Code Change Summary: New language in 700.12(G)(1) clarifies that lamps with built-in batteries are not considered battery-equipped emergency luminaires unless they are directly wired to the branch circuit.

SME commentary: The 2026 revision to 700.12 moves the former 700.12(H)(1) requirements into 700.12(G)(1) and expands them to address a type of product that has created confusion in the field. Lamps are now widely available that contain an internal battery, a small charging circuit, and a basic transfer function, all built into what looks like an ordinary replacement bulb. These lamps can keep glowing during a power loss, and may be suitable as auxiliary lighting, but they are not evaluated the same way as listed emergency luminaires.

The new text in 700.12(G)(1) states that “luminaires that use battery equipped lamps that are not directly wired to the branch circuit shall not be considered battery-equipped emergency luminaires.” This addition reflects a key requirement in the UL 924 safety standard for Emergency Lighting and Power Equipment. Emergency battery packs, whether stand-alone or part of a retrofit kit, must be permanently wired to the branch circuit. That wiring connection is what prevents someone from walking into a building, changing a lamp during routine maintenance, and unknowingly removing the only source of emergency illumination from that luminaire.

User-replaceable lamps with built-in batteries do not have any safeguard that keeps them from being swapped out with a non-battery version. For that reason, they cannot meet UL 924 and cannot serve as emergency lighting. They may still be useful for auxiliary lighting, but they do not carry the reliability expectations that Article 700 demands.

On the other hand, some battery-equipped lamps are built with leads or terminals for direct wiring, similar to UL 924–listed emergency battery packs. These are evaluated as luminaire retrofit kits under UL 1598C and, when intended for emergency egress lighting, also evaluated to UL 924 as emergency lighting equipment. Because they must be wired in place, they are not easily removed and maintain the same level of system reliability expected of listed emergency luminaires.

The accepted public input and revised code language make the intent clear: if the design of a battery equipped lamp does not include direct wiring to the branch circuit, it is not considered a battery-equipped emergency luminaire. The revised text gives installers, designers, and inspectors a straightforward way to separate general-purpose lamps with added battery features from true emergency lighting equipment, which helps ensure that required egress illumination stays dependable when it is needed most.

Below is a preview of the NEC^®. See the actual NEC^® text at NFPA.ORG for the complete code section. Once there, click on their link to free access to the 2026 NEC^® edition of NFPA 70.

2023 Code Language:

700.12(H) Battery-Equipped Emergency Luminaires.

(1) Listing. All battery-equipped emergency luminaires shall be listed.

2026 Code Language:

700.12(G) Battery-Equipped Emergency Luminaires.

(1) Listing. All battery-equipped emergency luminaires shall be listed. Luminaires that use battery equipped lamps that are not directly wired to the branch circuit shall not be considered battery-equipped emergency luminaires.

Informational Note No. 3: See ANSI/UL 1598C, Light-Emitting Diode (LED) Retrofit Luminaire Conversion Kits, for the requirements for lamps that are directly wired as luminaire retrofit kits and to ANSI/UL 924 for emergency lighting equipment provided with lead wires or wiring terminals for direct connection to the branch circuit.