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Overview: U.S. Energy Efficiency Requirements for Torchiere Lighting Products
July 2007 (07B-132)
There has been increasing global and political awareness for the need to use energy efficiently in recent history. Last year the U.S. Department of Energy (DOE) published the January 1, 2006 version of 10 CFR 430 with requirements limiting the energy use allowed by torchiere lighting products. The development of these regulations was mandated by the 2005 Energy Policy Act (EPACT 2005) and was in part based upon the work carried out by the California Energy Commission (CEC) of 2001 on energy efficiency.
However, the January 1, 2006 version of 10 CFR 430 resulted in some confusion regarding the definition of a torchiere lamp and the associated requirements. In the meantime, a number of retailers and manufacturers are anxious to begin complying with the requirements and have been seeking clarification. This spring, the DOE published information on their website, including frequently asked questions (FAQs) and interpretative guidance, to help answer questions and clarify requirements. This information can be accessed at: http://www.eere.energy.gov/buildings/appliance_standards/residential/torchieres.html
Clarification of Definition/Scope
A torchiere lamp is a portable electric lighting fixture with a reflective bowl that directs light upward onto a ceiling so as to produce indirect illumination on the surfaces below. A “Torchiere” may be built so that it includes other downward directed lamps in addition to the upward, indirect illumination. If so, the power limit applies only to the torchiere part of the design.
The 10 CFR 430.32(t) defines a torchiere as:
“[A] portable electric lamp with a reflector bowl that gives light upward to give indirect illumination.”
Additionally, the CFR requires that a torchiere manufactured on or after January 1, 2006 shall:
Consume not more than 190 watts of power AND
not be capable of operating with lamps that total more than 190 watts.
The FAQs on the DOE website state that the definition of a torchiere is affected in part by the amount of illumination it produces. DOE went on to offer that the Illuminating Engineering Society of North America (IES) has a definition for indirect lighting based on the percentage of light that is direct versus indirect. While not explicitly requiring compliance with an IES standard to show exemption, the ability to support or determine if a design may be exempt from being considered as a torchiere may depend upon photometric testing. For more information, please access the complete FAQs at: http://www.eere.energy.gov/buildings/appliance_standards/residential/torchieres.html
Compliance Options
While the CFR provides requirements, it does not provide methods for compliance to this requirement. The DOE ruled that these regulations are a design requirement and can be met by any appropriate method. Since the power draw of a luminaire is almost entirely dependent upon the selected lamp, the options for limiting power usage in a design are few. It is the opinion of Bureau Veritas that for one to sell a torchiere design luminaire to be compliant with the present and expected future forms of regulations, the options are limited to:
1) Prevent re-lamping with a higher wattage lamp – such as by designing the luminaire with integral fluorescent ballast and special contacts so only compliant lamps may be used.
2) Prevent operation of the luminaire if it is re-lamped with a higher wattage lamp by designing torchieres to use a power limiting component (like fusing) with existing socket technology. The DOE FAQ page addresses this option, considering the time for over-protection devices to operate, and the consumer interaction with the protective devices.
Future Developments
Europe’s Energy using Products Directive (2005/32/EC), a CE Marking Directive, requires companies to evaluate and improve their design, documentation and management system processes to improve and comply with energy efficiency guidelines. These are being set per product category through Implementing Measures. EU Member States have to transpose the Directive into national law by August 2007, while the first Implementing Measures are expected during the second half of 2007.
Why Compliance Matters
The future is green. Don’t be caught unprepared. Customers of electrical and electronic products want to save energy and money. Many customers are already aware of energy efficiency programs such as the Energy Star program and shop accordingly. As adoption and education of this spreads, your efficient products can be a differentiator for choice of quality and efficiency. Additionally, as the DOE’s new standards illustrate, energy efficient requirements are becoming mandatory.
How Bureau Veritas Can Assist You
 To help you determine the energy efficiency of your torchiere lamps, Bureau Veritas can measure power consumption at all of its electrical laboratories in the US, Europe and Asia. For client quality assurance (protocol) programs, we recommend testing for energy usage in addition to our two or three star safety testing program for torchiere lamps. Electrical products need to be both safe and energy efficient in today’s marketplace.
Our Engineering Services Team can further assist you with design review and technical consulting. Please contact your program manager if interested.
For More Information: For additional details on how to submit your sample or for an evaluation of your lighting design, please contact your Bureau Veritas Program Manager, Client Services Representative, or one of the following:
Technical Contacts:
Hong Kong: Patrick Wong (patrick.wong@hk.bureauveritas.com)
Taiwan: Mike Su (mike_su@adt.com.tw)
USA: Tom Heckmann (thomas.heckmann@us.bureauveritas.com)
All other inquiries:
Scott Griggs (scott.griggs@us.bureauveritas.com)
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Bureau Veritas Consumer Products Services, Inc. (“BVCPS”) provides the information in this client bulletin as a resource of general information. It does not replace any applicable legal or regulatory requirements and is provided “as is.” BVCPS will not be liable for any indirect, special, punitive, consequential or other damages (including without limitation lost profits) of any kind in connection with this client bulletin. BVCPS DISCLAIMS ALL REPRESENTATIONS AND WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, IN CONNECTION WITH THIS CLIENT BULLETIN.
Copyright © 2007 Bureau Veritas Consumer Products Services, Inc. All Rights Reserved.
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