It is the responsibility of the supplier to identify if the product is a light source or a containing product according to Commission Regulation (EU) 2019/2020 as amended by Regulation (EU) 2021/341. A containing product is defined as:
“a product containing one or more light sources, or separate control gears, or both, including, but not limited to, luminaires that can be taken apart to allow separate verification of the contained light source(s) (for Ecodesign and Energy Labelling verification), or separate control gears (Ecodesign verification), household appliances containing light source(s), furniture (shelves, mirrors, display cabinets) containing light source(s).”
Recital (6) in the amendment Commission Regulation (EU) 2021/340 states: “Products containing light sources from which these light sources cannot be removed for verification without damaging one or more of them, should be tested as light sources for compliance assessment and verification.”
What counts to define a product as a light source is the possibility to remove the light source for verification, without permanent damage to the contained light source (while if the containing product gets damaged is not relevant). If the light source cannot be removed from the containing product without being permanently damaged, the entire containing product should be defined as a light source (including the registration in the products database EPREL and bearing an EU energy label).
Once the supplier decides that their product is a product containing a light source (and not a light source in its entirety), there are two entities: (1) the supplier of the light source and (2) the supplier of the containing product. Each entity has its own set of obligations. In detail, the energy labelling for light sources is the responsibility of supplier number (1). That supplier has to do the registration in Eprel and generate the EU label.
As for energy labelling, the obligations that apply to suppliers of containing products are those from Article 3.2 of Commission Delegated Regulation (EU) 2019/2015, that reads:
“Suppliers of containing products shall:
(a) provide information on the contained light source(s), as specified in point 2 of Annex V (it applies from 1 March 2022);
(b) upon request by market surveillance authorities, provide information on how light sources can be removed for verification without permanent damage to the light source (it applies from 1 September 2021).”
This means that there is no obligation to generate the EU label for the light source and/or print it on the package of the containing product.
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.