Are ceiling fan light kits that provide up-lighting (i.e., directed at the ceiling) subject to the same EPCA requirements as traditional ceiling fan light kits (i.e., directing light downward)?
Yes. In its December 2006 Test Procedure Final Rule, DOE specifically addressed the issue of ceiling fan light kits that direct light upward in a discussion about how the standard would apply to one particular type of ceiling fan light kit. DOE clarified that the requirements of traditional (i.e., directed downward) ceiling fan light kits would also apply to light kits designed to direct light upward. 71 FR 71340 (Dec. 8, 2006). On this point, DOE stated, “EPCA expressly subjects ceiling fan light kits with sockets other than medium screw base sockets and pin-based sockets for fluorescent lamps to the wattage limitation requirement. It is conceivable that some ceiling fan light kit designs could provide ‘up-lighting’ if the lamps installed in the ceiling fan light kit are directed upward. Thus, these ceiling fan light kits would be subject to the 190-watt limitation.” 71 FR 71340, 71346-47 (Dec. 8, 2006). In other words, any ceiling fan light kit that directs light upward (in whole or
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