NEMA FACT SHEET
NEMA Analysis of California Energy Commission 45-Day Language Proposal1 for Title 20 Regulations
for LED Lamps
1. The California Energy Commission (CEC) proposes a minimum color rendition index (CRI) of 82
for lamps to be sold in California. The California Lighting Technology Center (CLTC) performed
small study of LED lamps available on the market in 20142 that was used by the CEC in its
analysis. Several of the lamps in the study scored a CRI of 82; however, LED lamps are overengineered in many parameters, including CRI, to ensure that they meet claimed performance.
This over-engineering causes manufacturing variation. Manufacturers aiming for a lamp
compliant with CRI 80 design to 82 CRI as a safeguard. While the small sampling of lamps in the
aforementioned study scored 82 CRI, their siblings from another production run could score
only 80. It follows that setting a minimum score of 82 would necessitate designing to 84-85 CRI
to ensure compliance. The sample size for each lamp type tested by CLTC was 10 or smaller,
and the lamps were sourced at the same time, likely all from the same production run. The
number of lamps tested for each type was therefore not statistically significant or
representative and fails to account for manufacturing variation in real-world production.
2. After LED chips are cut from the parent wafer, the chips are evaluated and grouped according
to their performance because they are not all the same. This process is called binning. Globally,
LED chip manufacturers design and bin LEDs to fall into groups that average either 80 or 90 CRI.
No chip manufacturers today routinely supply LEDs binned to 85 CRI. Designing LED lamps at 85
CRI in order to meet a regulatory specification of 82 CRI (or other levels besides 80 or 90 CRI)
would require a change to global LED production and binning practices. This makes no sense
because consumers cannot detect the difference between 80 CRI and 82 CRI. The
Environmental Protection Agency’s ENERGY STAR® program for LEDs specifies 80 CRI. Last year
the ENERGY STAR Lamps program accounted for almost eighty million LED light bulb sales
nationwide, and the vast majority of these bulbs were popular 80-CRI products.
3. CRI is a lighting parameter that attempts to express how colors shift when compared to a
defined source, such as incandescent light. Differences in consumer appeal for lamps with a CRI
of 80 or, alternatively, 90 or higher are typically application-dependent. However, a very high
CRI is not essential in many tasks, and many people either see little or no difference between a
high CRI of 80 and a very high CRI of 90 or have no preference for CRI above 80. In some
applications, a very high CRI of 90 can be desirable.
4. CRI is a score representing an average of eight sub-categories that examine different hues.
These sub-categories are designated as R1 through R8. An overall CRI score is the average of
these individual scores3. Of the eight, R8 is the most difficult to produce at a reasonable cost
for components with today’s LED technology. The CEC proposal would require each R1-R8
score to be at or above 72. Many lamps today can meet an R8 of 50, but an R8 of 72 is only
1
http://docketpublic.energy.ca.gov/PublicDocuments/15-AAER06/TN206375_20151015T152718_Express_Terms_45_Day_Languge.pdf
2
http://cltc.ucdavis.edu/sites/default/files/files/publication/140609-report-omni-directional-led-replacementlamps_rev140807.pdf
3
CRI = (R1+R2+R3+R4+R5+R6+R7+R8) / 8
typical of lamps that average above 90 CRI, due to current technology limits. The R8 score can
be raised with the addition of red LED chips, changes to the phosphors used in the lamps, or
the use of red-green-blue-white chip sets, but these all add significant cost4 to the light bulb,
for a performance specification that is not necessary for most the needs of most consumers.
The CEC’s specification that R8 have a score of 72 effectively mandates a minimum CRI score of
90, not 82.
5. The CLTC study identified a few LED lamps that scored a CRI in the mid- to high 80s. Some
NEMA member companies have advised NEMA that they believe these are lamps they
manufactured that represent failed attempts to produce a 90-CRI lamp. This is significant
because these “failed” lamps had high R8 scores and were significantly more expensive to
produce. The existence of these more expensive, failed lamps cannot justify the CEC’s
contention that by mandating an R8 greater than 72 they are not mandating a CRI score of 90
for all LED lamps. The cited samples were aberrations, not products that a manufacturer would
design and produce for regular sale in the market. Manufacturers compete with LED products
at either 80 CRI and slightly above or 90 CRI and slightly above, not at some point in between,
because of the LED chip-binning process.5
6. The CEC proposal includes an equation that scores an LED lamp based on CRI and energy
efficiency6. This equation was developed in response to industry concerns that very high CRI
lamps are less efficient and should not be treated unfairly by the regulation. The equation
reveals that a 90-CRI lamp can be 10% less energy-efficient than an 80-CRI lamp, resulting in an
overall energy cost for California as sales of 80-CRI lamps would be effectively eliminated.
7. Some California-based studies identify purchase price as the most significant hurdle to
consumer uptake7. The CEC staff analysis admits that more costly additional components are
likely needed to raise CRI in non-compliant lamps.8
4
See pages 89 and 91 http://docketpublic.energy.ca.gov/PublicDocuments/15-AAER06/TN206387_20151016T152059_2015_Staff_Report_Analysis_of_SDDL_and_General_Service_LED_Lamp.pdf.
5
See Item 2 above.
6
See footnote 1, page 14.
7
Fernstrom, Gary http://homeenergy.org/show/article/year/1994/id/1088/magazine/88.
8
See footnote 4.