Due to a high volume of applications, initial and comprehensive review timeframes are currently extended by 10 days each for SSL, LUNA, and Hort applications. Click here for more details about SSL application review timeframes, and here for more details about Hort review timeframes. Thank you for your understanding!

Qualify A System

Private Label Applications


  • You may only submit a Private Label Application if the original equipment manufacturer’s (OEM) system is already DLC qualified. The principle behind Private Label applications is that private labeled systems are identical in components, performance and capabilities to the originally qualified versions.
  • The private label can only submit application for the same scope as that of the OEM. For example, if the OEM system is qualified for Interior scope, the private label can only qualify for Interior.
  • Please note that private labeled systems are dependent on qualification and maintained listing of the OEM system, and if for any reason the OEM system is de-listed, all associated dependent private labeled systems will also be de-listed. The private label can be re-listed by providing a new application and qualifying as an OEM. In this case, the discounted private label fee will not apply.
  • De-listing of an OEM system may occur for a variety of reasons such as if a manufacturer voluntarily requests that their system be de-listed, or if the system is delisted due to non-compliance with program requirements, logo use violation, or other misrepresentation.


Please refer to the Revision Schedule and Listing Fees for details.

Technical Requirements Update

  • When the DLC announces the Technical Requirements revision schedule, private labelers are held to the same deadline for meeting the requirements as the OEM systems.
  • The private label system’s version listing is dependent on the OEM. To update to the Technical Requirements version in effect, the OEM system must first update before the private labeler can submit an application for the version update. Private labelers are encouraged to coordinate with their OEM suppliers to prevent delays. The application process is described in the section below.

QPL Listings

The intent of the Private Label application policy is to allow listing of systems that are exactly the same as the OEM ones already listed on the QPL. Because of this relatability, Private Label systems do not need to go through a comprehensive review, and application fees are reduced due to the simplified application review process. However, because this process is intended for systems that are identical, the DLC lists private labeled versions of systems with exactly the same capability information as their OEM versions. The reasoning behind this is that identical systems should have identical performance and capabilities, even if brand, manufacturer, date qualified, and similar descriptive fields are necessarily different.

Third Party Relationships

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

  • The private label request letter can be signed by the original 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 letter would be signed by company A and company C.
  • Alternatively, the original manufacturer can provide a blanket letter that grants the first private labeler permission to private label any product they manufacture to a third organization. Requests for private labeling from the initial private labeler and the third organization would then need a letter signed only by those two parties, along with the letter from the original manufacturer. In this scenario, company A provides a blanket letter for company B to private label their products; then applications for products from company C would need to include both that letter and the signed letter between company B and company C.

NLC Private Label Application Instructions

  • Determine that the system(s) you intend to private label have already been qualified on the QPL by the original equipment manufacturer (OEM).
  • 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.
  • Complete the Private Label Agreement Form
    Download the 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 label system(s) from the QPL.
  • Email info@designlights.org the OEM Product ID(available in the NLC QPL) and the completed Private Label Agreement form to develop the qualification process of the private label system.
  • Upon Agreement verification, you will receive the private label application for your system.
  • Be sure to update the ‘Manufacturer and System’ section in the application with Private Label information.
  • The private label system can use the OEM’s reference documents for submission or the documents from the OEM re-labeled with a new private label logo (but same document names and page numbers). In either case, reference documents must be included in the application package.
  • In addition to the application and reference documents, the package must include:
    • Warranty document of the private label The DLC requires a minimum warranty of at least 5 years for all components of the system addressed by the requirements, with the exception of software, on-premises computer server, and cloud service. An optional warranty extension to 5 years is acceptable for meeting this requirement.
    • Signed Private Label Agreement Form