February 21, 2025
Regulatory Reset: DOE Delays Lamp Testing Standards
New administration seeks feedback from industry stakeholders before enforcing updated testing requirements
The U.S. Department of Energy (DOE) has announced a delay in the implementation of new energy efficiency test procedures for various appliances, including General Service Lamps (GSLs), central air conditioners, heat pumps, and clothes washers and dryers. This decision, published in the Federal Register, reflects a broader review process initiated by the new presidential administration following the issuance of an executive memorandum on January 20, 2025.
The changes effectively delay the compliance deadlines set by a previous rulemaking finalized during the final month of the Biden administration. This delay moves the enforcement date from January 7, 2025, to March 21, 2025, allowing the incoming administration under President Trump to reassess recent regulatory measures in line with new policy priorities.
Background: What Was Originally Planned?
The DOE has introduced updated testing procedures for GSLs to ensure accurate energy efficiency assessments. The rule clarified testing requirements for several types of lamps:
- Non-Colored Lamp Testing: Prohibited testing colored lamps as white light sources, ensuring accuracy in efficiency ratings.
- Component Isolation: Required disabling non-light-affecting components (e.g., smart features, speakers) during testing to avoid skewing results.
- Non-Integrated Lamps: Required these lamps to be tested with specific ballasts or drivers compatible with the manufacturer’s recommendations.
- Tunable CCT Lamps: Originally mandated testing at a correlated color temperature (CCT) of 2700K to reflect common usage settings.
The compliance deadline for these new testing procedures was originally set for July 15, 2025.
Key Changes Introduced by DOE
This publication delayed the effective date of these new testing procedures and introduced several additional clarifications and changes. These include:
- Delay in Compliance: The effective date for GSLs' new testing procedures has been moved from January 16, 2025, to March 21, 2025. Compliance deadlines, however, remain at July 15, 2025 unless further delayed.
- Revised Testing for Tunable White Lamps: Instead of testing tunable white lamps at 2700K, the update would mandate testing at maximum power across all settings. This aligns DOE testing requirements with ENERGY STAR and California Title 20 standards, reflecting real-world consumer use and ensuring consistency across jurisdictions.
- Expanded Definitions for Ballasts:
- Incorporates High-Intensity Discharge (HID) lamp ballasts into testing procedures.
- Provides a clear hierarchy for selecting ballasts based on manufacturer compatibility lists and commercial availability.
- Smart Lamp Testing Revisions:
- Clarifies procedures for testing lamps with integrated smart features (e.g., sensors, cameras).
- Requires disabling non-light-related functions during energy efficiency testing unless this would permanently alter the product.
- Public Comment Period:
- DOE has invited industry stakeholders to submit comments on potential further delays or amendments to the testing procedures by March 7, 2025.
Industry Implications
For manufacturers and stakeholders in the lighting industry, these delays provide additional time to adjust manufacturing and testing procedures to meet the revised requirements. However, the uncertainty introduced by the ongoing regulatory review could delay new product launches or necessitate additional compliance investments if further changes are introduced.
The delay also reflects the broader regulatory approach of the new administration, which could lead to a reassessment of energy efficiency priorities in future rulemaking processes.
Comparison of Key Changes
| Feature | January 2025 plan | February 2025 changes |
|---|---|---|
| Colored Lamp Testing | Prohibited testing as colored lamps | No major change |
| Non-Light Component Testing | Required disabling components during testing | Clarified to exclude altering lamp functionality |
| Tunable White Lamp Testing | Tested at 2700K | Tested at maximum power output, regardless of CCT |
| Ballast Selection for Testing | Manufacturer-specified ballasts | Expanded to include HID ballasts, commercial availability considered |
| Smart Lamp Testing | Basic standby instructions | Detailed clarification for non-light-related components |
| Effective Date | July 15, 2025 | Delayed to March 21, 2025 for enforcement; compliance deadline remains July 15, 2025 |
With the delay in effect until March 21, 2025, manufacturers should monitor potential further regulatory changes. The DOE has signaled openness to additional comments, meaning the regulatory landscape for GSLs and other energy-efficient appliances may evolve further in the coming months.
