In a fitting continuation of the battle for light bulbs, the US Department of Energy recently finalized rules prohibiting the sale of most general use lamps with an efficiency rating of less than 45 lumens per watt (lpw)(for anyone new to the area, “lamp” in this context means what you typically think of as a “light bulb”). While most LED lamps can meet this standard, almost no incandescent or halogen incandescent lamps can.
The new rule, which affects general service lamp manufacturers, importers, distributors, and retailers, goes into effect on July 25, 2022, but the DOE has announced a progressive enforcement approach to allow for a transition period while businesses make the required changes, included a partial sell through of existing inventory.
Background
The Energy Independence and Security Act of 2007 requires DOE to examine lamp efficiency. If DOE determined efficiency requirements should be stringent, the Act required DOE to amend the existing standard by 2017. The Act also included a backstop provision setting the minimum efficiency standard for general service lamps at 45 lpw if DOE did not meet the 2017 deadline (effective Jan. 1, 2020).
Toward the end of 2016, the Obama DOE issued regulations defining general service lamps to include most incandescent bulbs and acknowledging that the backstop provision of 45 lpw would apply to these products on Jan. 1, 2020. Then in 2019, the Trump DOE withdrew the regulations defining general service lamps and announced that it had concluded the backstop provision did not apply, effectively keeping the standard where it was. We think you know where this is going…. In 2021, the Biden DOE said the opposite, concluding that the backstop provision was triggered and issuing a regulation codifying the 45 lpw standard, effective July 25, 2022.
The new federal lightbulb efficiency standard
The new 45 lpw requirement applies to “general service lamps,” the definition of which encompasses most consumer lightbulbs including:
- A-shaped or pear-shaped bulbs; smaller
- Decorative lightbulbs shaped like a candle
- Bullet or globe (often used in chandeliers)
- Desk lamps
- Ornamental wall lights
- Cone shaped lightbulbs that have an inner reflective coating and are often used in recessed light fixtures.
This will effectively phase out traditional incandescent and halogen lightbulbs. Those bulbs currently only deliver around 14-20 lpw, but they continue to hold a large share (up to 36%, depending on the source) of the consumer lamp market. The new rules are expected to further accelerate the transition to LEDs, which easily exceed the 45 lpw requirement. DOE estimates that there are about 5.8 billion lightbulbs subject to the new rules.
A progressive enforcement approach
DOE recognizes that the new rule is a sales prohibition, which departs from the DOE’s norm of using date of manufacture in setting efficiency standards. To provide time to sell through, DOE announced that it will phase in enforcement, providing manufacturers and importers until January 2023 to meet the standard and an additional seven months, to August 2023, for retailers to sell through inventory:
A challenge for retailers
While DOE seems to think a grace period to 2023 is a boon to the industry, the order cycle for these products can include longer lead times. As a result, retailers may need to start reviewing existing inventory and purchase orders to determine the universe of potentially non-compliant products. This could include notices to suppliers and requests for information, if the retailer does not want to review products from a variety of suppliers itself. Retailers may also want to set an internal deadline for any new orders of non-compliant product to cut off the flow of new inventory based on expected sell through times.
