PROJECT PROPOSED REVISED STANDARD: Revision of Green Seal s Environmental Standards for Compact Fluorescent Lights, GS-5

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1 November 9, 2007 PROJECT PROPOSED REVISED STANDARD: Revision of Green Seal s Environmental Standards for Compact Fluorescent Lights, GS-5 Green Seal is revising its leadership environmental standard for Compact Fluorescent Lights (GS-5). Green Seal is inviting the participation of stakeholders to assist in the development of the revision of GS- 5. The revised standard will help consumers identify and choose environmentally preferable products and services. Proposed revisions to the standard are attached along with some background information about the proposed changes. Green Seal is soliciting suggestions and comments on these proposed revisions from the diverse stakeholders including producers, users, and general interest groups. Comments will be submitted through an online forum system. Once registered on the forum for this project, one can post comments. All registered users will be able to view all the comments and the name of the commenter. Some topics are locked from replies since they are administrative (indicated with a lock symbol). To register for the project and access the forum: Get on the following URL: Register an account; for the username please use first initial and full last name (e.g., G Seal); select GS-5 CFL ; review the disclaimer information; click Register. You should receive a welcome from the Green Seal Development Forum within one business day. There is a User Tips and a Help section available once you log in to the forum to help address questions on how to use the online forum as well as general guidelines and rules on posting comments and attachments. Green Seal has administrative rights to the forum to ensure proper use of the online forum. Green Seal will also accept comments by , fax and postal mail. Any comments received by postal mail, fax and will be posted to the online forum and will be viewable by GS-5 registered forum participants by the name of the commenter. Please refer to specific sections (see below) on which you have comments and include copies of any supporting documentation and send your comments to: Green Seal, Inc. Attn: GS-5 CFL 1001 Connecticut Avenue, NW, Suite 827 Washington, DC Or by fax: (202) (please fax no more than 10 pages) Or by greenseal@greenseal.org with GS-5 CFL in the subject header. The commenting periods on the proposed revision will be open for 6 weeks beginning November 9, Comments must be received by December 21, The forum will be closed for comments on December 21 st and no additional comments will be accepted for the scoping portion of this project after this date. Registration of stakeholders will be available until the end of the public comment period on the proposed revised standard. This is done to enable access to the draft final standard and balloting. As a result, only registered stakeholders will be able to vote. If you submit comments through another party, such as a trade association, you will need to still register yourself in order to receive and cast your ballot. Registration is open to all interested parties until the deadline.

2 All comments received on the proposed revisions will be reviewed and carefully considered during the development of the Draft Final Standard. Responses to comments will be available with the Draft Final Standard, in February If you have any questions, please contact Green Seal at (202) or By participating in the process of setting environmental standards, you play an important role in our efforts to encourage the design, manufacture, and use of environmentally responsible products and services. Thank you in advance for your participation. Sincerely, Cheryl Baldwin, Ph.D. Director of Science and Standards Background Information on Proposed Revisions Lighting continues to be a leading energy requirement in buildings. Current estimates are that 20% of home electric costs come from lighting. The life cycle analysis shows that energy consumed during lamp use is the most significant environmental impact (90% of the total environmental impact occurs during use) (EU, 1999). However, there are additional considerations including the quality and performance of the products, handling and recovery of mercury, and packaging. Scope: The scope of the standard includes energy efficient lamps. This includes those lamps used for general illumination purposes, and can include those for some special purposes such as germicidcal and bug-a-way lamps. The product group includes those with both screw based and pin based lamps and those with integrated and non-integrated ballasts. Energy Efficiency & Performance: Average initial lumen output is relatively unchanged since the last version. The groupings were modified a bit to reflect improvements in technology. Since base down often has significant reduction in output, the testing needs to be with the base up and the base down (50/50). An exception can be made when a specific position is restricted by the manufacturer and is labeled as such. The average initial lumen output is labeled on the product package. Average rated life increased to 10,000 to reflect improvements in technology. The average rated life is labeled. Starting characteristic also improved, to 1 second, to reflect current technology. 40% lamp life was added to ensure the output performance his limited variability and consistent with labeled initial lumen output. A range of 15% within the average initial lumen output is recommended. Cycle time effects lamp life. This should be considered with thresholds for performance. The EU uses a lamp cycle life greater than 20,000 when cycled for 0.5 minutes on and 4.5 minutes off for the lamp life. This is included in the proposed revisions. Since temperature affects the performance of the lamp, minimum and maximum operating temperatures should be labeled, along with the optimum operating temperature.

3 A product warranty will be required for a minimum of 2 years. Warranty information shall be on the product label. Input power and color temperature is unchanged, and will continue to be used on the label. Color rendering and safety requirements are also unchanged. Power Quality Electronic ballast CFL s are known to have power quality issues, namely with power factor and harmonic distortion to potentially interfere with electronic and signaling equipment and may cause losses in power. When CFL s are extensively used in a large facility and combined with other electronics, the total impact may be an issue. However, CFL s contribution is likely minimal overall. If a CFL s power quality is improved, with circuitry and filters, the price of the product may be higher. There is concern that a higher price for such power-factor-corrected CFL s would be too high for many consumers; given the price is already three to ten times that of incandescent lamps. Electric utilities haven t had power quality issues with CFL s in residential applications, but considering the growth CFL s and of electronic equipment in both homes and offices this may rise as an issue. The International Electrotechnical Commission (IEC) issued standards that state that lighting equipment must have a power factor (PF) better than 0.96 and total harmonic distortion (THD) below 33%. The IEC lighting standards made an exception for equipment with a rated power of less than 25 watts, such as screw-base CFL s. However, many manufacturers have been able to surpass the IEC levels even for lower wattage products (Ecobulb). Green Seal recommends that lamps have a power factor greater than 0.96 and total harmonic distortion below 10%. Mercury: There are significant environmental advantages in the use of fluorescent lamps because the energy that they consume in use is significantly lower than that for either an incandescent or halogen lamp (at least 3-4 times less), and this reduces emissions of acid gases and heavy metals released during power generation. It has been found that the CFL mercury content is less than the mercury emissions from fueling a comparable incandescent for halogen lamp (EU). However, a few actions can be taken to further reduce concerns with mercury content in CFL s given their rapid increase in sales. First, the mercury can be further decreased; second the mercury can be recovered when the lamp reaches the end of its life; and finally, the method of adding mercury should ensure safety for workers. Green Seal recognizes that mercury is still needed for effective fluorescent lamp function. The Lighting Industry has effectively reduced the mercury used in fluorescent lamps. To further this effort, earlier this year, the National Electrical Manufacturers Association (NEMA) announced a voluntary commitment to cap the amount of mercury present in each compact fluorescent lamp. Under the voluntary commitment, effective April 15, 2007, NEMA members capped the total mercury content in CFL s of less than 25 watts at 5 milligrams (mg) per unit. The total mercury content of CFL s that use 25 to 40 watts of electricity were capped at 6 mg per unit. According to Philips Lighting, their bulbs contain less than 3 mg, and some have as little as 1.23 mg (Wal-Mart, 2007). Ecobulb TM products contain 1.5 mg (Ecobulb). Sylvania has committed to reducing the mercury content to 2.5 mg by the end of 2008 (Wal-Mart, 2007). Lights of America expect that all of its bulbs will have no more than 2 mg of mercury by the end of 2007 (Wal-Mart, 2007). As a result, Green Seal recommends setting the mercury limit to a maximum of 3 mg. Workers can be exposed to mercury when it is being added to the product during manufacturing. Green Seal recommends that manufacturers use methods to minimize such exposure, with automated dosing (like pellets). Other Metal Restrictions Other heavy metals such as lead, copper, zinc, and tin are used in very limited quantities in CFL s. Nevertheless, there have been compliance issues in other industries with meeting the limits on these metals. The RoHS Directive was established in the EU for "the restriction of the

4 use of certain hazardous substances in electrical and electronic equipment". This Directive bans the placing on the EU market of new electrical and electronic equipment containing more than agreed levels of lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE) flame retardants. However, leaded glass is still prevalent in the industry. The leaded glass has been used for performance reasons. Lead used to be common in the solder, but is bein phased out. Green Seal will continue to encourage leadfree solder. However, Green Seal will not include requirements for lead-free glass. Instead, a lead-free claim is recommended in order to recognize and encourage products made without lead in the entire product. Radioisotopes Radioisotopes were traditionally included in electromagnetic ballats. These types of products are no longer the leading technology for CFL s. As a result, Green Seal will prohibit the use of radioisotopes. End of Life At the end of the lamp s life, the lamp components can be recovered. Importantly, recovery of lamp components reduces the potential of the mercury used in these products from exposing the environment and population to this hazardous material. Recycling of these products is not widespread, with 70.8% of the mercury-lamps used by business and 98% of the lamps used in homes are not being recycled (ALMR, 2004). However, recycling of lamps is increasing. Fluorescent Lamps are now covered by the Universal Waste Rule. Currently, three states, California, Vermont and Minnesota, require household recycling. Nine States require commercial facilities to recycle. Many states have Household hazardous waste days and will accept CFL s. It is recommended that Green Seal facilitate, to the extent feasible, the recovery of lamps. As a result, manufacturers shall have a program in place to encourage and facilitate recycling of lamps. This shall include information on the package, website, through customer service, and be able to take-back lamps and send them to a lamp recycling program. Lamp collection programs can be designed for all types of facilities from small to large facilities. For example, NEMA suggests that small users can participate by using a box program, where a container is provided that can be sent to any recycler via ground mail shipment. This is a prepaid program and labels and shipping papers are provided. For larger users, recyclers can arrange pick-ups to transport lamps to accumulation facilities where they are consolidated for shipment to destination facilities. Finally, for very large generators, materials can be picked up in trailer loads as needed. Recyclers typically provide customer services and containers, and will also arrange all aspects of getting lamps recycled for anyone who is interested. When CFL s are handled, the EPA 40 CFR Parts 260, , 265, 268, 270 and 273 Hazardous Waste Management System; Modification of the Hazardous Waste Program; Hazardous Waste Lamps should be followed. Packaging Including recovered and post consumer material in packaging is technically feasible. However, upper ranges of recycled content may limit the package s ability to protect the product. Further, it is likely that increasing the recovered content of paperboard packaging may increase the thickness of the material in order to meet requirements for strength (due to shorter fiber length with recovered content). With more material required to produce the package, and being transported, this may be less environmentally beneficial than a thinner package containing a lower recycled content. As a result, the recycled content is recommended to be 50% for paperboard. Green Seal will follow the recommendation by the Rigid Plastic Packaging Container Program in California that requires plastic packaging to have at least 25% post consumer material. In addition, all packaging shall be recyclable. Further, packaging content shall follow the regulations endorsed by Coalition of Northeastern Governors (CONEG) on heavy metal restrictions.

5 Optional Claims: When an elite company is able to go beyond the leadership level criteria in the standard and establish protocols which provide a greater environmental or social benefit, they should be recognized for such efforts. These types of efforts should also be encouraged, to facilitate greater adoption across the industry. Green Seal has proposed a program for such a result, an optional claim verification program. The following claims are proposed: Lead-free Made with green energy Lamp lifetime emissions offset Made with zero greenhouse emissions References: ALMR (Association of Lighting and Mercury Recyclers) National Mercury-Lamp Recycling Rate and Availability of Lamp Recycling Services in the U.S. November 2004 Ecobulb TM web site: European Union. Revising the ecolabel criteria for lamps. A report produced for European Commission DG XI.E.4 March Wal-Mart. Wal-Mart Announces Major Mercury Reduction in Compact Fluorescent Light Bulbs Press Release. May 10, 2007.

6 November 9, 2007 PROPOSED REVISED STANDARD CFL GS-5 1 GREEN SEAL TM PROPOSED REVISED ENVIRONMENTAL STANDARD FOR ENERGY EFFICENT LIGHTING (GS-5) 1.0 SCOPE This Standard establishes environmental requirements for energy efficient lighting. This includes those lamps used for general illumination purposes, and can include those for some special purposes such as germicidcal and bug-a-way lamps. The product group includes those with both screw based and pin based lamps and those with integrated and non-integrated ballasts. 2.0 DEFINITIONS 2.1 Compact Fluorescent Lamp: A fluorescent lamp of with a single base which performs the entire mechanical support function. Bulb shape may be tubular, multi-tubular, twister or spiral, reflector, globular, decorative (candle) or shaped similarly to a conventional incandescent lamp. 2.2 Conversion Kit: A set of field-installed components which converts a portable luminaire (fixture) to a permanently installed ballast adaptor, or remote ballast and socket adaptor, with a replaceable compact fluorescent lamp. 2.3 Fluorescent Self-Ballasted Lamp: A compact fluorescent electric lamp unit that incorporates, permanently enclosed, all elements that are necessary for starting and stable operation of the lamp, and which does not include any replaceable or interchangeable parts. The unit including all elements is discarded at the end of the lamp life. 2.4 Intentional Introduction: The act of deliberately utilizing a restricted material in the formation of packaging or a packaging component where its continued presence is desired in the final package or packaging component to provide a specific characteristic, appearance, or quality. 2.5 Lamp Efficacy: The quotient of the lamp lumen output divided by the power input to the lamp, measured in lumens per watt (a measure of lamp efficiency). 2.6 Post-Consumer Material: Finished products, packages or materials generated by a business or consumer that have served their intended end uses, and that have been recovered from or otherwise diverted from the waste stream for the purpose of recycling. 2.7 Primary Packaging: The material physically containing and coming into contact with the product.

7 November 9, 2007 PROPOSED REVISED STANDARD CFL GS Recovered Material: Material that has been recovered from or otherwise diverted from the waste generated after a material manufacturing process. Recovered material may include post-consumer material, cuttings, trimmings, obsolete inventories, and rejected unused stock, but does not include material capable of being re-used within the process that generated it. 2.9 Recyclable Package: The package can be collected in a substantial majority of communities, separated or recovered from the solid waste stream and used again, or reused in the manufacture or assembly of another package or product through an established recycling program: 2.10 Secondary Packaging: Any packaging or material other than primary packaging, including wrappers, boxes, and blister packs, but excluding shipping containers System Efficacy: The quotient of the lamp lumen output divided by the power input to the ballast, measured in lumens per watt (a measure of system efficiency). 3.0 PRODUCT-SPECIFIC ENVIRONMENTAL PERFORMANCE REQUIREMENTS 3.1 Efficacy and Energy Efficiency Average Initial Lumens. Average initial lumen output shall be measured in accordance with American National Standard Institute (ANSI) C reaffirmed 2003, Fluorescent Lamps Guide for Electrical Measurement Input Power. Input power to self-ballasted fluorescent lamps shall be measured in accordance with ANSI C reaffirmed 2003, Fluorescent Lamps Guide for Electrical Measurement, measuring true RMS voltage within 1% error, over the frequency range of the measured product. Input power to a compact fluorescent lamp sold in combination with a ballast adaptor shall be measured with the supplied ballast, rather than a reference ballast, as required by IES LM-41-98, IES Approved Method for Photometric Testing of Indoor Fluorescent Luminaries Ballast Factor. Ballast factor, as measured in accordance with ANSI C82.2, Methods of Measurements for Fluorescent Lamp Ballasts, 1 ANSI publications can be obtained from American National Standards Institute, Inc., 11 West 42 nd Street, New York, NY ( ) 2 IES publications can be obtained from Illuminating Engineering Sociert of North America, 120 Wall Street, Floor 17, New York, NY ( ).

8 November 9, 2007 PROPOSED REVISED STANDARD CFL GS-5 3 shall be included in the rated efficacy of ballast adaptor and conversion kit units Efficacy. Efficacy shall be determined with lumen measurements with 50% of samples with the lamp in base-up orientation and 50% of samples with the lamp in the base-down orientation, unless the lamp design is exclusively for one or the other orientations. Products shall meet the following minimum average efficacies. Compact Fluorescent Lamps Lamp Wattage Lamp Efficacy (initial lumens) (on reference ballast) <10 watt 50 lumens/watt watt 60 lumens/watt >15 watt 65 lumens/watt Self-Ballasted Lamps, and Lamp and Ballast when supplied together Lamp Wattage System Efficacy (initial lumens) <10 watt 40 lumens/watt watt 45 lumens/watt >15 watt 55 lumens/watt 3.2 Lamp Life. The average minimum rated product life span shall be 10,000 hours at 3 hours per start as measured in accordance with IES LM , IES Approved Method for Life Performance Testing of Fluorescent Lamps. In units packaged with replaceable lamps, the ballast shall be tested to assure an average minimum rating of 1 lamp life cycle of 10,000 hours, with on going testing to confirm a life expectancy of an average minimum of 4 lamp life cycles, in accordance with IES LM Mercury Lamps shall contain a maximum of 3 milligrams of mercury per unit The manufacturer shall use methods to minimize mercury exposure to workers during product manufacturing. This shall be done with automated dosing of mercury. 3.4 Radioisotopes. Lamps shall not contain radioisotopes. 3.5 Lead. Lead shall not be used in the solder components of the lamp.

9 November 9, 2007 PROPOSED REVISED STANDARD CFL GS PRODUCT-SPECIFIC PERFORMANCE REQUIREMENTS 4.1 Color Rendering Index. Lamps shall have a color rendering of no less than 80, as measured in accordance with IES , Colorimetry of Light Source. 4.2 Color Temperature. The correlated color temperature of lamps shall be determined in accordance with IES LM Operating Temperature and Starting Characteristics. Lamp optimal, minimum and maximum operating temperature shall be determined. Lamps shall start in a smooth manner within 1 second at their minimum rated operating temperature. The Ballast adaptor shall be rated to start and operate in conjunction with the ballast s intended compact fluorescent lamps % of Lamp Life. The lamp lumen output measured at 40% of the lamp s life shall be within 15% of average initial lumens. 4.5 Cycle Life. The lamp cycle life shall be greater than 20,000 when cycled for 0.5 minutes on and 4.5 minutes off for the lamp life. 4.6 Safety. Ballast adaptors and self-ballasted compact fluorescent lamps must meet the minimum safety requirements as evidence by third party certification such as Underwriters Laboratories (UL) listing or its equivalent. 4.7 Warranty. The manufacturer shall provide a product warranty for at least 2 years from the date of purchase. 4.8 Power Quality Designation. The product s power factor and total current harmonic distortion shall be tested measuring true rms voltage to an accuracy of 1% Power Factor. Power factor shall be greater than 0.96, leading or lagging Harmonic Distortion. Total current harmonic distortion in triplens shall be less than 10%. 5.0 END OF LIFE REQUIREMENTS 5.1 Lamp Recycling: Manufacturers shall have a program in place to encourage and facilitate recycling of lamps. Information on the package, as pursuit to section Recycling program access on the company website Recycling program information available through customer service

10 November 9, 2007 PROPOSED REVISED STANDARD CFL GS-5 5 Provide a take-back program. This take-back program shall at a minimum accept lamps returned by customers and send such lamps to a local recycling program. 6.0 PACKAGING REQUIREMENTS 6.1 Recyclable Package. The product s package shall be recyclable. 6.2 Recovered Material Content. Plastic packaging shall contain at least 25% post consumer material and paperboard packaging shall contain at least 50% recovered or post consumer material. 6.3 Secondary Packaging. Secondary packaging shall not be used. An exception may be made for packaging of multiple units when the total packaging (primary plus secondary) is a reduction in packaging material use. 6.4 Heavy Metal Restrictions. Restrictions. Heavy metals, including lead, mercury, cadmium, and hexavalent chromium, shall not be intentionally introduced. Further, the sum of the concentration levels of these metals present shall not exceed 100 parts per million by weight (0.01%); an exception is allowed for packages that would not exceed this maximum level but for the addition of recovered materials. Further, intentional introduction does not include the use of one of the metals as a processing aid or intermediate to impart certain chemical or physical changes during manufacturing, where the incidental retention of a residual of that metal in the final package or packaging component is not desired or deliberate, if the final package or packaging component complies with the incidental concentration restrictions of 100 ppm. 7.0 LABELING REQUIREMENTS 7.1 The Green Seal Certification Mark may appear on the packaging and may appear on the product itself. 7.2 The Green Seal Certification mark shall not be used in conjunction with any modifying terms, phrases, or graphic images that might mislead consumers as to the extent or nature of the certification. 7.3 Whenever the certification mark appears on a package or product, the product or package must contain a description of the basis for the certification. The description shall be in a location, style, and typeface that are easily readable by the consumer. Unless otherwise approved in writing by Green Seal, the description shall read as follows:

11 November 9, 2007 PROPOSED REVISED STANDARD CFL GS-5 6 This product meets the Green Seal TM Environmental Standard requirements for energy efficient lamps for energy efficiency, low mercury content, and a recyclable package. 8.0 PRODUCT INFORMATION LABELING REQUIRMENTS 8.1 Compact fluorescent lamps, self-ballasted lamps, ballast/lamp systems, conversion kits Primary Packaging Information. The following shall be displayed on the front face (the package side intended to face forward in merchandising) or adjacent side panels (not top, bottom, back or flaps) of the individual product sales packaging Total input watt rating, as specified in section Average initial lumen output, as specified in section Average rated life, as specified in section Comparison to nearest incandescent lamp wattage with equivalent lumen output within 10% maximum deviation (soft white, hour, A-19 or A-21, R20, R30, or R40 lamp as appropriate) Correlated color temperature, as specified in section The words contains mercury, dispose of properly, can be recycled and for more information contact customer service at 1800-xxx-xxxx, or local authorities ) Warranty information, with the words Two-year warranty, contact customer service at xxx-xxxx. Alternatively, a mailing address and web site can accompany this information Optimal operating temperature is XX F (YY C), light output reduces at other operating temperatures. This may be written as a temperature range Minimum and maximum operating/starting temperatures of XX F (YY C), as specified in section Ballast Adaptors.

12 November 9, 2007 PROPOSED REVISED STANDARD CFL GS Primary Packaging Information. The following information shall be displayed on the front face (the package side intended to face forward in merchandising) or adjacent side panels (not top, bottom, back or flaps) of the individual product sales packaging Total input watt rating, as specified in section Average rated life, as specified in section Applications Information. The following information (or equivalent language) on the recommended use of the product shall be displayed on the individual product sales packaging, if applicable Possible dimension fit problem with some common luminaries Not for use in enclosed fixtures Not recommended for use with photo-control devices Reduced mechanical stability possible with freestanding luminaries Replacement parts listing Not for use with 2-way, 3-way, or dimmable fixtures. 3 Refer to ANSI C , Fluorescent self-ballasted lamps-performance guide, for guidance.

13 November 9, 2007 PROPOSED REVISED STANDARD CFL GS-5 8 ADDENDUM Green Seal Criteria for Verification of Optional Claims for GS-5 Certified Energy Efficient Lighting A. SCOPE This criteria document establishes environmental requirements for optional verified claims on GS-5 certified products. Verification applications must be reviewed during the initial application for GS-5 certification. There is emphasis on demonstrated leadership in the following environmental impact areas: energy reduction, waste reduction, resource minimization (including water), emissions reduction, and biodiversity conservation. B. DEFINITIONS B.1 Carbon offsets: mitigation of greenhouse gas emissions generated using reduction measures that may be purchased from a third-party carbon offset provider. B.2 Greenhouse gas (GHG): Components of the atmosphere that contribute to the greenhouse effect including water vapor, carbon dioxide, methane, nitrous oxide, sulfur hexafluoride, hydrofluorocarbons, perfluorocarbons, chlorofluorocarbons, and ozone. B.3 Renewable energy: energy from non-depleting sources and derived from natural processes that are replenished constantly including wind, solar, water, geothermal, and biofuels. C. CLAIM CRITERIA C.1 Lead-Free: A product will be verified to contain no lead in the product when all components have no measureable amounts of lead in the product. C.2 Made with Green Energy: A product shall be verified to be manufactured with green energy if the energy requirements for product and package production was directly fueled with a minimum of 75% with renewable energy, not including any renewable energy certificate purchases. C.3 Lamp Lifetime GHG Emissions Offset: A product shall be verified to have the lamp lifetime (at least 10,000 hours) greenhouse gas emissions offset by the manufacturer. This can be done through carbon offsets.

14 November 9, 2007 PROPOSED REVISED STANDARD CFL GS-5 9 C.4 Made with Zero GHG Emissions: A product shall be verified to be manufactured with zero greenhouse gas emissions during production of the product and package. This can be achieved within the company, with proven partnerships, or through carbon offset programs. If a carbon offset program is used for 100% of the emissions, a successful emissions reduction program must be demonstrated, with 10% or greater annual reductions in emissions. D. LABELING REQUIREMENTS: D.1 The verification claim may only appear on packaging, literature, or marketing materials for GS-5 certified products. D.2 The verification claim shall not be used in conjunction with any modifying terms, phrases, or graphic images that might mislead consumers as to the extent or nature of the verification. D.3 Whenever the verification claim appears on a package, the package shall contain a description of the basis for the claim verified along with the description of the basis of certification. The description shall be in a location, style, and typeface that are easily readable; shall be on the same side of the product label as the Green Seal certification mark; and not detract from the Green Seal certification mark. Unless otherwise approved in writing by Green Seal, the description shall, as applicable, read as follows: Lead-Free: This product meets the Green Seal TM Environmental Standard requirements for energy efficient lamps for energy efficiency, low mercury content, and a recyclable package. This product was also verified to contain no measurable amounts of lead. Made with Green Energy: This product meets the Green Seal TM Environmental Standard requirements for energy efficient lamps for energy efficiency, low mercury content, and a recyclable package. This product was also verified to have been manufactured with at least 75% renewable energy. Lamp Lifetime GHG Emissions Offset: This product meets the Green Seal TM Environmental Standard requirements for energy efficient lamps for energy efficiency, low mercury content, and a recyclable package. This product was also verified to have the lifetime of the lamps greenhouse gas emissions offset by the manufacturer. Made with Zero GHG Emissions: This product meets the Green Seal TM Environmental Standard requirements for energy efficient lamps for energy efficiency, low mercury content, and a recyclable package. This

15 November 9, 2007 PROPOSED REVISED STANDARD CFL GS-5 10 product was also verified to have been manufactured with no net greenhouse gas emissions.