wall packs compliance lession

Wall Pack Lighting Code Compliance (UL, DLC, Title 24)

A plain‑English guide to wall pack lighting code compliance—what core UL listings mean (UL 1598, UL 924), how DLC affects rebates, and what Title 24 requires for outdoor controls. This reference is written for building managers, facility engineers, and project coordinators who need to get submittals approved the first time. For products, browse the Wall Pack Lights collection; for fundamentals, start with Wall Pack Lights 101.

Last updated: October 2025

Educational Guide UL • DLC • Title 24 For Building Managers & Facility Engineers

Scope: What “compliant” really means for wall packs

For most facilities, compliance is the intersection of safety listings, energy program eligibility, and controls that satisfy local rules. In short: the luminaire must be listed for the environment (Wet or Damp), meet rebate criteria if incentives are part of the plan (usually DLC), and use outdoor controls that switch or dim the fixture appropriately. When a wall pack provides egress illumination, add life‑safety requirements such as UL 924 operation and NFPA 101 egress‑illumination criteria. Always confirm with your authority having jurisdiction (AHJ) and the project spec.

UL listings that matter (UL 1598, 1598C, 924)

  • UL 1598 — Luminaires: The baseline for safety in non‑hazardous locations. Confirm the location rating on the label and spec sheet (Wet or Damp). See our UL 1598 Compliance Guide.
  • UL 1598C — Retrofit kits: Use when converting existing housings with a listed LED kit rather than replacing the whole fixture. The kit preserves enclosure integrity and gives inspectors a clear path to approval.
  • UL 924 — Emergency egress: Relevant only when the wall pack provides emergency illumination (integral battery or emergency branch). Typical plans target about 90 minutes of operation. Details in the UL 924 Compliance Guide.

DLC listing & utility rebates

The DesignLights Consortium (DLC) maintains qualified product lists—Standard and Premium. Many utility programs tie rebates to DLC status, and DLC Premium often indicates higher efficacy and enhanced controllability. Before submittal, verify that your exact model and SKU are on the current QPL for the category you intend to claim. If you are replacing legacy HID, match lumen packages instead of wattage; rebates sometimes include minimum efficacy thresholds.

Title 24 outdoor control rules (photocell + occupancy/bi‑level)

California’s Title 24, Part 6 requires most outdoor luminaires with the bottom of the fixture at or below roughly 24 ft to incorporate occupant sensing and to reduce power when the area is vacant. Combine occupancy control with an automatic shutoff or daylight‑responsive control (e.g., photocell or time schedule) to satisfy the mandatory measures. Some space types have exceptions, and local amendments can tighten thresholds—use our Title 24 Compliance Guide.

Common pitfalls: relying on photocell‑only; missing zone maps in submittals; and failing to document bi‑level set‑points during acceptance testing. Configure sensor timeouts and dim levels early and capture screenshots or photos for the O&M binder.

Dark‑sky & glare control (cutoff optics)

Exterior compliance increasingly includes quality of light. Full‑cutoff optics, optional shields/visors, and level mounting help reduce uplight and light trespass. In sensitive locations, select lower CCT near residences and use BUG ratings from the IES TM‑15 framework to satisfy local ordinances tied to dark‑sky goals. Document your selections in the submittal to prevent delays.

NEC wiring & mounting notes

  • Branch‑circuit basics: Most wall packs accept 120–277 VAC. Match overcurrent protection to conductors, and coordinate with a listed junction box and gaskets for Wet locations.
  • Bonding & sealing: Bond metal parts per code, seal entries to prevent water intrusion, and form a drip loop if conductors enter from above.
  • Emergency circuits: If the unit supports egress lighting, identify the emergency branch or inverter feed and label the circuit accordingly to aid inspections.

For deeper wiring rules and mounting best practices, see our NFPA 70 (NEC) Compliance Guide.

Ingress protection & NEMA ratings

Outdoor wall packs are commonly listed for Wet Location, but some sites need more protection—think hose‑down areas, coastal exposure, or heavy dust. Use our primers on IP ratings and NEMA enclosure types to match the environment and gasket strategy to the actual conditions.

IFC & local amendments (NYC, Chicago)

The International Fire Code (IFC) and local adoptions can add requirements “on top of” UL and energy rules. When a jurisdiction enforces the IFC alongside its building code, verify any exterior‑lighting limits in zoning or nuisance ordinances and pay attention to signage rules near doors used for egress. Large metros publish their own bulletins and interpretations—New York City and Chicago are two frequent examples. Start with our overviews and then confirm with the AHJ early in design.

Tip: Even if a fixture meets UL and DLC, submittals can stall if control sequences are not stated plainly or if shield/visor details are missing in light‑trespass districts.

Photometrics & distribution selection

Compliance is not only about the safety label—it is also about where the light goes. Choose optical distributions (e.g., Type II/III/IV) that cover walkways without blasting windows or the property line. Full‑cutoff housings, shields, and sensible mounting heights keep uplight in check while protecting neighbors from glare. For egress paths, verify that your layout delivers the required illumination on the walking surface along the designated route. If the same fixture doubles as security lighting, coordinate target levels and sensor logic so occupied scenes meet security needs without violating control requirements.

On retrofits, use lumen equivalence rather than one‑for‑one wattage swaps. LED wall packs often deliver higher lumens per watt and tighter optics than legacy HID, meaning a lower input power may still exceed your target footcandle values. Run a quick point‑by‑point using the manufacturer’s IES file and attach the output to your submittal—this de‑risks closeout and shows inspectors the reasoning behind the fixture selection.

Maintenance, testing & recordkeeping

After turnover, compliance is sustained through documentation. If any wall packs provide emergency illumination, schedule regular functional checks, log the test dates and outcomes, and replace failed batteries promptly. For control systems (photocell + occupancy/bi‑level), keep the set‑points in the O&M binder and note any seasonal adjustments. A one‑page “controls snapshot” with sensor models, timeouts, and dim levels prevents failed acceptance testing or warranty claims down the road.

In corrosive or coastal environments, augment maintenance SOPs with fresh gaskets and anti‑seize, inspect conduit seals annually, and treat exterior fasteners as consumables. Environmental wear is not a line item in most codes, but it is a frequent cause of nuisance failures that appear as non‑compliance during inspections.

Submittals, labels & acceptance testing

  • Submittals: Include UL location rating, DLC listing (model/SKU), sensor model & settings, and any emergency (UL 924) documentation.
  • Label photos: Capture UL/DLC and sensor labels for closeout.
  • Acceptance testing (Title 24): Document control sequences, photocell/schedule operation, and bi‑level set‑points on the required forms.

Quick compliance checklists

Pre‑bid / pre‑submittal

  • UL location rating (Wet/Damp) confirmed; UL 1598 or 1598C as applicable.
  • DLC (Standard/Premium) verified on the current QPL, if rebates are targeted.
  • Title 24 applicability checked (mounting height ≤ 24 ft; control type and dim level specified).
  • Emergency role defined (UL 924) if the wall pack supports egress lighting.
  • Local amendments reviewed (IFC/NYC/Chicago) and any shields/visors called out.

Pre‑install / rough‑in

  • Control zoning coordinated (per façade/area); photocell location planned.
  • Sensor type and bi‑level set‑points chosen (target ~50–70% dim when vacant).
  • Emergency branch or inverter circuit identified (if applicable).
  • Backplate/j‑box sealing details and bonding path confirmed.

Commissioning / closeout

  • Verify photocell/schedule operation and vacancy dim level at night.
  • Capture label photos and sensor settings for the O&M binder.
  • For egress units, document transfer test and runtime.
  • Attach photometric summary to submittals where required.

FAQ

Is DLC listing legally required?

No. DLC is not law, but many utility rebate programs require DLC‑qualified products for incentives. Verify program rules before purchasing.

Do all wall packs need motion sensors under Title 24?

Not all, but many outdoor luminaires mounted at or below common heights require occupant sensing with bi‑level reduction plus automatic shutoff/daylight control. Check the specific space type and local amendments.

When is UL 924 relevant?

Only when the wall pack is used for emergency egress illumination (integral battery or an emergency circuit). The life‑safety plan typically targets about 90 minutes of emergency lighting.