It is not allowed to have energy labels in products that are not under any Energy label regulations. Article 6(d) of the Framework Regulation on Energy Labelling (EU) 1369/2017 reads: “The supplier and the dealer shall: …(d) for products not covered by delegated acts, not supply or display labels which mimic the labels provided for under this regulation and the relevant delegated acts;”)
Consequently, the packaging of a product containing a light source cannot show the energy label of the contained light source. The relevant provision of Commission Delegated Regulation (EU) 2019/2015, Article 3(2)(a) reads:
“Suppliers of containing products shall: (a) provide information on the contained light source(s), as specified in point 2 of Annex V”
Annex V, point 2 sets requirements regarding “Information to be displayed in the documentation for a containing product” as follows:
“If a light source is placed on the market as a part in a containing product, the technical documentation for the containing product shall clearly identify the contained light source(s), including the energy efficiency class.
If a light source is placed on the market as a part in a containing product, the following text shall be displayed, clearly legible, in the user: ‘This product contains a light source of energy efficiency class <X> ’, where <X> shall be replaced by the energy efficiency class of the contained light source.
If the product contains more than one light source, the sentence can be in the plural, or repeated per light source, as suitable.”
Article 3(2)(a) applies to units of light sources placed on the market from 1 March 2022. Thus, the regulation does not require the energy label of the contained light source elsewhere than in the manual or booklet of instructions and the technical documentation. Going beyond what is required may confuse consumers and distort the level playing field that the Regulation seeks to achieve, as this information will be available for some products but not for others. The fact that is not explicitly forbidden does not mean that it should be allowed.
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.