In the letter to all stakeholders, EPA responded a series of amendments for
the purpose of improving transparency and increasing flexibility, saying that it
has seriously considered all suggestions and have published them on the Lighting
normative's website for public review, and comes with a summary of the comments
EPA has responded. The final draft retains the key elements of the draft 4,
added some minor modifications and further refined the dimming requirements.
Notably, the final draft allows new models automatically to pass
certification, as long as the changes in these models will not violate any
performance standards or any other requirements of this specification. In
addition, the new draft updates the "tolerance" section to make the specific
tolerance consistent with the UL1993 safety report requirements; the test data
of measuring the temperature change has also been extended. The final draft also
defined the tolerance range of luminous efficiency and light output value.
References to new models have been removed from the specific product variation
section. The specification notes that any lamp variant of a certified product
may be selected for verification testing and the results from such random
testing will impact the certification for all variants certified that are using
the same representative model test data. New models that fall outside of the
allowed tolerances that exempt it from fresh certification must undergo a
minimum of 3,000 hours of testing before any Energy Star certification can be
granted.
For initial lifetime claims of 25,000 or less hours, Energy Star
certification can be obtained after just 3,000 hours of testing if a certain
percentage of lumen maintenance is achieved. This required percentage is based
on the claimed lifetime. The higher the claimed lifetime, the higher the
percentage of the original lumen output must be maintained for the interim
certification. However, testing of the lamp must continue through 6,000 hours
for full lifetime certification. In a similar fashion, for lifetime claims
between 30,000 and 50,000 hours can receive interim certification after 6,000
hours of testing if a certain percentage of lumen maintenance is achieved. For
full lifetime certification of 30,000 or more hours, the testing must continue
to specific hour values based upon the lifetime being claimed.
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