While many in the lighting industry are aware that US DOE recently issued a Final Rule for a definition change of general service lamps (GSL) as well as General Service Incandescent Lamps (GSIL), many in the industry don’t realize the impact of this expanded GSL definition on many LED lamps. Most of the public discussion around the new GSL definition focused on the addition of incandescent and halogen specialty lamps to the regulated GSL category. However, the new expanded GSL definition encompasses many LED lamps, in addition to incandescent and halogen.
This means that many LED A-lamps, LED specialty lamps, and LED tube lamps will now be regulated by the DOE, in less than two months. For LED lamp manufacturers, this means self-certifying the regulated models onto DOE’s database of regulated products, known as CCMS. This is a great deal of spreadsheet work, and will be most difficult for manufacturers that have no previous experience uploaded spreadsheets to CCMS. Well-placed sources tell me that DOE will take more than two months to create the forms for manufacturers to submit all of the new regulated lamp types, thereby giving manufacturers some much needed additional time for certification compliance. It’s unlikely that the new 45 lpW “backstop” Final Rule will create problems for any LED lamps, as most are significantly above the 45 lpW requirement for GSL.
What follows is the amended GSL definition, from the April, 2022 DOE GSL Final Rule:
“General service lamp means a lamp that has an ANSI base; is able to operate at a voltage of 12 volts or 24 volts, at or between 100 to 130 volts, at or between 220 to 240 volts, or at 277 volts for integrated lamps, or is able to operate at any voltage for non-integrated lamps; has an initial lumen output of greater than or equal to 310 lumens (or 232 lumens for modified spectrum general service incandescent lamps) and less than or equal to 3,300 lumens; is not a light fixture; is not an LED downlight retrofit kit; and is used in general lighting applications. General service lamps do not include:
(1) Appliance lamps;
(2) Black light lamps;
(3) Bug lamps;
(4) Colored lamps;
(5) G shape lamps with a diameter of 5 inches or more as defined in ANSI C79.1-2002;
(6) General service fluorescent lamps;
(7) High intensity discharge lamps;
(8) Infrared lamps;
(9) J, JC, JCD, JCS, JCV, JCX, JD, JS, and JT shape lamps that do not have Edison screw bases;
(10) Lamps that have a wedge base or prefocus base;
(11) Left-hand thread lamps;
(12) Marine lamps;
(13) Marine signal service lamps;
(14) Mine service lamps;
(15) MR shape lamps that have a first number symbol equal to 16 (diameter equal to 2 inches) as defined in ANSI C79.1-2002, operate at 12 volts, and have a lumen output greater than or equal to 800;
(16) Other fluorescent lamps;
(17) Plant light lamps;
(18) R20 short lamps;
(19) Reflector lamps that have a first number symbol less than 16 (diameter less than 2 inches) as defined in ANSI C79.1-2002 and that do not have E26/E24, E26d, E26/50×39, E26/53×39, E29/28, E29/53×39, E39, E39d, EP39, or EX39 bases;
(20) S shape or G shape lamps that have a first number symbol less than or equal to 12.5 (diameter less than or equal to 1.5625 inches) as defined in ANSI C79.1-2002;
(21) Sign service lamps;
(22) Silver bowl lamps;
(23) Showcase lamps;
(24) Specialty MR lamps;
(25) T shape lamps that have a first number symbol less than or equal to 8 (diameter less than or equal to 1 inch) as defined in ANSI C79.1-2002, nominal overall length less than 12 inches, and that are not compact fluorescent lamps;
(26) Traffic signal lamps.”
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