Separate control gears are subject to the ecodesign requirements set in Annex II.1(b).. These include energy efficiency requirements at full-load and for no-load power,, standby power and networked standby power
Halogen control gears have to meet the efficiency requirement and it shall be shown in the DoC how this has been assessed. The absence of a measurement reference for halogen control gear efficiency in the transitional methods (Commission communication 2014/C 22/02; OJ C22/17 of 24.01.2014) cannot be used as a reason to omit the assessment. This is also clearly stated in 2014/C 22/02 itself, at point 1:
“In case no specific documents have been referenced for measured parameters, reliable, accurate and reproducible measurement procedures, which take into account generally recognised state-of-the-art measurement methods, shall be used. This includes but is not limited to the number of switching cycles, the rated lifetime for LEDs, and the premature failure rate of LEDs.”
Hence, if the manufacturer believes that IEC 62442-3 is not applicable for efficiency measurements, the manufacturer should report the alternative method that has been used.
Please note that in the meantime, standard EN 62442-3:2014/A11:2017 (E) is available. Even if the reference to this standard has not been published in the Official Journal yet, it is recommended to use this standard for measurement of halogen control gear efficiency.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.