California Title 24: What It Requires from Lighting and Glazing on China-Sourced Products

California’s Title 24 is not a product certification a Chinese factory can hold. It is a building code, and it reaches imported lighting and glazing through two separate mechanisms: performance limits the design must meet (lighting power density, control functions, maximum U-factor and SHGC by climate zone), and state product registrations that must exist before an item may legally be sold in California — a Title 20 listing in the MAEDbS database for regulated lamps and power supplies, and an NFRC certified rating with a CPD number for fenestration. A factory’s CE or CB certificate satisfies neither. This guide sets out what Part 6 and Part 11 each require, what to ask a factory for, and where China-sourced packages usually fall down; for the ratings themselves, start with our guide to NFRC ratings and U-factor for US projects. This is exactly the kind of project FBM Sourcing, your China sourcing partner, is built to handle.

What Do Title 24 Part 6 and Part 11 Each Cover?

Title 24 of the California Code of Regulations is the California Building Standards Code, published in parts. Two of them decide what you can buy.

• Part 6 — Building Energy Efficiency Standards. Envelope, lighting, mechanical and controls. This is where lighting power allowances, mandatory control functions, fenestration U-factor and SHGC limits, and the acceptance testing requirements live.
• Part 11 — CALGreen. The green building standards code: VOC limits for adhesives, sealants, paints and coatings, formaldehyde limits for composite wood, water efficiency for plumbing fittings, and construction waste management. It overlaps heavily with the documentation covered in LEED and WELL documentation from Chinese factories.
• Title 20 — Appliance Efficiency Regulations. Technically outside Title 24, but it is the gate that stops shipments: regulated products, including many lamp and power supply types, must be certified to the California Energy Commission and listed in the Modernized Appliance Efficiency Database System (MAEDbS) before they can be sold or offered for sale in the state.
• Code cycle matters. California updates on a three-year cycle. The 2025 Energy Code took effect on 1 January 2026, replacing the 2022 edition; projects permitted under the earlier cycle stay with it. Confirm which cycle your permit falls under before writing any numeric limit into a purchase order.

What Does Title 24 Require from Nonresidential Lighting?

Two things at once: a wattage budget, and a set of control functions the fittings must physically support. The budget is expressed as a lighting power density in watts per square foot, and Part 6 offers three ways to calculate the allowance — the Complete Building Method, the Area Category Method (allowances by space type) and the Tailored Method for spaces with unusual task requirements. The control requirements are mandatory regardless of how much wattage you have left.

• Manual area controls in each enclosed space, accessible and marked.
• Multi-level control. Luminaires must be capable of stepped or continuous dimming, which means the driver, not just the fitting, has to support it. Continuous dimming down to low levels is required in many space types.
• Automatic shut-off by occupant sensing or time-switch control, with specific space types requiring occupant sensing.
• Daylighting controls in primary and secondary sidelit daylit zones and in skylit zones above the code-defined area thresholds, dimming the electric lighting in response to available daylight.
• Demand responsive controls. Buildings above the code’s floor area threshold — historically 10,000 ft² of conditioned lighted area — must be able to automatically reduce lighting power by at least 15% below total installed power on a demand response signal.
• Outdoor lighting carries its own allowances by lighting zone (LZ0 to LZ4), plus motion sensing, automatic scheduling and backlight/uplight/glare (BUG) rating limits derived from IES TM-15.
• JA8 high-efficacy sources apply to dwelling units rather than to general nonresidential space. Reference Joint Appendix JA8 sets efficacy, colour rendering, dimming and flicker criteria, and JA8-certified products are listed with the Energy Commission. On a mixed project — a hotel with apartments above, or a multifamily block with retail — keep the dwelling-unit schedule separate, because the JA8 requirement follows the dwelling units.
• Acceptance testing. Reference Nonresidential Appendix NA7 requires installed lighting controls to be functionally tested and documented before occupancy by a certified acceptance test technician. Controls that cannot pass NA7 hold up the certificate of occupancy, not just the commissioning report.

Does Our Lighting Need a Title 20 MAEDbS Listing?

This is the question that decides whether a container can be sold in California at all, and it is separate from whether the design complies. Title 20 applies to the product; Title 24 applies to the building.

• What is covered: state-regulated and federally-regulated appliances, including general service lamps, LED lamps, small-diameter directional lamps and external power supplies. Coverage is defined by product category and by physical characteristics, so check the exact scope for each item rather than the category name.
• What listing means: the responsible manufacturer certifies the model to the California Energy Commission with its test data, and the brand and model number appear in MAEDbS. A product not listed cannot lawfully be sold or offered for sale in California, whatever its performance.
• Listing is by model number. The number in the database must match the number on the carton and the ratings label. A house-brand relabel of a listed product is not automatically covered by the original listing.
• Safety listing is separate again. A UL or ETL listing to the relevant UL standard proves electrical safety, not California energy compliance. See whether lighting fixtures from China need UL listing for how that side works.
• Integrated luminaires generally sit outside the lamp categories, but their drivers and any external power supplies can be caught. Confirm per model.

What Does Title 24 Require from Glazing and Fenestration?

The envelope side is where the largest sums are usually at risk, because a curtain wall or window package with the wrong documentation cannot be substituted late. Before the approval mark, get the supply right — see what voltage and electrical standards apply to lighting and appliances from China.

• Certified ratings. Part 6 requires fenestration to be rated and labelled. Manufactured products are rated through an NFRC-licensed programme: U-factor to NFRC 100, SHGC and visible transmittance to NFRC 200, air leakage to NFRC 400. Certified products receive a CPD number in the NFRC Certified Products Directory and a temporary label that must stay on the unit until the inspector has seen it.
• Default values are punitive. Where a product has no certified rating, the Energy Commission’s default tables apply. The defaults are deliberately conservative, and a package forced onto default U-factor and SHGC values will usually fail the prescriptive envelope requirements or eat the whole margin in a performance calculation.
• Prescriptive limits vary by climate zone. California has 16 climate zones, and the prescriptive envelope tables set a maximum U-factor and a maximum SHGC for each, with the window-to-wall ratio limiting when the prescriptive path may be used at all. Projects above the ratio move to the performance path.
• Air leakage. Manufactured fenestration must meet the code’s maximum air leakage rate — historically 0.3 cfm/ft² — certified to NFRC 400 or the referenced ASTM method.
• Site-built fenestration. Large curtain wall and storefront assemblies fabricated on site follow a separate compliance route, usually component modelling or a site-built certification programme. Confirm the route with the energy consultant before the glass is ordered.
• Visible transmittance matters. Chasing a low SHGC with a heavily tinted or highly reflective coating can drop VT far enough to lose the daylighting credit that the lighting controls were relying on. The two sides of the code interact.

What Should You Ask a Chinese Factory For?

Compliance evidence is a deliverable, and it should be listed on the purchase order with the goods. For a California package the minimum set is short and specific.

• For fenestration: the NFRC CPD number for the exact product line, frame and glass make-up; the certified U-factor, SHGC and VT for that configuration; the air leakage certification; and confirmation that temporary labels will be applied and left in place.
• For the insulating glass unit: the low-e coating designation and surface position, spacer type, gas fill and overall thickness, matched to the configuration on the CPD listing. A “similar” coating from another coater is a different product.
• For lamps and power supplies: the Title 20 MAEDbS listing, with the brand and model number as registered.
• For luminaires: the fitting model, the driver model, the dimming protocol and range, the UL or ETL listing, the photometric file, and for exterior products the BUG rating.
• For controls: written confirmation that the driver supports the required dimming method and depth on the specified control system, whether 0–10 V, DALI or a wireless protocol, and that the combination has been tested together.
• Underlying reports. Ask for the accredited laboratory report behind each certificate, not just the certificate face — factory test reports vs accredited lab testing explains what each proves.

Where Do China-Sourced Products Fall Down on Title 24?

• CE or CB offered as a substitute. A factory with a full European file will often insist it is equivalent. California registration is administrative, not technical: without the MAEDbS entry or the CPD number, the file is irrelevant to the inspector.
• Driver substitution. Changing the driver after approval breaks the UL listing, can break the Title 20 position for any regulated component, and frequently breaks the dimming behaviour the control acceptance test will check. Prohibit substitution in writing.
• Glass make-up drift. The quoted unit was 6 mm low-e / 12 mm argon / 6 mm with a named coating; the produced unit uses a different coater’s equivalent, a different spacer or air instead of argon. The CPD number no longer describes the product, and the U-factor and SHGC on the compliance forms are no longer supported.
• Labels removed. Temporary NFRC labels peeled off at the factory or by the installer before inspection. Write into the order that labels stay on, and check it before the container is sealed.
• Controls that cannot pass NA7. Occupancy sensors without the required time delays, daylight sensors that cannot be commissioned, drivers that flicker or drop out at low dim levels. These surface at acceptance testing, when the building is otherwise finished.
• Mixed-market production. The same factory building 220–240 V fittings for another job puts the wrong driver or the wrong lamp in the right carton. Label cartons by project and destination market.

Factories differ enormously in how much of this they already hold; our pages on top LED and architectural lighting manufacturers and curtain wall and architectural glass manufacturers are the starting point for a California shortlist, because the ones already exporting to the US usually have live NFRC and UL relationships.

How FBM Sourcing Handles a California Package

FBM Sourcing manages the entire China procurement package for overseas construction projects. On a California hotel, apartment, school or office package the lighting and glazing schedules are written with the compliance evidence attached to each line: CPD number and certified U-factor, SHGC and VT for each glazing type; glass make-up locked to the certified configuration; luminaire and driver model pairs with dimming protocol; Title 20 listing numbers where the product category is regulated; UL or ETL listing and photometric files. Factories are shortlisted on what they actually hold for those exact models rather than on catalogue claims, substitution of driver, coating, spacer or gas fill is prohibited in the purchase order, and samples are approved before production. Before shipment our own FBM Sourcing QC team checks the goods at the factory against the approved samples — glass make-up and stamps, labels left in place, driver and luminaire model numbers, carton marking — with photo and video records that go to you with the packing documents. All quotations, invoices and shipping documents are issued by FBM Sourcing, you deal with us, and we carry the responsibility. For suppliers you nominate, we charge a 5% commission; for products we source for you, we quote a direct price. Sometimes the glazing alone fills full containers; sometimes it shares containers with the other product categories of the same project; and sometimes a dozen or more product categories from several projects of the same client go into a few containers — always full containers, and for us this is routine, well-practised work.

For a showroom or dealership project where glazing and lighting are governed by a brand corporate identity manual rather than a building code alone, see our guide to procurement for car dealership and showroom construction projects.

Get a China Procurement Quote for Your Project

If you are specifying lighting or glazing for a California project, send us the lighting schedule, the glazing schedule with the required U-factor, SHGC and VT, the climate zone, the destination port and the required-on-site dates. Our team will review it line by line, flag where the compliance evidence is missing, and set out a quotation.

Use the quote button above or WhatsApp +86 135 6007 5057.