The DLC will be switching to a new application portal for SSL and Hort applications on January 31, 2022. Any SSL and Hort applications that have been created must be submitted by close of business on January 31 in order to complete their review through the old portal. Any applications that remain unsubmitted on February 1 must be recreated in the new portal. There will be no change for NLC applications at this time. Click for more details.

Qualify a Fixture

Horticultural Private Label Applications

Private label applications allow manufacturers the option to list qualified products under multiple manufacturers and brands without having to conduct duplicate testing.


Private label applications may only be submitted if the original equipment manufacturer’s (OEM) product is already DLC qualified. Private label products must be identical to the originally qualified versions.

  • If OEM test reports are used to submit an application for a product or family that has not been previously qualified on the Qualified Products List (QPL), a Test Report Authorization Form must also be completed and submitted for both single product and family grouping applications.

Organizations submitting information for multiple brands should provide the private label documentation described below and the applicable fees for listing the original single product or family grouping application. Wholly-owned subsidiaries wishing to use a different model/brand than what is listed on the QPL with the parent company must also follow this process.

Private labeled products are dependent on the qualification and maintained listing of the OEM product, and if for any reason the OEM product is delisted, all associated private labeled products will also be delisted. These private labeled products may be re-qualified as an OEM product by providing a new single product or family grouping application, with new testing for the product, or may be re-qualified as a private label product once the OEM product is updated and re-listed on the QPL.

  • Delisting of an OEM product may occur for a variety of reasons, such as if a manufacturer voluntarily requests that their product be delisted, or if the product is delisted due to non-compliance with program requirements, logo use violation, or other misrepresentation.
  • Private label listings are based on a mutual agreement between the OEM and a private labeler. If either party notifies the DLC that the private label agreement is no longer in place, the DLC will delist the private labeled product.

Qualified Products List (QPL) Listings

The intent of the private label application policy is to allow listing of products that are exactly the same as the OEM products already listed on the Horticultural QPL. Because of this, private label products do not need to go through redundant testing, and application fees are reduced due to a simplified application review process.

However, because this process is intended for products that are identical to listed OEM products, the DLC lists private labeled versions of products with exactly the same performance information as their OEM versions. The reasoning behind this is that identical products should have identical performance ratings, even if brand, manufacturer, model number, date qualified, and product ID are different.

To ensure all products listed on the QPL are associated with at least one product that includes tested data, private label applications must include at least one of the parent models of the OEM listing. If the private labeler does not wish to include at least one of the parent models of the OEM listing, the private labeler must provide test data for the worst-case model(s) of the OEM products they wish to private label in a single product or family grouping application. The tested product(s) will then be listed as the parent product for the private label listing.

Private label products and OEM products cannot be included in the same family on the QPL, i.e., a privately labeled product cannot be considered a parent for an OEM child product and an OEM product cannot be considered a parent for a private label product. Parent and child products on the QPL must be part of the same family and listed with the same manufacturer.

Model Numbers

To avoid confusion in the market, the same private label model number cannot be used to represent different OEM products. For example, if a private labeler is using Model-ABC to represent OEM product Model-DEF, the private labeler cannot then update Model-ABC to represent a different OEM product Model-XYZ.

In the event that a private labeler submits the same model number for multiple OEM products, the DLC reviewer will inform the private labeler that a unique model number must be supplied in order for the review to continue.

Resellers that sell DLC qualified products under the exact manufacturer name and model number explicitly listed on the QPL under the OEM information (manufacturer name, manufacturer brand, model number) do not need to use the private label application process.

New Versions of the Technical Requirements

When the DLC releases new versions of the Technical Requirements, private labelers are held to the same deadline for submitting private label applications under the previous Technical Requirements as OEMs. Private label update applications submitted during transition periods will only be processed for products qualified under the new Technical Requirements until the submission window for the previous Technical Requirements version has closed. Transition periods are submission windows where the deadline for new applications under the old Technical Requirements version has ended; however, products qualified under the old Technical Requirements version have not yet been delisted.

Third Party Relationships

If a private labeler wishes to extend the private label to a third organization, there are two options:

  1. The private label request can be signed by the original equipment manufacturer and the final private labeler.
    • For example, if company B private labels a product from company A, and then company C wishes to private label that product from company B, the private label request would be signed by company A and company C.
  2. Alternatively, the original equipment manufacturer can provide a blanket letter that grants the first private labeler permission to private label any product they manufacture to a third organization. This blanket letter must be provided with any requests for private labeling from the initial private labeler and the third organization.
    • In this scenario, company A provides a blanket letter for company B to private label their products, which company C includes in applications to private label products listed by company B.

Application Instructions

  1. Determine that the products you intend to private label have already been qualified on the QPL by the original equipment manufacturer (OEM).
    • If you are submitting an application to list products under multiple brand names but the products have not yet been qualified on the QPL, you must submit either a Single Product Application or a Family Grouping Application and include the Hort Private Label Application form and Hort Private Label Agreement form.
    • If you are submitting an application to private label a product that has already been DLC qualified by the manufacturer, continue with these instructions.
    • Note: Private labels must include at least one OEM parent model per unique OEM family ID to be eligible. Please ensure the OEM products downloaded from the DLC QPL include at least one parent model.
  2. Create a Manufacturer Account.
    • If you have not done so already, create a manufacturer log-in. The DLC recommends that the application be completed by a person with technical knowledge of lighting products and testing, such as a product engineer. Experience has shown that applications submitted by non-technical staff may lack important details which can delay overall processing.
  3. Complete the Hort Private Label Application Form.
    • Download the Hort Private Label Application Form (.xlsx) at the bottom of this page. The OEM’s qualified products must be downloaded directly from the DLC QPL and the model numbers listed exactly as they appear on the QPL.
  4. Complete the Hort Private Label Agreement Form.
    • Download the Hort Private Label Agreement Form at the bottom of this page. This statement must be filled out in its entirety and signed by representatives of all organizations involved. If one organization is listing products under different brand names, the signature of a representative of the parent organization is sufficient.
    • An organization that is a signatory to the private label statement may choose to withdraw its consent at any time by submitting a written request that the private label listing be terminated. Any such request must be signed by an authorized representative of the organization. Upon receipt of such request, the DLC will delist the private labeled model numbers from the QPL.
  5. Start a new application in your Manufacturer Account.
    • Once logged in, click the Applications tab on your Dashboard. Click the green Create Application button. This will lead you to the Create New Application window. Enter the required Application Details and Application Contact information. Be sure to select the Hort Private Label application type. After creating the application, you will be redirected to the Application Home.
  6. Upload ALL required application materials. Learn more about application supporting documentation here.
    • To upload supporting documentation, click the Documents section in the left-hand navigation menu of Application Home. Within the Documents section, each question requires a specific document to be uploaded. Questions are determined by the selected application type. Files must be individually uploaded in order to save your progress. All “Required Documentation” must be uploaded before you can submit the application. “Optional Documents” are necessary for evaluating products against the Premium classification requirements and certain Primary Use designations. The system will allow you to replace and delete files as necessary before submitting your application.
      • Completed Hort Private Label Application Form (.xlsx)
      • Completed Hort Private Label Agreement Form
      • A product specification sheet for any new model numbers being submitted
      • OEM product specification sheet for the model numbers being private labeled
      • Proof of safety certification under the private labeler’s organization name and model number(s) from an appropriate safety certification body relevant in the US or Canada
      • Proof of safety certification under the OEM’s organization name and model number(s) from an appropriate safety certification body relevant in the US or Canada
      • Multiple Listing Correlation Sheet issued by the approved safety organization which cross references the OEM model numbers with private label model numbers
      • Installation instructions must be provided for private labels of Linear Replacement Lamps, Retrofit Kits, Screw-Base Replacements for HID Lamps, Color-Tunable Products, Field-Adjustable Light Output Products and Field-Adjustable Light Distribution Products.
      • Supplemental Documentation for Field-Adjustable Light Output Products and Field-Adjustable Light Distribution Products that describe the functionality of the product features.
      • Warranty document from the private labeler covering the private label models in the applications
  7. Digitally sign the Application Agreement and submit the application.

    Application reviews will not begin until the application is submitted. After uploading documentation, you must click the green Submit Application button in the top right-hand corner of the Documents section. This button will present you with a digital Application Agreement that includes the DLC Self-Certification Statement, Logo Guidelines Compliance Statement, Surveillance Testing Compliance Statement, and Safety Certification Compliance Statement. Full text of the agreement is available here. Sign the agreement to submit your application.

For those applicants who do not have the appropriate level of authority to sign the agreement, it is recommended that the signing authority create a DLC account under your company’s organization and digitally sign off once the application is complete.

Hort Application Forms