Specialty bulb triggered violation for not having lighting facts label, but it's not required!

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Seller_wyAc9vB7hDMrx

Specialty bulb triggered violation for not having lighting facts label, but it's not required!

ASIN: B000J3ZV2K

Is a specialty bulb that is for use in a specific theater and DJ lighting equipment. It is not a general service light bulb and the US DOE exempts specialty bulbs from requiring the "Lighting Facts" label on the packaging. I submitted an appeal to this violation stating this but received a denial, even though it's very clear just by looking at the product that is NOT a general service light bulb.

@Atlas_Amazon I see you've dealt with these in the past, can you please review our case and have the ASIN reinstated?

Case ID: 17771374761

Thank you!

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3 replies
Tags:Regulations and standards
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Seller_i6S8knzW6zU6Z

Hi @Seller_wyAc9vB7hDMrx,

I checked through Amazon’s help pages to see if there’s anything you might reference in your appeal.

The 'Energy Labeling Rule' page (link) says Lighting Facts labels are required for “most general service ‘lamps’ with medium screw bases… as well as specialty consumer lamps.” That suggests exceptions do exist (just like you mentioned), but unfortunately, the help pages don’t spell them out directly.

On the “Lighting” help page (link), there’s an “Additional resources” section with a link to the DOE Appliance and Equipment Standards. That could be worth digging into for specifics.

Since your US listing isn’t visible, I looked up your ASIN on Amazon UK. I couldn’t tell for sure, but if your bulb doesn’t use a medium screw base, that may help you show the labeling rule shouldn’t apply to your product.

If that still doesn’t do the trick, you might want to reference the exact DOE standards in your case as well.

Hopefully, there’s something helpful here—if not, apologies, but I wanted to at least give it a shot.

Good luck getting this sorted out,

Michael

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Seller_08TZq9sOIaGvv

Why not simply print a label and attach to the packaging if you are FBM. Looks like all you need is how much it costs to use the bulb at 11 cents kw/h etc. In the mean time you can fight with AZ. I had to "just comply" when AZ insisted that my UPC show clearly on my product for sale on MY website. But it is not actually on my product. So I just made a giant UPC, stuck it on the package and uploaded to my site. Sometimes easier to just do it than argue with bots.

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