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Department for Business, Energy and Industrial Strategy

White LED Lighting Modules for Backlit Illuminated Signs

1.1    Scope

The internally illuminated box signage and built up letters that, for example, spell out company names, logos or other messages and pictures, have been included in the Energy Technology List (ETL) scheme because they offer substantial energy and carbon savings, considering their usual long hours of operation. These products are designed to provide a more efficient solution to back-lit Illuminated signs, which have traditionally been using fluorescent batten fixtures or cold cathode systems.

These products are a form of Display Lighting, i.e., lighting which are used to highlight displays of exhibits, signs associated with the business function, merchandise, and display case lighting used predominantly in the services and the retail industries either indoors (e.g., shop vitrines) or outdoors (e.g., hotels and restaurant facades).

The ETL criteria are only applicable for situations where the white light emitting diodes (LED) lighting modules are integrated with the electronic control gear. Neither the individual white LED lighting module nor the electronic control gear alone can be said to ‘comply with the ETL’. 

The internally illuminated signs with white LEDs may also incorporate lighting control devices such as dimming and presence controls.

To be eligible for inclusion on the ETL products shall meet the requirements as set out below.

1.2    Definitions

The white LED lighting modules used for backlit illuminated signs are products that provide white light by means of solid-state lighting technology to illuminate signage. 

This technology is used to internally illuminate box signs and built-up letters using white LEDs and modules, in combination with appropriate control gear, in both internal and external applications. 

The ETL scheme will cover 3 categories:

  • Channel letters
  • Box and cabinet signs
  • Faux neon


  • Channel letters are custom-made metal or plastic letters which are commonly used in exterior signage on public and commercial buildings, and often internally illuminated. Unlit three-dimensional letters that are applied to sign panels or monuments are usually referred to as Dimensional Letters
  • Box and cabinet signs are signs with text or symbols printed on a plastic or acrylic sheet which is mounted on a cabinet or a box that houses the lighting source and equipment.
  • Faux neon signs are a new alternative to traditional neon. They are built using low voltage LEDs and depict words, sentences, images, symbols or logos. The LED tubing used for faux neon signs has been designed to replicate the look of traditional neon lighting while being more energy efficient and accessible.

1.3    Requirements 

1.3.1    Eligibility requirements  

To be eligible, white LED lighting modules for backlit illuminated signs shall:

  • Be used exclusively to back light illuminated signage;
  • Not be used as road traffic signs, safety signs or fire safety signs, trackside railway signs or airside airport signs.
  • Include one or more LEDs which are driven by suitable electronic control gear;
  • Not be designed to incorporate or be supplied with LED based ‘lamps’ that retrofit to traditional light sources;
  • Include only components which are appropriately Conformity Assessment marked;
  • Be capable of producing white light. The definition of white light is as defined in “The Ecodesign for Energy-related Products and Energy Information (Lighting Products) Regulations 2021 No 1095” [1];
  • Only include the components that are compliant with the Ecodesign requirements and energy labelling regulations in force, wherever applicable. At the finalisation of this ETL criteria, the relevant regulations are: The Ecodesign for Energy-related Products and Energy Information (Lighting Products) Regulations 2021 No 1095.

In addition, lamps and control gear shall comply with the following British standards:

  • BS EN 50107-3: 2018 - Product standard covering luminous signs with discharge lamps and/or LED (light emitting diodes) and/or EL (electroluminescent) light sources with a nominal voltage not exceeding 1,000 V, with the exclusion of general lighting, traffic lighting or emergency purposes;
  • BS EN 61347-2-13:2014+ A1:2017, “Lamp control gear. Particular requirements for D.C. or A.C. supplied electronic control gear for LED modules.”

1.3.2    Performance requirements 

White LED lighting modules for backlit illuminated signs shall meet the appropriate lighting efficacy performance requirements set out in Table 1.1 below, when tested after 100 hours of continuous operation. If the product incorporates dimming control, it shall be tested at its highest light output level:

Table 1.1   Performance thresholds for white LED lighting modules for backlit illuminated signs

Product Category Lumens / Circuit Watt [2]
Channel Letters ≥100
Box and Cabinet signs ≥125
Faux Neon signs ≥100

"≥" means "greater than or equal"

In addition, products shall:

  • Have a power factor that is greater than or equal to, 0.9 at ≥75% of the designed driver load at highest light output level.
  • Be able to provide a light output (in lumens) after 3,000 hours of continuous operation that is not less than 90% of their initial light output (in lumens) as per The Ecodesign for Energy-related Products and Energy Information (Lighting Products) Regulations 2021 No 1095.
  • Be able to meet the L70B50 performance threshold at 50,000hrs in line with the TM-21 - “Lumen degradation lifetime” estimation method for LED light sources.

In addition:

  • The electrical power consumed (in circuit watts) is defined as the total power consumed by the whole unit from the main circuit connection point to the LED light source, including losses in the control gear.
  • Individual control gear shall have a standby power not exceeding 0.5 Watts when the lighting unit incorporates an electronically addressed dimming or switching circuit. If the product is not fitted with an automatic switching or dimming circuit, the product shall not consume any power when it is switched off.

1.4    Measurement and Calculations

1.4.1    Measurement standards

All products shall be tested in accordance with the procedures laid down in one of the following standards:

  • BS EN 13032-1:2004 +A1:2012, “Light and lighting. Measurement and presentation of photometric data of lamps and luminaires. Measurement and file format”.
  • IESNA LM-79-19, “Electrical and Photometric Measurements of Solid-State Lighting Products”.
  • BS EN 62722-2-1:2023, “Luminaire performance Part 2-1: Particular requirements for LED luminaires”.

1.4.2    Rounding  

For the avoidance of doubt test data should be presented to zero decimal places by rounding down. As an example, an efficacy of 99.9 lumens per circuit Watt for channel letter signage would be expressed as 99 lm/W and deemed to be a fail.

1.5    Verification for ETL Listing 

Any of the following testing routes may be used to demonstrate the conformity of products against the requirements:

  • In-house testing – Self-tested and verified or cross-checked by an independent body
  • Witnessed testing
  • Independent testing
  • Representative testing (see clause 1.5.1)

Further information regarding the first three routes can be found in the ETL Testing Framework.

1.5.1    Representative testing

Where applications are being made for a range of two or more products that are variants of the same basic design, test data may be submitted for a representative selection of models, provided that all variants conform to the following condition:

  • Parameters such as size, shape, power rating, product category and constructional design do not reduce product energy efficiency performance or basic functionality.

The representative models shall be selected by dividing the range of products into groups of models with similar design characteristics, and testing a model in the lowest quartile of predicted performance in each group. The performance of each model in the group shall be predicted using a validated mathematical model. 

It should be noted that: 

  • If a manufacturer voluntarily removes the representative model from the ETL then other products linked with that representative model may or may not be permitted to remain on the ETL. 
  • If any product submitted under these representative model rules is later found not to meet the performance criteria when independently tested, then all products based on the same representative model will be removed from the ETL.  

1.6    Conformity testing

Products listed on the ETL may be subject to the scheme’s conformity testing programme in order to ensure listed models continue to meet the ETL requirements.

1.7    Review

1.7.1    Indicative review date

This specification is scheduled to be reviewed during the 2023/24 review cycle.

1.7.2    Illustrative future direction of the requirements

The next technical review will consider: 

  • Uplifting the lumens/circuit watt performance thresholds



[2] Lumens of light output emitted by the module per circuit watt of electrical power consumed.