Why Can't These Light Bulbs Ship to California? An Overview of the California Energy Commission's Title 20

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The State of California has historically been a leader in promoting energy efficiency at the policy level, oftentimes by requiring manufacturers across a range of industries to meet certain efficiency, pollution control or performance standards.

The total amount of energy required to operate light bulbs and lighting systems across the entire state of California is obviously quite significant, so the California Energy Commission (CEC) has always had a vested interest in reducing the amount of energy that lighting products consume overall.

In recent years, the CEC has adopted a new set of regulations called Title 20, in an attempt to accelerate the adoption of LED-based lighting. Unfortunately, the rollout of Title 20 has caused frustration for some customers based in California who are currently unable to purchase certain light bulbs.

If you are a California-based consumer wondering why a company would ever refuse to sell their lighting products to a customer, this article is for you!

What are the Title 20 requirements?

The CEC Title 20 regulations cover a very wide range of electrical appliances. For lighting products, Title 20 dictates a set of specific performance standards for "general service lamps" which cover any light bulbs that have a screw-base such as E12, E17, E26 or GU-24.

Some of the most common types of household lamps, such as A19 bulbs and BR30 lamps, use a E26 lamp base, which makes them subject to the Title 20 requirements.

Lamps that are subject to Title 20 requirements are evaluated on the following:

  • Luminous efficacy of 80 lumens per watt

  • Color point (color temperature / Duv) that is within an acceptable range

  • Color rendering, based on a sliding scale that also considers luminous efficacy

  • Sufficient light distribution appropriate for the lamp shape

  • Rated lifetime of 10k hours or more

  • Power factor of 0.7 or higher

As you can see, the list of requirements above (which have been significantly simplified from their original form) are quite lengthy and go far beyond just basic efficiency metrics such as lumens per watt. You will also notice that rather than an explicit ban on incandescent or halogen lamps, they have instead been effectively banned due to their low luminous efficacy and short lifetimes that fall far short of these requirements.

You will also notice many requirements on color quality that are not directly related to efficiency. The reason these have been included is to ensure that consumers "feel good" about the light produced by these energy efficient alternatives, a lesson that was learned from the serious consumer backlash during the previous push for the adoption of CFL and fluorescent lamps. You yourself may find that you still harbor some negative feelings about these first-generation energy efficient bulbs which oftentimes had insufficient color rendering or color temperatures inappropriate for residential lighting installations.

Although California boasts a sizable population and economy, many manufacturers and resellers continue to produce lighting products that do not meet the requirements above, since they may believe that the cost of meeting the requirements are simply not worth it, especially if the bulk of their customer base is outside of California.

What is the process for a product to be considered Title 20 compliant?

In order to effectively enforce the regulations laid out in Title 20, the CEC has strict rules for manufacturers and companies who sell Title 20 lighting products to California consumers.

Manufacturers must first submit third-party testing reports to verify that the products do indeed meet the Title 20 requirements. After review, the CEC will check the reports to verify compliance, and if applicable, approve the product for sale to California consumers.

Until a light bulb product is approved for sale under Title 20, a manufacturer or seller is forbidden by California state law to sell the product to any California consumer, with harsh penalties for any violations.

What happens if a light bulb is NOT Title 20 compliant?

We live in an age now where we no longer automatically head down to the local hardware store when a light bulb goes out. Instead, we might consider turning to our computers and smartphones. With a few clicks and keystrokes, online light bulb sellers will have your lights delivered to your door.

If you are a consumer based in California, you will find that your local brick-and-mortar hardware store sells only Title 20 compliant lamps (with the exception of old inventory). Your selection might be quite limited due to the Title 20 restriction, though you can be assured that all of the bulbs on the shelf can legally be sold to you.

On the other hand, if you're shopping online, you may find a much wider selection of lighting products, but encounter situations where a perfect lighting product shows the dreaded "unable to ship to California" message if that particular product does not meet the requirements or is not yet approved by the CEC.

If that happens, unfortunately, there really isn't anything you can do as both online sellers and brick-and-mortar stores are subject to this restriction. For online sellers, the regulations prohibit the seller from shipping non-compliant bulbs to any shipping address located within the state of California, and similarly, any physical storefronts located within the state of California are forbidden from selling non-compliant Title 20 lamps.

Is it illegal to use non-compliant Title 20 light bulbs in California?

Do keep in mind that the information provided here does not constitute legal advice, and we cannot be held liable for any legal or other consequences that arise from the use of this information.

We are currently not aware of any regulations that prohibit individual consumers from actively using a non-compliant Title 20 light bulb in the state of California, or otherwise transporting them into the state if they are for personal use only (not for resale).

It is our belief that it would seem unreasonable, for example, if the CEC were to tell someone moving their personal residence and belongings from Phoenix to Los Angeles that they would need to have their U-Haul inspected, and dispose of their non-compliant Title 20 LED lamps prior to completing their relocation.

What are the most common reasons a light bulb fails to meet Title 20 requirements?

The best way to understand why a bulb is not Title 20 compliant is to either review the specifications provided by the manufacturer and compare them against the requirements, or ask the company directly for any additional insights. Anecdotally, we have seen that many of our competitors' lamps do not meet the Title 20 requirements due to poor color rendering scores.

Superficially, the Title 20 requirements for color rendering do not seem difficult to meet, as the CRI requirement is a relatively low 82. A second part of the requirement, however, is that each of the eight R-scores must also meet a minimum of 72. Effectively, this means that even if the CRI score (which is an average of the eight R-scores) is a decent 85, if any of the individual sub-scores that make up this average fall below 72, the light bulb fails to meet the Title 20 requirement for color rendering.

Why do some Waveform Lighting products not meet Title 20 requirements?

UPDATE June 7, 2021: Our 10 watt A19 flicker-free lamps are now Title 20 compliant! See here for details.

Despite our excellent color rendering, some of our products do not meet Title 20 requirements and cannot be shipped to our customers in California. As of 2020, our 10 watt A19 flicker-free lamps, which include our CENTRIC HOME™, DAYLIGHT™, NorthLux™ and D50 series lamps, do NOT meet the Title 20 requirement for a power factor rating of 0.7 or higher.

Power factor is not a commonly encountered electricity concept and can be a bit tricky to understand, but you may find the following explanation helpful. At a very basic level, power factor is a ratio of how much power is consumed versus how much power generation and transport capacity is needed to operate the product. A low power factor device, for example, might only consume 10 watts, but require 20 watts of power generation and transport capacity at the power plant. While inconsequential for a household, low power factor values can add up, and public utilities that the CEC works with, and they certainly have a vested interest in keeping power factor values as high as possible in order to reduce inefficiencies caused by power factor losses.

Waveform Lighting's 10 watt A19 lamps were designed with flicker-free light output as the first and foremost concern, and unfortunately we were only able to achieve a power factor rating of 0.6. Consequently, these lamps are currently banned for sale in California and we are unable to ship them to our California customers.

We receive many inquiries from our valued customers in California asking about our flicker-free A19 lamps, and we do sincerely regret that we are unable to sell our lamps in California at this time. We are working on some product modifications that meet the power factor requirement while maintaining flicker-free light output, and hope to have them available in the very near future.

In the meantime, our A19 filament lamps and BR30 lamps are Title 20 compliant and may be viable alternative options for our California customers.

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