product design (Section 11).
A stakeholder webinar will be held on July 12, 2023, from 2 to 3:30 pm EDT to provide an overview of the version 1.0 draft 2 specification and allow for detailed discussion. Register here to attend. All documents related to draft 2 are posted to www.energystar.gov/luminaires.
Stakeholders are encouraged to provide written comments to the EPA for consideration via e-mail to email@example.com no later than July 28, 2023. Indicate “ENERGY STAR Recessed Downlights V1 Draft 2 Comments” in the subject line. All comments received will be posted to the Recessed Downlights Version 1.0 Draft 2 website unless the submitter specifically requests that comments remain confidential.