Private Label Eligibility
- The principle behind Private Label applications is that private labeled products are identical to the originally qualified versions. You may only submit a Private Label application if the original equipment manufacturer’s (OEM) product is already DLC qualified.
- If you are using OEM test reports to submit an application for a product or family group that has not been previously qualified on the QPL, please complete the Test Report Authorization Form and submit either a Level 1 (formerly Single Product) application or a Level 2 (formerly Family Grouping) application.
- Organizations submitting information for multiple brands should provide the private label documentation described below and the applicable fees with the original Level 1 or Level 2 application. Wholly-owned subsidiaries wishing to use a different model number/brand than what is listed on the QPL with the parent company must also follow this process.
- If you wish to update the performance of products previously qualified through a Private Label application, please select the Private Label – Update application type to create an application in the Application Portal. This will ensure that necessary product information from the original application is retained during the DLC review. Selecting any other application type when creating the application will cause delays in review.
- Private labeled products are dependent on qualification and maintained listing of the OEM product. If for any reason the OEM product is delisted, all associated dependent private labeled products will also be delisted. These products may only be re-listed by providing a new Level 1 or Level 2 application with new testing for the product.
- 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, failed surveillance testing, logo use violation, or other misrepresentation.
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 QPL. Because of this, Private Label products do not need to go through redundant testing, and application fees are reduced. However, because this process is intended for products that are identical, 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 similar descriptive fields are necessarily different.
To ensure all products listed on the QPL are associated with at least one line item that includes tested data, Private Label applications must include at least one of the parent models of the OEM listing that contains a full set of color data. If the private labeler does not wish to include at least one of the parent models of the original OEM listing, the private labeler must submit the private label products and provide test data for the worst-case model(s) of the OEM products they do wish to private label in a single product or family grouping application, which will be assessed at the full application fee. A Test Report Authorization Form, found on the Level 2 (formerly Family Grouping) Applications page, must be included in the Level 1 or Level 2 application. The private label equivalent of the tested product will then be listed as the parent product for the private label family.
Private label products and OEM products cannot be included in the same family on the QPL, i.e. a private label 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.
Premium classification applications require review of an additional independent test report for the driver ISTMT. Private Label application fees are assessed based on the application fee of the originally qualified product(s). As such, the private label application fee will also include the additional independent test report fee, at the reduced fee structure of $250 for each original $500 application fee. Additional fees for family member products and dimming variations still apply. Please see the Application Fees page for more information.
Model Number Guidance
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 also use model-ABC to represent 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.
Private label model numbers must list full and complete model numbers that clearly demonstrate all qualified product options offered.
- “Full and complete model numbers” means model numbers that include all performance-affecting and non-performance affecting variations offered, and which do not omit any option that is available to customers in the market. In general, options that do not affect the performance of the product can be submitted as a single model number with multiple options bracketed in the model number. For example, a product that has multiple exterior paint color options or mounting options, that do not affect performance, may include all color and mounting options in brackets (e.g. “[WH, BLK, SLV, GRY]”) within a single model number. Low and high voltage options can be submitted as a single model number (e.g. “ABC 10LM [120V-277V, 347V-480V] WH”) with the worst case performance reported. Multiple or alternate drivers can also be listed in a single model number as long as the drivers perform nominally the same. If the alternate drivers perform nominally differently – that is, they are not presented to customers as having the same performance other than voltage input, and result in different ordering codes – then the unique drivers will need to be listed in separate model numbers. Options that affect the lumen output, presence or lack of dimming capabilities, FALO, FALD, color tunable, or DC/POE cannot be bracketed and submitted as a single model number.
- Private label model numbers may include a subset of the options included in the OEM’s model numbers. For example, if the OEM model has multiple color options (“[WH, BLK, SLV, GRY]”), the private label model could list a smaller number of equivalent color options (“[SNW, ONYX, SMK]”). Private label model numbers may not include any options that are not included in the OEM model number regardless if it does or does not affect luminaire performance. For example, if the OEM model has only one color option (“WH”) the private label model can not list multiple color options (“[WH, BLK, SLV, GRY]”).
- DLC reviewers may check web listings and other marketing materials and reserve the right to request additional information to demonstrate the full and complete model number. A lack of clarity in model numbers will result in delayed application processing; misrepresentation of model numbers in the application process discovered outside the application process will generally be considered a violation of the DLC program and trademark rules.
- Each model number can only represent the fixture under a single brand. If the fixture can be sold under multiple brands, model numbers will need to be listed separately for each brand.
Brand Name Guidance
To enhance the functionality of the QPLs, the DLC requires a Brand Name to be noted on all product applications. Using consistent nomenclature for your brand names optimizes the searchability of your products on the QPLs and reduces the number of brands a user must select from in the filter list to find your products.
- If N/A or a blank is entered in the Brand Name field in the application form, it will be replaced with the manufacturer name associated with the products.
- When entering the brand name, please be conscious of spelling errors, extraneous characters, and extra spaces, and consolidate brand names where applicable. This ultimately allows users of the QPL to search for products more efficiently.
Below is an example of how different variations of the same brand name creates multiple options, leading to increased confusion for users.
There is no cost to update your existing brand name nomenclature on the QPLs. Simply complete and submit a Product Update Application to make these changes for listed products. For more information, please review the instructions under Updating Nomenclature/Brand Name on the Product Update Applications page.
New Technical Requirements
When the DLC announces a Technical Requirements revision, private labelers are held to the same deadline for submitting private label requests under the old Technical Requirements. During transition periods, Private Label applications will only be processed for products qualified under the old Technical Requirements if it is clear that the OEM’s product will remain qualified under the new Technical Requirements.
During transitions to new versions of Technical Requirements, if a previously-qualified OEM product is listed at a certain classification (i.e. as a Premium product) due to the requirements in place at the time of its qualification, and a private label is sought during a time when products are only being evaluated against a new set of requirements, the private label will only be listed with respect to how that product performs relative to the requirements in place at the time of its qualification.
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.
Please review the FAQs page for additional policy clarifications and contact email@example.com with any questions about submitting an application to the DLC.
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 Level 1 (formerly Single Product) application or a Level 2 (formerly Family Grouping) application. 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.
Complete the SSL Private Label App Excel Form.
Download and complete the SSL Private Label App Excel Form (.xlsx) at the bottom of this page.
Create or log into your MyDLC account.
If you have not done so already, create a MyDLC account with the DLC. Once logged in, select the manufacturer you will be submitting on behalf of. Enter the Application Portal by clicking on the blue Application Portal button. Note that this button is only accessible for manufacturers and users authorized to submit applications.
Start a new application and upload the SSL Private Label App Excel Form.
Select the program and application type you wish to submit, name the application for your reference, and select the manufacturer you are submitting on behalf of. If you have not done so already, download and complete the SSL Private Label App Excel Form (.xlsx) at the bottom of this page. Upload this completed form under the “Upload Completed Application Excel Form” section. If there are errors within your uploaded form, a red error message will display the reason why the form was not accepted.
Complete the online application questionnaire.
Complete the application questionnaire by entering all required information and uploading all required supporting documentation files. Your answers will be auto-saved, and you may exit and return to the questionnaire at any time. Required supporting documentation includes:
- 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 (.pdf file format required)
- 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 (.pdf file format required)
- 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
- Warranty years and warranty document must be provided within the application to qualify any private labeled product.
- If OEM provides warranty for PL
- Warranty documents from OEM manufacturers along with a signed statement on OEM letterhead stating that the private labeled products are within the OEM warranty scope must be provided and is an acceptable means of qualification.
Once you have signed the Private Label Agreement, your application status will be changed to “Application Awaiting Signature.” The OEM application contact will also receive an Private Label Agreement notification through DocuSign. Once the agreement has been signed by the both the Private Label and OEM organization, your application will enter comprehensive review.
The application forms below should be used on all applications submitted through the Application Portal.