- You may only submit a Private Label Application if the original equipment manufacturer’s (OEM) product is already DLC qualified. The principle behind Private Label applications is that private labeled products are identical to the originally qualified versions.
- If you are using OEM test reports to submit an application for a product or family that has not been previously qualified on the QPL, please complete the Test Report Authorization form and submit either a Single Product Application or a Family Grouping Application.
- Organizations submitting information for multiple brands should provide the private label documentation described below and the applicable fees with the original Single Product or Family Grouping 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 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.
- Please note that private labeled products are dependent on qualification and maintained listing of the OEM product, and if for any reason the OEM product is de-listed, all associated dependent private labeled products will also be de-listed. These products may only be re-listed by providing a new Single Product or Family Grouping Application with new testing for the product.
- De-listing of an OEM product may occur for a variety of reasons such as if a manufacturer voluntarily requests that their product be de-listed, or if the product is de-listed 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 ones already listed on the QPL. Because of this relatability, 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, 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 authorization form, found on the submit a product family grouping page, must be included in the single product or family grouping 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.
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.
New Technical Requirements
When the DLC announces the Technical Requirements revision schedule, private labelers are held to the same deadline for submitting private label requests under the old Technical Requirements. Private label applications during transition periods 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.
Private Label Application Instructions
- 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 Private Label Application form and 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.
- 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 labeled model numbers from the QPL.
- 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 SSL Private Label application type. After creating the application, you will be redirected to the Application Home.
- 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 Private Label Application Form (.xlsx)
- Completed 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
- 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.