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How does one comply with the ENERGY STAR CFL light bulb packaging requirements and FTC labeling requirements? Follow

All products sold into the United States must comply with federal laws. As a reminder, ENERGY STAR certified compact fluorescent lamps and lamp systems must comply with the labeling requirements of the U.S. Federal Trade Commission Packaging Laws - FTC 16CFR Part 305.1-.25 76 FR 20233. The Lighting Facts label from the Federal Trade Commission is required on all medium screw base (edison base) bulbs as of January 1, 2012. FTC has created an FAQ for manufacturers  as well as a resource page for consumers on the new label. PLEASE NOTE: The FTC labeling rule does not apply to candelabra or pin base lamps – only medium screw base general service lamps.  Information on the labeling law is available at www.ftc.gov

Light output: ENERGY STAR requires 100 hour lumen output rating based on a sample size of ten lamps to be displayed on the packaging. The new FTC labeling requirements refer to the DOE test procedures for measuring the lumen output of CFLs -- the same test procedure required by ENERGY STAR. The ENERGY STAR specification references the 3% measurement tolerance for lumen output which would also apply to the average lumen output for the FTC label; however, the FTC requires manufacturers to round the average lumen output measurement to the nearest 5 lumens. The sample size required by ENERGY STAR includes five samples tested base up as in the DOE requirement but also requires five samples tested base down, so if you test to the ENERGY STAR requirements you fulfill both and may use the average of ten samples for the lumen rating on the FTC label. Mercury Labeling:

  • The FTC disclosure does not require the Hg symbol but allows manufacturers to voluntarily include it in the Lighting Facts label after the term “Contains Mercury” to comply with ENERGY STAR requirements.
  • The FTC disclosure cites epa.gov/cfl, an EPA web site for information on CFLs and mercury that is cited in the ENERGY STAR CFL V 4.0 specification.

Manufacturers should use epa.gov/cfl in the FTC label in lieu of the web sites (epa.gov/bulbrecycling and lamprecycle.org) cited in the latest ENERGY STAR CFL specification (V 4.2). Providing additional web addresses for the same information is unnecessary.

Average Rated Life: ENERGY STAR requires average rated life to be reported on the packaging. Under the old FTC labeling rule this was required to be displayed in hours; however, the new current FTC labeling rule requires life to be displayed in years, according to the hours divided by 365 and expressed by rounding to the nearest tenth of a year.

Correlated Color Temperature (CCT): CCT was not required by previous FTC labeling but was required in ENERGY STAR CFL V 4.0. The new current FTC label includes CCT thereby fulfilling the ENERGY STAR packaging requirement.

ENERGY STAR Certification Mark: The new FTC Lighting Facts label allows for the placement of the ENERGY STAR certification mark for certified products. While not required, ENERGY STAR encourages partners to continue to identify certified products with the cyan blue ENERGY STAR certification mark on the front of product packaging in addition to including the black and white version in the FTC Lighting Facts label.

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