See You in Court. Title 20 Under Pressure.

Since the soon-to-be implemented Title 20 regulations were announced in 2016, there has been widespread opposition. It just got stronger.

Plaintiff: National Electrical Manufacturers Association

Defendant: California Energy Commission

Case Number: 2:2017cv01625

Filed: August 4, 2017

Court: California Eastern District Court

Office: Sacramento Office

SACRAMENTO, CA: The National Electrical Manufacturers Association (NEMA) has filed legal action against California Energy Commission (CEC). The increased thresholds and more stringent Title 20 regulations for general service lamps, (including many retofit downlights) with bases E12, E17, E26, GU24. It also affects smaller diameter directional LED lamps including MR16, MR11, Par, R-type with diameters less than or equal to 2.25".

Many lighting stakeholders have been voicing concerns for the thresholds which are virtually leading these source types to have a minimum CRI of 90. Manufacturers seeking to comply with the regulations are investing considerable resources to ensure that all lamps and fixtures manufactured after January 1 comply with the regulation. The additional costs can create tighter margins that could possibly be spread throughout manufacturers' non-Title-20 product lines. Conversely, some say that this measure could create a huge uptick in 90+ CRI product demand (and manuifacturer buying power) that passes along more affordable high-CRI solutions to other markets outside of California.

With January just 4.5 months away manufacturers, distributors and retaliers are already prepping for the changeover. NEMA's legal action may create some relief, but until there is any definitive verdict, plans must remain in motion to address these thresholds. Not to be overlooked, a second wave of regulations take effect just 18 months later in July 2019, as the efficacy and performance bar is raised to new heights, that may also be a concern for manufacturers.

Most General Service LED Lamps and Retrofit Downlights with E12, E17, E26, GU24 bases

Smaller diameter (<=2.25") directional LED lamps including MR16, MR11, Par, R-type

(1) Must have luminous efficacy of at least 80 lumens per watt.

(2) Must have a minimum luminous efficacy of 70 lumens per watt or greater and a minimum compliance score of 165 or greater, where compliance is calculated as the sum of the luminous efficacy and CRI.

Full details: Download the entire Title 20 Code of Regulations (27MB)

(go to page 309 for the good stuff)

August 15, 2017