Terms for General Purpose Lights

On this page:

• Compact Fluorescents Lamps (CFLs)
• Incandescent Lights (or Lamp)
• General Purpose Lights
• Halophosphate Fluorescent Lamps
• High Output or Very High Output Straight (Linear) Fluorescent Lamps
• Homogeneous Material
• Straight Triphosphate Fluorescent Lamps with a Long Lifetime
• Preheat Fluorescent Lamps
• Specialty Lighting
• Straight (Linear) Fluorescent Lamps
• Straight (Linear) Fluorescent Lamp used for “Special Purposes”
• State Regulated General Service Incandescent Lamps
• Solder
• Triphosphate Fluorescent Lamps

Compact Fluorescents Lamps (CFLs)

Compact fluorescents lamps (CFLs) are usually single-based florescent lighting with a plug-in or screw-in base and are generally smaller and more compact than linear fluorescents. They include bare and covered CFLs, all wattages and all shapes (twist, loop, globe, a-shape, flood, bullet, candle flame, etc.). Some CFLs are designed to replace incandescent lighting in any type of lighting fixture. There are two general categories of CFLs:

• CFLs with integrated ballast, which typically have a screw-in base
• CFLs with non-integrated (separate) ballast, which often are pin-based

Incandescent Lights (or Lamp)

Incandescent lamps include traditional light bulbs that emit light by passing electric current through a filament, including halogen lamps. The California Energy Commission (CEC) has defined an “incandescent lamp” as “a glass enclosure in which light is produced by a filament of conducting material heated by an electric current.” (Cal. Code Regs., tit. 20 § 1062, subd. (k))

General Purpose Lights

Health and Safety Code section 25210.10 defines “general purpose lights” to include “lamps, bulbs, tubes, or other electric devices that provide functional illumination for indoor residential, indoor commercial, and outdoor use.” Some examples may include:

1. Compact Florescent lamps
2. Straight (linear) fluorescent lamps
3. Incandescent lights (including halogen)
4. Light Emitting Diodes (LEDs)

The definition of “general purpose lights” excludes the following specialty lighting:

Halophosphate Fluorescent Lamps

The inside of a fluorescent lamp is coated with a phosphor powder, which produces visible light when struck by ultraviolet light. Various blends of phosphors are used in fluorescent lamps to determine the type of light emitted (cold, cool, warm, etc.).

Halophosphates are an older class of phosphors that are limited in their ability to provide a high coloring rendering index (CRI). A light tube’s or bulb’s CRI is a measure of how accurately the colors of objects appear under its light. The higher the number the closer the colors are to natural light.

Most halophosphate fluorescent lamps have a CRI of less than 80. Most halophosphate straight (linear) lamps (LFLs) are T12 models. Other less common halophosphate sizes include T8s, T9s and T5s as well as T6s and T17s.

Please note: Not all T12 lamps use halophosphate phosphors. Some T12s, which typically have a CRI of 80 or more, are triphosphates. As triphosphate fluorescent lamps, the triphosphate mercury requirements set forth in RoHS exemption – Application 2 may be applicable.

Also, some T12 triphosphate fluorescent lamps with a high CRI are considered linear fluorescent lights used for for “special purpose” because they are designed to be shatter resistant or are used for displays, signage, backlighting, appliances, aquariums or as plant lights. These may be exempted from EU RoHS requirements for mercury content under RoHS exemption – Application 3.

High Output or Very High Output Straight (Linear) Fluorescent Lamps

Health and Safety Code section 25210.9, subdivision (e) exempts high output and very high output straight (linear) fluorescent lamps greater than 32 millimeters in diameter from the RoHS Directive hazardous substance restrictions.

“High output” and “very high output” straight (linear) fluorescent lamps usually have a lower starting temperature and a higher lumen output than standard fluorescents. The words “high output” or “very high output” are usually abbreviated on the bulb as HO or VHO. These lamps are typically used for outdoor lighting, sign lighting, coolers and freezers. The most common types are T12/HO or T12/VHO, but there are also some high output/very high output T5s and T8s.

The ballasts for high output and very high output lamps are usually larger than standards types and they tend to put out a lot more heat. Some HO lamps also have a single pin end (T12s specifically) and others have a recessed double contact end which does not match up to fixtures designed for standard fluorescent light bulbs.

Some high output and very high output lamps used for general purpose lighting are covered under Section 25210.9, subdivision (e), while others are not. In addition, mercury content may not be restricted in most T5 and T8 HO and VHO fluorescent lamps because under EU RoHS Directive exemptions they are often considered “straight fluorescent lamps for special purposes” (e.g. “lamps with special ignition features including those designed for low temperatures” or “amalgam” lamps).

Homogeneous Material

The term “Homogeneous material” is defined in RoHS Directive guidance documents to mean “a material that cannot be mechanically disjointed into different materials.” (Frequently Asked Questions on Directive 2002/95/EC on the Restriction of the Use of certain Hazardous Substances in Electrical and Electronic Equipment (RoHS) and Directive 2002/96/EC on Waste Electrical and Electronic Equipment (WEEE), p.17.)

The guidance further defines homogeneous as “is of uniform composition throughout” and mechanically disjointed as “the materials can, in principle, be separated by mechanical actions such as: unscrewing, cutting, crushing, grinding, and abrasive processes.” (Frequently Asked Questions on Directive 2002/95/EC on the Restriction of the Use of certain Hazardous Substances in Electrical and Electronic Equipment (RoHS) and Directive 2002/96/EC on Waste Electrical and Electronic Equipment (WEEE), p.17.)

Examples of “homogeneous materials” include individual types of glass, metals, alloys, resins and coatings.

Straight Triphosphate Fluorescent Lamps with a Long Lifetime

The EU RoHS Directive contains an exemption for straight triphosphate fluorescent lamps with a long lifetime which is summarized below:

RoHS Application 2. Mercury in a straight fluorescent lamp may not exceed:

8 mg in triphosphate lamps with a long lifetime

Health and Safety Code section 25210.9 references the current EU RoHS standards. However, the EU is currently debating the definition of “long” lifetime triphosphate lamps. It has been proposed to amend the EU definition “long lifetime” to be > 25,000 hours when tested on a modern electronic ballast (equivalent to an “instant start” ballasts in the US) and turned on and off every 3 hours (“three hour starts”). If the EU amends the RoHS Directive to incorporate this revised criterion for “long lifetime,” it may be applicable in California as well.

Generally, the term “standard life” is used by the lighting industry to describe a fluorescent lamp with a rated life of 24,000 hours or less, when tested on an electronic ballast with three hour starts. This is consistent with the current EU proposal to define “long lifetime” to mean having a rated life of > 25,000 hours.

Manufacturers usually label triphosphate fluorescent lamps with a life > 24,000 hours with a symbol or word to differentiate them from “normal” lifetime lamps (e.g., (LL) long life, (XLL) extra long life, PLUS, (XL) extra life, (SXL) super long life or (XP) extended performance).

Preheat Fluorescent Lamps

Health and Safety Code section 25210.9, subdivision (e) exempts preheat straight (linear) fluorescent lamps from RoHS Directive hazardous substance restrictions.

Preheat fluorescent lamps are designed to be used in fixtures with a starter – a switch that briefly allows electrical current to run through the lamp’s filaments. The filaments heat the gas inside the lamp, which allows electricity to flow. Preheat fluorescent lamps can be identified from their relatively short rated life (5,000 to 9,000 hours) and their relatively low CRI (50-70). The lamp life will usually be indentified in most manufacturers’ catalogs as the “average rated life,” and many of them are classified as halophosphates.

Specialty Lighting

California law excludes “specialty lighting” from the definition of general purpose lights. Specialty lighting includes the following lights:

Straight (Linear) Fluorescent Lamps

Straight (linear) fluorescent lamps generally have a double–pinned base. Their shape and size are expressed by means of a code consisting of the letter “T,” meaning the bulb is tubular, followed by a number. The number is the diameter of the bulb in eighths of an inch. (T2 – T12). Fluorescent tubes are available in lengths ranging between 6 inches and 96 inches (8 feet). The color properties of straight fluorescents lamps are determined by the phosphors used to coat the inside of the tube.

The EU RoHS Directive does not restrict the quantity of mercury in lamps that do not fall into one of its specific exemption categories (see RoHS exemption – Application 4).

A guidance document issued by the United Kingdom (UK) Department for Business Enterprise and Regulatory Reform (BERR) to assist those placing EEE on the market in the UK provides the following examples of lamps that are not subject to mercury restrictions: non-linear lamps such as u-bent and circular models, induction fluorescents, neon lamps and high intensity discharge lamps – including mercury vapor, high and low pressure sodium, and metal halide lamps.

Straight (Linear) Fluorescent Lamp used for “Special Purposes”

The EU RoHS Directive does not restrict the quantity of mercury in fluorescent lamps for special purposes. The UK Guidance lists the following examples of halophoshate fluorescent lamps used for “special purposes”: lamps used for tanning, lamps used in appliances such as refrigeration units, black lights (i.e., ultraviolet lights), aquarium and shatter-resistant models, long length lamps (greater than 1800mm in length), disinfection lamps with special components (e.g. integrated reflectors or external protection sleeves), lamps with special ignition features (e.g. designed for low temperatures), amalgam lamps, exit signs, and LCD back light lamps. (This is list of examples and should not be considered all-inclusive.)

State Regulated General Service Incandescent Lamps

Health and Safety Code section 25210.9 subdivision (g) exempts “state-regulated general service incandescent lamps” and “enhanced spectrum lamps” as defined in subdivision (k) of Section 1602 of Title 20 of the California Code of Regulationsuntil January 1, 2014 from hazardous substance restrictions.

The California Energy Commission defines a “state regulated general service incandescent lamp” as a standard incandescent or halogen type lamp that meets all of the following criteria:

1. It is intended for general service application and has a medium screw base;
2. It has a wattage rating > 25 watts and < 150 watts;
3. It has a rated voltage range at least partially within 110 and 130 volts;
4. It has a bulb finish of the frost, clear or soft white type; and
5. It has one of the following (or equivalent) shapes as defined in ANSI C78.20-2003: A-15, A-19, A-21, A-23, A-25, PS-25, PS-30, BT-14.5, BT-15, CP-19, TB-19, CA-22.

The California Energy Commission has also defined enhanced spectrum lamps in regulation.  For more information on enhanced spectrum lamps, see subdivision (k) of Section 1602 of Title 20 of the California Code of Regulations.

Solder

The EU RoHS Directive contains an exemption for lead from MCV restrictions when it is used for “high temperature-type solders,” (see RoHS Exemption – Application 7)

UK guidance defines solder as “an alloy used to create metallurgical bonds between two or more metal surfaces to achieve an electrical and/or physical connection.”

The UK guidance provides this information, which may be helpful in determining whether and when the “high temperature” exemption applies to solder used in lighting equipment:

“The high melting temperature type solder exemption has been introduced to allow the use of lead in solders for specific applications (such as in power semiconductor package manufacturing), for which viable lead-free alternatives have not yet been identified. This exemption is permitted as there are no alternative alloys with similar melting point and which are ductile. The high electrical conductivity and unique mechanical properties of such a high melting point tin-lead alloy make the material malleable and better able to withstand both temperature and physical stress. Such properties ensure fewer defects during manufacturing and high reliability throughout the life of the component, thereby also resulting in fewer components going into the waste stream.”

Triphosphate Fluorescent Lamps

The inside of a fluorescent lamp is coated with a phosphor powder, which produces visible light when struck by ultraviolet light. Various blends of phosphors are used in fluorescent lamps to determine the type of light emitted (cold, cool, warm, etc.).

Triphosphates (also referred to as “tri-band phosphates”) are a newer class of phosphors used to make fluorescent lamps that are more efficient than the older halophosphate type lamps. Most triphosphate fluorescent lamps have a relatively high CRI (>80) and a rated life of 15,000 hours or more. Straight triphosphate fluorescent lamps are commonly available in five types:

1. T5s (except preheat models)
2. T8s (except preheat models)
3. T10s
4. T2s (if they are cold cathode tubes, these bulbs are exempted as “special purpose” lamps)
5. T12s with a high CRI (usually >80) designed to run on an electronic ballast.