California’s Title 20 poses challenges for lamp sellers
Energy-saving measure requires manufacturers to include a CFL bulb inside packaging
Jenny Heinzen York -- Home Accents Today, 3/9/2010 7:21:00 AM
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 www.energy.ca.gov or www.americanlightingassoc.com.
For more on this story, see the March issue of Home Accents Today and watch for updates here at www.homeaccentstoday.com.
As a wholesaler of lamps, we have found this new law at best, one of the worst things to cross our desks since SOX.
The theory behind it is reasonable, but the execution is near impossible. For companies who ship nationwide and have full-scale warehouse systems that pick and process packaging, it's a logisitcs nightmare. For any and all lamps going to CA, those ordesr now have to be manually picked, repacked with a lightbulb and moved back into the order process. The reprogramming that entails, plau the reprogramming we must do on an item level to ensure that the prodcut is labeled with the date of manufacture, as well as the shipping carton is another giant expense.
Does CA think that wholesalers just can pop in a bulb and that's that? The average cost to add one of these bulbs is not "nominal" and as soon as Californians realize how much they are going to have to pay for this, my bet is that they will not be able to afford it.
The funny thing about this is that there is no law that says the retaler MUST sell the lamp with the bulb. THe retialer could very well pocked the bulb, put in a flourescent light and call it a day.
The whole things seems totally ridiculous. What's funny is that my company was told there were no penalties for non-complaince. If it were up to me, I'd stop selling the lamps to California all together. The profit is not worth the expense.
The Constitution says that state laws cannot interfere with interstate commerce. I believe this new law is complete unconstitutional and yet another example of bad government.
Anonymous - 2010-03-09 21:19:00 EST
The theory behind it is reasonable, but the execution is near impossible. For companies who ship nationwide and have full-scale warehouse systems that pick and process packaging, it's a logisitcs nightmare. For any and all lamps going to CA, those ordesr now have to be manually picked, repacked with a lightbulb and moved back into the order process. The reprogramming that entails, plau the reprogramming we must do on an item level to ensure that the prodcut is labeled with the date of manufacture, as well as the shipping carton is another giant expense.
Does CA think that wholesalers just can pop in a bulb and that's that? The average cost to add one of these bulbs is not "nominal" and as soon as Californians realize how much they are going to have to pay for this, my bet is that they will not be able to afford it.
The funny thing about this is that there is no law that says the retaler MUST sell the lamp with the bulb. THe retialer could very well pocked the bulb, put in a flourescent light and call it a day.
The whole things seems totally ridiculous. What's funny is that my company was told there were no penalties for non-complaince. If it were up to me, I'd stop selling the lamps to California all together. The profit is not worth the expense.
The Constitution says that state laws cannot interfere with interstate commerce. I believe this new law is complete unconstitutional and yet another example of bad government.
I am wondering how this will affect the
catalog/eCommerce industry. Will companies with a
presence in California such as Lamps Plus need to sell
only compliant lighting even if it is being shipped to
another state, probably never even passing through
California?
What about importers and manufacturers that ship
lighting products all around the country from inside
California? Will they need to comply even if the lamp
is going to another state?
California is in dire straits with very high
unemployment and very deep budget cuts. While the
reason behind this law is certainly very noble, if
these situations affect suppliers or drop ship
retailers domiciled in California it will cause even
more jobs to leave the state and lower the state's
revenues even further.
Clean air and water are incredibly important, but so is
having a job that doesn't move away from your state so
you have a roof over your head and food on the table...
clearly a balancing act for California.
Steven J. Husak - 2010-03-09 12:59:00 EST
catalog/eCommerce industry. Will companies with a
presence in California such as Lamps Plus need to sell
only compliant lighting even if it is being shipped to
another state, probably never even passing through
California?
What about importers and manufacturers that ship
lighting products all around the country from inside
California? Will they need to comply even if the lamp
is going to another state?
California is in dire straits with very high
unemployment and very deep budget cuts. While the
reason behind this law is certainly very noble, if
these situations affect suppliers or drop ship
retailers domiciled in California it will cause even
more jobs to leave the state and lower the state's
revenues even further.
Clean air and water are incredibly important, but so is
having a job that doesn't move away from your state so
you have a roof over your head and food on the table...
clearly a balancing act for California.
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