California’s Title 20 poses challenges for lamp sellers

Energy-saving measure requires manufacturers to include a CFL bulb inside packaging

Janice Chamberlain, Jenny Heinzen York, March 9, 2010

Title 20, a California law intended to drive down electrical energy consumption in the state, is having a noticeable impact on manufacturers, importers and retailers who produce or sell portable lamps.

Clark Linstone, CFO of West Coast retail chain Lamps Plus and chairman of the American Lighting Association’s Government Affairs Committee, told Home Accents Today that Title 20 changes were used to meet a portion of the energy savings required by the Huffman bill in the California legislature. The bill aims to reduce 2018 average statewide electrical consumption by not less than 50% from 2007 levels for indoor residential lighting, and not less than 25% from 2007 levels for indoor commercial and outdoor lighting.

The legislation outlines four options to compliance: (1) A dedicated fluorescent socket option; (2) a GU-24 socket not rated for incandescent; (3) an LED light engine meeting certain requirements; and (4) including the appropriate compact fluorescent light bulb in the box with the product. The regulation allows for a compact fluorescent light bulb to be packed in the box so that lighting companies can continue to manufacture and sell product with a regular screw-in socket.

“Title 20 allows for a four-prong means of creating energy efficiency for portable products, excluding torchieres which are already federally regulated. This is a superior solution to adding a 35-watt limiting device to portable lighting product.”

The ALA was active in adding the “bulb-in-a-box” provision to the regulations, he said.
“The whole idea behind putting a CFL into the box is that the consumer will likely use the bulb that comes with the product. They can use an incandescent light bulb in the product if they prefer another light source. They will however in all likelihood use the CFL somewhere else in their house.”

Linstone said the strategy will introduce CFLs to people who are not already using them. Once they become comfortable with the energy savings and the performance, they will probably continue to purchase CFLs as replacement bulbs for other products.

“The ‘bulb-in-a-box’ regulation would allow consumer choice and still provide energy-efficiency,” Linstone said. “There are multiple avenues to energy-efficiency, but this is beneficial to manufacturers and consumers because requiring a dedicated socket would limit the product assortment as many manufacturers could not afford to create products just for California.”

Linstone said the implementation of the legislation has been “extremely difficult. We have had conversations with all our manufacturers and have had to do a lot of training of our store staff.”

Though Title 20 only applies to California at this time, it is likely to become federal legislation, as similar language is included in the current energy bill which is stalled on Capitol Hill.

“It’s much better to deal with these types of product issues on a national basis rather than on a state-by-state basis,” Linstone said.

Fine Art Lamps got busy early to address the Title 20 changes, according to Director of Marketing Ed Leshansky. “As a company, our engineering staff alerted management to the pending legislation and drove the company’s processes to make and distribute compliant product,” he said.

“In anticipation of Title 20 law going into effect on Jan. 1, 2010, Fine Art Lamps sent a letter in December to all customers alerting them of the new California law and our ability to deliver compliant product. The letter also stated that all Title 20-compliant merchandise would have a label on the packaging identifying it as Title 20 compliant. This step was added to ensure that any of our customers who receive product in any state other than California, but intend on shipping it to the state of California, would easily identify the compliant product required.”

Fine Art Lamps has 248 compliant portables that will ship to California with the bulb(s) in the packaging. “Fine Art Lamps attempted to convert all portables into Title 20 compliant and were successful in virtually all cases with some very few exceptions that simply prohibited the use of the fluorescent bulb,” Leshansky said. “There was a nominal up-charge incurred for all Title 20-compliant product to cover the added cost structure of the cost of the bulb(s), labor to package and label, etc.”

But the costs and the extra work were worthwhile, Leshansky said, because as an industry leader, it’s what customers have come to expect from the company. “Our ability to quickly establish the policies and make available compliant product, inform our customers, and help them avoid being non-compliant is part of the added-value of transacting with a leader like Fine Art Lamps,” he said.

For more information on Title 20 and how it impacts your business, visit or

For more on this story, see the March issue of Home Accents Today and watch for updates here at

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