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U.S. Department of Energy Energy Efficiency and Renewable Energy

Metal Halide Lamp Fixtures Frequently Asked Questions

Updated September 4, 2009

This page presents the U.S. Department of Energy's (DOE) answers to frequently asked questions about the provisions in the Energy Independence and Security Act of 2007 (EISA 2007) related to metal halide lamp fixtures.

General Questions

Definitions Contained in EISA 2007

Definitions Not Contained in EISA 2007

Labeling and Enforcement

General Questions

Question: What are the ballast efficiency values for compliance?

Answer: Section 324(e) of EISA 2007 requires specific efficiency values for the various types of covered metal halide ballasts. These requirements, codified at 42 U.S.C. 6295(hh), are as follows:
"(hh) METAL HALIDE LAMP FIXTURES.—
"(1) STANDARDS.—
"(A) IN GENERAL.—Subject to subparagraphs (B) and
(C), metal halide lamp fixtures designed to be operated
with lamps rated greater than or equal to 150 watts but
less than or equal to 500 watts shall contain—
"(i) a pulse-start metal halide ballast with a minimum
ballast efficiency of 88 percent;
"(ii) a magnetic probe-start ballast with a minimum
ballast efficiency of 94 percent; or
"(iii) a nonpulse-start electronic ballast with—
"(I) a minimum ballast efficiency of 92 percent
for wattages greater than 250 watts; and
"(II) a minimum ballast efficiency of 90 percent
for wattages less than or equal to 250 watts
Section 324(e) of EISA 2007 also establishes certain exclusions from the regulation. These are as follows:
"(B) EXCLUSIONS.—The standards established under
subparagraph (A) shall not apply to—
 "(i) fixtures with regulated lag ballasts;
"(ii) fixtures that use electronic ballasts that
operate at 480 volts; or
"(iii) fixtures that—
"(I) are rated only for 150 watt lamps;
"(II) are rated for use in wet locations, as
specified by the National Electrical Code 2002,
section 410.4(A); and "(III) contain a ballast that is rated to operate
at ambient air temperatures above 50°C, as specified
by UL 1029–2001

Definitions Contained in EISA 2007

EISA 2007 amends the Energy Policy and Conservation Act (42 U.S.C. 6291; EPCA), in relevant part, by adding the following definitions:

Question: What is a metal halide lamp fixture?

Answer: The term "metal halide lamp fixture" means a light fixture for general lighting application designed to be operated with a metal halide lamp and a ballast for a metal halide lamp. (42 U.S.C. 6291(64))

Question: What is a metal halide lamp?

Answer: The term "metal halide lamp" means a high intensity discharge lamp in which the major portion of the light is produced by radiation of metal halides and their products of dissociation, possibly in combination with metallic vapors. (42 U.S.C. 6291(63))

Question: What is a metal halide ballast?

Answer: The term "metal halide ballast" means a ballast used to start and operate metal halide lamps. (42 U.S.C. 6291(62))

Question: What is a ballast?

Answer: The term "ballast" means a device used with an electric discharge lamp to obtain necessary circuit conditions (voltage, current, and waveform) for starting and operating a lamp. (42 U.S.C. 6291(58))

Question: What is an electronic ballast?

Answer: The term "electronic ballast" means a device that uses semiconductors as the primary means to control lamp starting and operation. (42 U.S.C. 6291(60))

Question: What is a probe-start metal halide ballast?

Answer: The term "probe-start metal halide ballast" means a ballast that: (a) starts a probe-start metal halide lamp that contains a third starting electrode (probe) in the arc tube; and (b) does not generally contain an igniter but instead starts lamps with high ballast open circuit voltage. (42 U.S.C. 6291(65))

Question: What is a pulse-start metal halide ballast?

Answer: The term "pulse-start metal halide ballast" means an electronic or electromagnetic metal halide ballast that starts a pulse-start metal halide lamp with high voltage pulses. Lamps shall be started by first providing a high voltage pulse for ionization of the gas to produce a glow discharge, and to complete the starting process, power shall be provided by the ballast to sustain the discharge through the glow-to-arc transition. (42 U.S.C. 6291(66))

Definitions Not Contained in EISA 2007

Question: What is regulated lag ballast?

Answer: A "regulated lag ballast" is the industry term for a lag ballast with a third coil for improved lamp power regulation.

Labeling and Enforcement

Question: How do fixture manufacturers comply with EISA 2007 efficiency requirements for metal halide lamp fixtures?

Answer: As defined above, "metal halide lamp fixtures" are designed to be operated with metal halide ballasts and those fixtures must provide ballasts that meet certain efficiency requirements. For ballast efficiency measurements, section 324(c) of EISA 2007 states that "Test procedures for metal halide lamp ballasts shall be based on ANSI Standard C82.6–2005, entitled 'Ballasts for High Intensity Discharge Lamps—Method of Measurement'." As directed by EPCA, as amended, DOE is conducting a rulemaking to determine the adequacy and accuracy of this test procedure with respect to measurement of metal halide ballast efficiency.

Question: How do fixture manufacturers comply with EISA 2007 labeling requirements for metal halide lamp fixtures?

Answer:The Federal Trade Commission (FTC) established requirements for metal halide ballast/package labeling in 2008. These requirements are contained in two Federal Register notices, 73 FR 39221, July 9, 2008, and 73 FR 63066, October 23, 2008. The FTC labeling requirements relevant to metal halide lamp fixtures are codified in FTC's regulations at 16 CFR part 305.
The FTC requires an encircled capital letter "E" (i.e., circle "E" or E) for metal halide fixtures' product packaging, the ballast contained in the metal halide fixture, and all advertising/marketing materials (e.g., point of purchase merchandising, catalogs, manufacturer Website content). This symbol signifies that the product meets applicable DOE energy conservation standards and is consistent with the labeling requirements for other lighting products. Therefore, the covered metal halide fixtures (150W –500W) manufactured on/after January 1, 2009, will require the circle "E" identification mark.

Specifically, the FTC final rule amendments contain the following provisions: (1) insert metal halide lamp fixtures into the list of covered products (16 CFR 305.2(21)) and include metal halide lamp fixtures in the descriptions of covered products (16 CFR 305.3(s)); (2) require that the circle "E" be clearly and conspicuously disclosed in color-contrasting ink on the label of metal halide lamp fixture packages and the ballasts contained in those fixtures (16 CFR 305.15(c)); (3) require retail catalog sellers to include the circle "E" in their descriptions of metal halide lamp fixtures[1][1] (16 CFR 305.20(e)). The final amendments also require the circle "E" disclosures in point of sale promotional material as required for other covered products; and (4) consistent with requirements for other covered products, the final amendments add reporting requirements for metal halide lamp fixtures (16 CFR 305.8(a)(5) and (b)(1)).

For further information on labeling requirements, please see the FTC website at www.ftc.gov/energy.

Question: What is the enforcement mechanism for the standard? Is it up to the local inspectors to accept or challenge the circle "E" qualification?

Answer: DOE is responsible for enforcing Federal energy conservation standards, whether those standards were developed through a DOE rulemaking or prescribed by Congress. (42 U.S.C. 6303, 6304, 6316) DOE establishes specific enforcement regulations for each product covered by these standards, which may require manufacturers to file documents such as a compliance statement and a certification report. In a compliance statement, the manufacturer certifies its products meet all applicable regulatory requirements. In a certification report, the manufacturer provides product-specific information, such as the model number, energy consumption or efficiency, and other model-specific information that would enable DOE to determine which product class and standard the product is subject to and whether the product meets the standard. However, DOE has not yet finalized enforcement regulations for metal halide lamp ballasts. Until DOE finalizes such regulations, manufacturers will not be required to report any data to DOE, but they must still meet all statutorily prescribed standards that went into effect on January 1, 2009. If there is a question regarding compliance, DOE will contact the manufacturer to confirm compliance, and the manufacturer will need to demonstrate that the product meets the requirements of the applicable standard.

Question: Manufacturers must submit metal halide lamp fixture data annually by September 1. What data are required? Is the format the same as required by the State of California? Which agency receives the data?

Answer:The FTC established requirements for metal halide ballast/package labeling in 2008. These requirements are contained in two Federal Register notices, 73 FR 39221 July 9, 2008, and 73 FR 63066, October 23, 2008. Data must be submitted to the FTC by September 1 of each year. (16 CFR 305.8(b)(1)). Pursuant to 16 CFR 305.8(a)(5), metal halide lamp fixture manufacturers must submit the following data:

  1. Name and address of manufacturer
  2. All trade names under which the metal halide lamp fixture is marketed
  3. Model number
  4. Starting serial number, date code, or other means of identifying the date of manufacture (date of manufacture information must be included with only the first submission for each basic model)
  5. Type of ballast (e.g., pulse, probe, or electronic)
  6. Nominal input voltage and frequency
  7. Ballast efficiency (as determined pursuant to 42 U.S.C. 6293(b)(18))
  8. Lamp type and wattage (or range of wattages) with which the metal halide lamp fixture is designed to be used.

California's Title 20 (Appliance Energy Regulations) has requirements for Metal Halide Luminaires. California defines "Metal Halide Luminaire" as a luminaire that includes one or more metal halide lamps (CEC-400-2007-016). Please refer to the California Energy Commission Appliance Efficiency Program for more information about the data required to be submitted to the State of California.

Question: As a manufacturer, if I ship a ballast in a ballast enclosure, but not a fixture body (i.e., lamp holder and optical assembly) must the ballast be compliant with the EISA 2007 requirements in section 324(e)?

Answer: New metal halide lamp fixtures must meet all applicable EISA 2007 requirements, regardless of how the equipment is packaged or shipped.

Question: In the exclusions set forth under 42 U.S.C. 6295(hh)(1)(B), does the last exclusion "...contain a ballast that is rated to operate at ambient air temperatures above 50°C per UL 1029-2001" apply to any metal halide fixture that has a metal halide ballast made and marked above 50°C per UL 1029-2001?

Answer: According to Section 30.2.6 of UL-1029, "a ballast that is intended for high-ambient temperature use shall be marked 'This ballast is suitable for operation in ambient conditions not exceeding ___°C' (40, 55, 65, 75, or 90°C)." Therefore, any metal halide lamp fixture that has a metal halide ballast marked as above for high-ambient temperature use (i.e., over 50°C) would be excluded, but only if the fixture also met the other two specified statutory requirements: (1) that the fixture is rated only for 150W lamps (42 U.S.C. 6295(hh)(1)(B)(iii)(I)); and (2) that the fixture is wet-location rated, as specified by section 410.4(A) of the National Electrical Code 2002 (42 U.S.C. 6295(hh)(1)(B)(iii)(II)).