The FTC “Lighting Facts” Label: Questions and Answers for Manufacturers
The Energy Labeling Rule requires light bulb manufacturers to give consumers key information in an easy-to-read format.
The Lighting Facts label is modeled on the Nutrition Facts label on food packages. It gives shoppers the information they need to buy the most energy-efficient bulb to meet their lighting needs. The label includes a bulb’s brightness, energy cost, life, light appearance, and wattage. In addition, the principal display panel on the front of packaging focuses on lumens, a measure of brightness, rather than on watts, a measure of the amount of energy used, and includes the estimated yearly energy cost for each bulb. Bulbs themselves also feature lumens, and in the case of CFLs, a mercury disclosure.
The FTC enforces the Energy Labeling Rule. To help you comply with the labeling and reporting requirements for common household light bulbs, FTC staff have prepared answers to some common questions we’ve been asked. The Commission's Federal Register Notice also has basic information about the labeling requirements for light bulbs.
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The FTC Lighting Facts label and principal display panel information must appear on packaging for most general service “lamps” with medium screw bases. That includes most incandescent, compact fluorescent (CFL), and light emitting diode (LED) light bulbs. The Energy Labeling Rule has several exceptions for various lamp types, so it’s a good idea to review specific definitions for answers about coverage. See 16 CFR § 305.2 and § 305.3
You must use Department of Energy (DOE) test procedures for general service incandescent lamps and medium base compact fluorescent lamps. Find them at http://ecfr.gpoaccess.gov. See subpart B to 10 CFR Part 430, 10 CFR Part 431, and 10 CFR § 429.11
For lamp types not covered by these DOE tests, you must have competent and reliable scientific evidence for the representations you make on the required label. For representations of the light output for general service light-emitting diode (LED or OLED) lamps, the FTC will accept scientific tests conducted according to IES LM79 as a reasonable basis. See 16 CFR § 305.5
The FTC offers templates to use to create your Lighting Facts and principal display panel labels.
You must ensure that you enter the correct data for your products. If you are wondering about using the ENERGY STAR logo, you may use labels with the logo only on certified models listed on the ENERGY STAR website. You also must have a Memorandum of Understanding with the Department of Energy or the Environmental Protection Agency. Energystar.gov has qualifications and certified products.
The principal display panel on the front of the product’s package must be labeled clearly and conspicuously with:
- the light output of each lamp included in the package, expressed as “Brightness” in average initial lumens rounded to the nearest five, and
- the estimated annual energy cost of each lamp included in the package, expressed as “Estimated Energy Cost” in dollars and based on the average initial wattage, a usage rate of 3 hours per day, and 11 cents ($0.11) per kWh
See 16 CFR § 305.15
The Lighting Facts label must be on the side or rear panel of the package, and must include:
- the light output of each lamp included in the package, expressed as “Brightness” in average initial lumens rounded to the nearest five
- the estimated annual energy cost of each lamp included in the package based on the average initial wattage, a usage rate of 3 hours per day, and 11 cents ($0.11) per kWh
- the life of each lamp included in the package, expressed in years rounded to the nearest tenth (based on 3 hours operation per day)
- the correlated color temperature of each lamp included in the package, as measured in degrees Kelvin, and expressed as “Light Appearance,” and by a number and a marker placed proportionately on a scale ranging from 2,600 K on the left to 6,600 K on the right
- the wattage for each lamp included in the package, expressed as “Energy Used” in average initial wattage
- the ENERGY STAR logo for qualified products, if you wish. Only manufacturers who have signed a Memorandum of Understanding with the Department of Energy or the Environmental Protection Agency may add the ENERGY STAR logo to labels on qualifying covered products, and they may add the ENERGY STAR logo to labels only on those products covered by the Memorandum of Understanding
- the design voltage of each lamp included in the package, if other than 120 volts
- for any general service lamp containing mercury, the following statement:
“Contains Mercury / For more on clean up and safe disposal, visit epa.gov/cfl.” You also may print an “Hg[Encircled]” symbol on the label after the term “Contains Mercury.”
See 16 CFR § 305.15
No. The Lighting Facts label may not include any marks or information other than those specified in the Rule. See 16 CFR § 305.15
You must print the following information on general service lamps:
- the lamp's average initial lumens, expressed as a number rounded to the nearest five, next to the word “lumens,” both in minimum 8 point font, and
- for general service lamps containing mercury, the following statement: “Mercury disposal: epa.gov/cfl” in minimum 8 point font
See 16 CFR § 305.15
No. The Rule doesn’t require you to get FTC “approval” before labeling and selling these products. But you must meet the FTC reporting requirements before distributing products that are covered by the Rule. In addition, you must comply with the Rule’s testing requirements [See What test procedures must I use for the Lighting Facts label?]
If the total surface area of the product package available for labeling is less than 24 square inches — and the package shape or size cannot accommodate the standard label — you may provide the information using a smaller linear label. See 16 CFR § 305.15
You may present the information in a second language in one of two ways: either by using separate labels for each language or by using a bilingual label with the English text in the format required by the Rule, immediately followed by the text in the second language. See a sample bilingual label. All required information must appear in both languages. Numeric characters identical in both languages need not be repeated. Note that the amendments don’t allow a trilingual label. See 16 CFR § 305.15
Starting July 15, 2013, manufacturers of general service lamps covered by the labeling requirements must post images of the Lighting Facts labels for their products on a publicly available website so that website retailers can hyperlink to the label or download it. The label for each model must remain on the website for six months after production of that model ends. See 16 CFR § 305.6
Any manufacturer, distributor, retailer, or private labeler who advertises a general service lamp on a website or in a print catalog must disclose clearly and conspicuously — on the page listing the lamp — all of the information found on the product’s Lighting Facts label, or show an image of the Lighting Facts label itself. However, this requirement applies only to websites and print catalogs that contain the terms of sale, retail price, and ordering instructions for consumers.
Starting January 15, 2014, these websites and catalogs must post the Lighting Facts label. The labels must be clear and conspicuous, and appear in close proximity to the lamp’s price on each page that contains a detailed description of the lamp. If the website hyperlinks to the image of the label, it must use the sample Lighting Facts icon (i.e. web button) provided by the FTC. The website must hyperlink the image so that consumers don’t have to save the hyperlinked image to view it. See 16 CFR § 305.20
For general service incandescent and CFL models in production, manufacturers must submit reports by March 1 every year, and reports for new models before distribution. See 16 CFR § 305.8
The Rule requires reporting for general service incandescent lamps and CFLs, but not yet for other general service lamps, like LEDs. See 16 CFR § 305.8
Manufacturers can submit the reports required by the FTC through the Department of Energy’s Compliance Certification Management System (CCMS) at https://www.regulations.doe.gov/ccms. The reports must contain the same content the Department of Energy requires under its certification rules. See 10 CFR Part 429