California's Title 24 divides lighting fixtures into high efficacy (an efficient source in a hard-wired or GU-24 base fixture) and low efficacy fixtures (Edison base fixtures and track lighting), and then puts limits on where and how much wattage for low efficacy fixtures can be used.
In practice, the selection of GU-24 base fixtures is much more limited than Edison base fixtures; they often cost 10 to 30 percent more and getting different bulbs is still not easy.