BECAUSE!!!![]()
Seriously, it is because they have not been tested by UL for such use. It may also be because you were looking at two-wire photocells and these draw a small amount of electricity through the filament of an ordinary incandescent bulb to operate, even when the light is off during the daytime.
I have a three-wire photocell on my outside lights and it works just fine with CF lamps. The three-wire photocells have both hot and neutral leads along with a switched lead for the lamp.





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