Code Change Summary: New code section provides listing requirements for Class 2 Powered Emergency Lighting Systems.

With advancing Power Over Ethernet (PoE) emergency lighting technology and a wide range of varying products available for use in these systems, it is important for the code reader to know which devices in the emergency lighting system have NEC^® code requirements tied to them.

In the 2020 NEC^®, Section 700.16(B) made it clear that “control devices” in the emergency lighting system shall be listed for use in emergency systems. This was a very broad requirement with little direction given to the installing electrician or inspector and left room for several questions:

• What is considered “control”?
• How could one tell by looking at the product if it was considered a “control device”?
• Do all ethernet switches used in the different PoE emergency lighting system configurations provide a “control” function or is the “control” provided by another device in line with it?
• If the type of PoE network switch used in the emergency lighting system has any sort of internal controlling capabilities, how will it be evident in the product markings so it can be easily recognized in the field in order to apply the applicable NEC^® requirements?

The 2023 NEC^® added new language in Article 100 to define a Control Device, Emergency Lighting (Emergency Lighting Control Device) as a separate or integral device intended to perform one or more emergency lighting control functions. (700)

UL 924 is the Standard for Emergency Lighting Equipment and makes it clear in Section 4.18.1 that an Emergency Lighting Control Device (ELCD) is a separate or integral device intended to perform one or more emergency lighting control functions.

The act of “distributing emergency power or control signals among connected devices” meets the definition of an Emergency Lighting Control Function (ELCF) in Section 4.18.2 of UL 924.

In the 2023 NEC^®, new Section 700.27 addresses Class 2 Powered Emergency Lighting Systems. This section makes it clear that devices that combine control signals with Class 2 emergency power on a single circuit shall be listed as emergency lighting control devices.

The Informational Note states that a PoE switch is an example of a device combining control signals with Class 2 emergency power sources.

Before this new code language, an argument could be made that a PoE network switch used in an emergency lighting installation was not required to be listed as an emergency lighting control device if it only provided a connection point and did not provide any kind of control or if it did not have features to aid in the decision making process to switch the connected devices to emergency mode.

Now, any PoE network switch used in a Class 2 powered emergency lighting system that combines control signals with Class 2 emergency power on a single circuit must be listed as an emergency lighting control device. Part of the listing (certification) process will include appropriate markings to identify the product for its intended purpose.

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 2023 NEC^® edition of NFPA 70.