DOE previously provided guidance to general service lamp (GSL) manufacturers that the Department would not require certification in CCMS (the regulated product database) of GSL lamps that did not already require certification, until the effective date of new standards which come into effect July of 2028. DOE published a pre-publication final rule document, this week, withdrawing the previous guidance, and alerting industry that all GSL lamp manufacturers will be required to certify to CCMS in roughly 7 months (210 days from when this final rule is published in the Federal Register).

This will create significant administrative work for lamp manufacturers needing to certify their regulated GSL products by the new deadline. The new certification requirements will apply to companies who domestically manufacturer or who import LED lamps either as a stand-alone product or included in a package with light fixtures. In order to certify GSL lamps (including LED and fluorescent technologies), the lamps must be tested in an accredited lab in accordance with the current applicable federal test procedure.  Though manufacturers were not previously required to certify the product in CCMS, DOE’s guidance makes it clear that where a federal test procedure exists all manufacturers must test to DOE standards. Now that certification will be required, companies must begin reviewing their basic model test data and ensuring all products have in fact been tested in order to submit to CCMS. Failure to certify to CCMS can result in those manufacturers being subject to costly enforcement action by DOE. Publicly available information on prior DOE enforcement on manufacturers that didn’t test and/or certify covered products have resulted in significant penalties, from 10’s of thousands to in some cases 100’s of thousands of dollars in fines.

Manufacturers that have proper test reports will have to go through their test data in order to fill in the CCMS templates, by next Spring’s deadline. Manufacturers who do not have proper test reports will need to get started right away to meet the compliance deadline. The DOE GSL pre-publication final rule document can be found here.

Special thanks to Dave Gatto, Director of QC/Compliance at Westinghouse Lighting.

David Shiller

David Shiller is the Publisher of LightNOW, and President of Lighting Solution Development, a North American consulting firm providing business development services to advanced lighting manufacturers. The ALA awarded David the Pillar of the Industry Award. David has co-chaired ALA’s Engineering Committee since 2010. David established MaxLite’s OEM component sales into a multi-million dollar division. He invented GU24 lamps while leading ENERGY STAR lighting programs for the US EPA. David has been published in leading lighting publications, including LD+A, enLIGHTenment Magazine, LEDs Magazine, and more.

See Full Bio