Buy your LED lighting or HVAC upgrade before your utility signs off, and in most custom programs you lose the incentive entirely, no matter how efficient the equipment is.
If your utility hasn't approved your project in writing, don't buy the equipment, don't schedule the install, and do not remove your old fixtures. In most custom rebate programs, any one of those steps can cost you the entire incentive, even if the new equipment is exactly what the program would have paid for.
Pre-approval is the utility's written confirmation that your project qualifies and that incentive money is reserved for it. For a cannabis cultivator planning an LED lighting retrofit or a heating, ventilation, and air conditioning (HVAC) upgrade, that one rule can decide whether the project comes with a meaningful rebate or none at all.
Utility rebate budgets are set per program year, so utilities pre-approve custom projects to confirm eligibility, estimate energy savings, and reserve funding before money is committed. Approving a project only after installation would force a utility to pay for an upgrade it never had the chance to review, compare against the baseline,old equipment, or budget for.
Facility-wide lighting and HVAC retrofits usually go through a utility's custom program. Instead of paying a fixed amount per fixture or unit (a prescriptive rebate), a custom program calculates the incentive from the energy your specific project will save. Energy Trust of Oregon is a good example: it treats all horticulture and cannabis lighting projects as custom, and each one has to be reviewed, pre-qualified, and pass a cost-effectiveness analysis before it's eligible. Savings are estimated in kilowatt hours (kWh) with Energy Trust's Lighting Tool, based on actual operating hours, and the incentive is based on that estimate. The calculation starts with the equipment you have today, so it can't be done once the old equipment is gone.
$0.15 per kWh saved, up to $350 per fixture: Energy Trust of Oregon's custom incentive for horticulture and cannabis lighting, capped at 50% of eligible project cost.
For custom programs, yes. Equipment purchased or installed without approval doesn't get paid later; it doesn't get paid at all. Energy Trust of Oregon states that "All equipment purchases eligible to receive custom incentives must be pre-qualified," which makes pre-approval a condition of eligibility rather than a formality.
For horticulture lighting, that proposal has to be submitted by one of Energy Trust's enrolled Business Lighting trade allies before any equipment is purchased or installation begins. ComEd in Illinois follows the same order, but its approval comes as a reservation letter instead of an offer. Oregon and Illinois are very different markets, but the order of operations is the same in both. If your project budget assumes you can buy now and apply for the rebate later, check that assumption against the program terms before you sign a purchase order.
Buying or starting installation before the utility approves your project can disqualify that purchase from the incentive entirely. ComEd's custom incentives application tells customers to "wait until you receive an incentive reservation notification before purchasing equipment," and warns that failure to wait for the reservation letter "will result in the forfeit of requested incentives."
Notice that ComEd draws the line at the purchase itself, not just the install. Removing old equipment early is a risk too. Energy Trust of Oregon won't let a horticulture lighting upgrade, or even the removal of existing fixtures, begin until its own on-site pre-verification is complete. That matters for growers who want to pull high-pressure sodium (HPS) fixtures during a room turnover. Neither program's published materials describe an appeals process for work started without approval. The practical result is forfeiture: the new equipment is installed, there's no approved application behind it, and the incentive money goes to someone else's project. Whether you can apply again later depends on funding and the program year, and neither is guaranteed.
ComEd's custom application is a good example. It asks for manufacturer specification sheets, a scope of work, invoices for materials and labor, installation photos, an IRS Form W-9, and measurement and verification data when required. The spec sheets and scope of work let the utility check the exact equipment before you buy it, and the invoices and photos later confirm that's what was installed. For horticultural LED lighting, that check often includes confirming the fixture is listed on the Design Lights Consortium (DLC) Qualified Products List (QPL), an independent list of tested, energy-efficient lighting products that many lighting rebate programs rely on. Energy Trust of Oregon requires a QPL listing for every horticulture lighting project, and since July 1, 2026, only fixtures listed under DLC's Version 4.0 horticultural requirements qualify. Confirm your exact model is listed before you order.
In the custom programs covered here, no. Prescriptive rebates, which pay a set amount for a single qualifying product, sometimes allow you to apply after purchase, but the custom programs used for large lighting and HVAC retrofits are built around approval first.
Canopy-wide lighting and facility HVAC upgrades usually land in the custom track because of their size and cost, and even prescriptive programs often require pre-approval once a project passes a certain size for example ComEd’s Standard Offering. Before assuming an exception applies to your project, confirm it directly with the utility that runs your program. Rebates are case-by-case: eligibility, funding, and program rules vary by utility and by state, and no program reviewed for this article guarantees a specific outcome.
Confirm eligibility and submit a complete pre-approval application before signing any equipment purchase order. Get the specific make and model approved in writing, keep your project documentation on file, and wait for the utility's written offer or reservation letter before equipment ships, old fixtures come down, or installation begins.
Watch the calendar too. Many utility rebate programs run on an annual cycle with deadlines in November or December, so an approval that lands late in the year can leave very little time to finish the install. Treat the pre-approval application as its own project phase, not a formality squeezed in after equipment is already ordered, and build that time in before you commit to a delivery date with a vendor. If you're not sure whether your utility's program requires pre-approval, or what documentation it wants before you buy, confirm it before signing anything. What Rebates handles the utility side of lighting and HVAC projects for growers, from the pre-approval application through the final paperwork. Reach our team at https://www.whatrebates.com/contact before you place an order, and we'll confirm your program's requirements and get your application in first.
Rebate rules vary by utility, state, and program year. The examples in this piece come from the published terms of two utility programs; always confirm current requirements directly with the utility administering your program before you buy.
Q: What happens if I buy LED lights before my utility approves the rebate?
A: In most custom incentive programs, buying first can disqualify that purchase. Energy Trust of Oregon, for example, requires custom equipment purchases to be pre-qualified, so equipment you already bought may not qualify no matter how efficient it is.
Q: Can I apply for a rebate after installing HVAC equipment?
A: Generally no. The custom incentive programs used for large lighting and HVAC upgrades typically require pre-approval. Some smaller, prescriptive rebates for a single qualifying product may work differently, but facility-wide retrofits generally need sign-off before installation begins, not after.
Q: How long does utility rebate pre-approval take?
A: Timelines vary by utility and by program, and neither program reviewed here publishes a guaranteed turnaround on its public pages. Submit your application, equipment specifications, and any required documentation as early as possible, and wait for written approval before you sign a purchase order or schedule installation.
Q: Does pre-approval guarantee I will get the rebate?
A: No. Pre-approval reserves funding and confirms your proposed project meets a program's requirements when you apply. Most custom incentive programs still verify the finished installation, its paperwork, and its savings before releasing any rebate funds.
Q: Can I reapply if my purchase gets disqualified?
A: It depends on the program and whether funding is still available in the current cycle or a future one. Neither program reviewed for this piece publishes a guaranteed path to reapply after a disqualified purchase, so the safer approach is getting approval locked in before any purchase order goes out.
SOURCES
Energy Trust of Oregon, Commercial: Existing Buildings: Custom, 2026, https://www.energytrust.org/incentives/commercial-existing-buildings-custom/
Commonwealth Edison (ComEd), Energy Efficiency Custom Incentives Application (2026 form), 2026, https://www.comed.com/ways-to-save/for-your-business/incentives/custom-incentives
Energy Trust of Oregon, Horticulture Lighting Incentives, Production Efficiency Information Sheet (PI 490HL, v2025.2), effective July 1, 2025; Horticulture Lighting incentives page, 2026, https://energytrust.org/incentives/industry-agriculture-horticulture-lighting; and DLC Horticultural Lighting v4.0 trade ally notice, https://insider.energytrust.org/?p=19947
DesignLights Consortium (DLC), Qualified Products List (QPL), 2026, https://www.designlights.org/qpl/
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