Comment to Energy Star Draft 3

Comments to Energy Star requirements for Integral LED Lamps Draft 3 1. The determination of efficiency of the Directional LED lamp Regarding the directional lamp requirement, minimum luminous efficacy needs to fulfill. However, this requirement may not appropriate to directional lamp. For general, domestic illumination, non-directional light sources (NDLS) are most suitable and all emitted lumens are functional. For directional light sources (DLS) that are intended for accent lighting, only the lumens that are emitted in a solid angle are functional. Any light emitted out of the solid angle is not useful and should therefore not be measured (i.e. stray light). Therefore, minimum luminous efficacy may not necessary to keep. According to EN 12665, the definition of luminous flux, luminous intensity and luminance are as follow: Luminous flux: Quantity derived from radiant flux (radiant power) by evaluating the radiation according to the spectral sensitivity of the human eye (as defined by the CIE standard photometric observer). It is the light power emitted by a source or received by a surface. Luminous intensity (of a point source in a given direction): Luminous flux per unit solid angle in the direction in question, i.e. the luminous flux on a small surface, divided by the solid angle that the surface subtends at the source. Luminance: Luminous flux per unit solid angle transmitted by an elementary beam passing through the given point ...