Lighting Europe developed their guidance document on their own and asked the Commission to check draft versions of the document for correctness. While no factual mistakes seem to be apparent, the Commission cannot and will not approve or validate such guidance document. The Commission does not acknowledge or endorse any guidance document by third parties, and therefore stresses that these do not allow any legally binding interpretation.
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.
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.
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.
The answer depends.
If the light source is sold together with other parts in a single packaging, the product being sold is probably the collection of all the parts, i.e. the ‘complex product set’. As the light source is removable for verification, this ‘complex product set’ would be a containing product for the Ecodesign and Energy Labelling regulations, meaning that the packaging does not need to have the above information for the light sources, but only, from 1 March 2022, the info on the contained light source(s) in the technical documentation of the ‘complex product set’ (Commission Delegated Regulation (EU) 2019/2015 art.3(2) as amended by Commission Regulation (EU) 340/2021).
In the case of a light source being sold together with a router and power supply, it is to be checked if this combination of parts is a Connected Light Source (CLS), as defined in Commission Delegated Regulation (EU) 2019/2015, Annex I, definitions (6) and (7): the router is a data-connection part, and even if it is physically separated from the light source, it can still be considered a part of it. In this case, the ‘complex data set’ would be a light source.
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.
Commission Delegated Regulation (EU) 2019/2015 on Energy Labelling for light sources (including its amendment from Commission Regulation (EU) 2021/341), has a void regarding the size of the energy label. According to the Regulation Annex III:
“Suppliers shall choose a label format between point 1.1 and point 1.2 of this Annex. The label shall be:
- for the standard-sized label at least 36 mm wide and 72 mm high (correction from 75 to 72 post Omnibus);
- for the small-sized label (width less than 36 mm) at least 20 mm wide and 54 mm high. The packaging shall not be smaller than 20 mm wide and 54 mm high. Where the label is printed in a larger format, its content shall nevertheless remain proportionate to the specifications above. The small-sized label shall not be used on packaging with a width of 36 mm or more.”
a) Energy labels on existing products placed on the market before the application on 1 September 2021 of Commission Delegated Regulation (EU) 2019/2015:
• Existing labels are replaced by the rescaled labels in a format and size that permits it to cover the existing label e.g with stickers (according to Commission Delegated Regulation (EU) 2019/2015, Article 3(i), Article 4(e), annex III(1)). Thus the supplier can adapt the size depending on the existing label, keeping it proportionate to the specifications in the new delegated act.
b) Energy labels for new products placed on the market from 1 September 2021: Relevant provisions in Commission Delegated Regulation (EU) 2019/2015:
• According to Annex III(1), the customer is supposed to be able to see the whole label when s/he chooses the product, suggesting that the label should be on the part of the packaging meant to face the prospective customer. The label can be on another side, as long as an arrow containing the letter of the energy efficiency class is displayed on the side facing the customer, as detailed in the Annex.
• According to Article 4(a), the energy efficiency class must be clearly visible.
In the event that none of the size options from Annex III fits, there is nothing in the Regulation that impedes that the print of the energy label continues on an adjacent face of the packaging, as long as the provisions in Annex III(1) and Article 4(a) are met.
In the case of a box with four sides (front, back, bottom and top side) and assuming that the part of the packaging meant to face the prospective customer is the front side, the energy consumption and the QR code should be on the front side, while the supplier’s name and the model identifier (which are on the upper part of the label) should be on the top side. It should be avoided that part of the label ends up in a supposedly non-visible side such as the bottom part.
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.
Commission Delegated Regulation (EU) 2019/2015 as amended by Commission Delegated Regulation (EU) 2020/340 clearly states in Annex III table 3 that the energy consumption in on mode needs to be rounded up to the nearest integer, leaving no room for interpretation.
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.
Differently from Directive 2011/65/EU, the Ecodesign legislation does not restrict substances in products but sets energy consumption values to be respected in order for the products to be placed on the market. The latest Ecodesign act on lighting Commission Regulation (EU) 2019/2020 identifies mercury content as a significant environmental aspect in the life-cycle of a light source, but acknowledges that the use of hazardous substances, including mercury in light sources, is governed by Directive 2011/65/EU.
The RoHS Directive 2011/65/EC might impose other requirements such as the allowable mercury content in each single light source. In such a case a product can be in conformity with Ecodesign measures but not with the RoHS Directive and is therefore not allowed to be placed on the market.
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.
For a light source, the supplier declares:
- The color coordinates or chromaticity coordinates (x, y) (which must remain within the limit of article 2 (1) to be within the scope of Commission Delegated Regulations (EU) 2019/2015 on Energy Labelling and its amendment Commission Delegated Regulation (EU) 2021/340);
- Color consistency, expressed in phases of MacAdam ellipses (ellipse steps) (maximum 6, according to the Ecodesign Commission Regulation for Ecodesign (EU) 2019/2020, table 4).
During verification of the color consistency, all 10 products of the sample must have chromaticity coordinates (x, y) within the declared MacAdam ellipse steps, taking into account verification tolerances. The chromaticity coordinates to be considered are (after a short period of time) spatially averaged ones, (Commission Regulation (EU) 2019/2020, Annex I (56)). For the color consistency, neither the variation with time nor the spatial variation are considered.
The verification tolerance in this case (reported in Commission Regulation (EU) 2019/2020, Annex IV, table 6) is not a percentage of the number of of the number of the ellipses steps (that if for example, the supplier declares 6 steps, the determined value should stay within 6 + 10% = 6.6), but a variation of the center of the ellipse of 0.005 units in any direction with respect to the declared center (ellipse whose centre is inside the tolerance circle or square). These 0.005 units represent the variation of measurements (x, y) between different laboratories.
In conclusion:
1) it is not necessary to determine a measured center of the ellipse as the average of the values measured on the 10 test samples.
2) there is no requirement on the average of the values (x, y) measured with respect to the declared center (x, y) (there is no verification tolerance on the color coordinates by Commission Regulation (EU) 2019/2020, table 6).
Furthermore, the authorities of the Member State only apply the tolerances allowed for the purposes of verification set out in table 6 and only use the procedure described in Annex IV of the Ecodesign Commission Regulation (EU) 2019/2020, table 6. For the parameters set out in the table 6 other tolerances do not apply, such as those established by harmonized standards or in any other measurement method.
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.
Yes. One entry in Table 9 of Annex XI reads “CRI and R9 [0-100]”. The 0-100 range applies only to CRI and not to R9. This is in line with the definition of light source in article 2(1), with CRI that should be >0. In EPREL it is correctly allowed to register a value in the range - 100 to +100. This may be clarified in a later amendment to the Regulation.
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.
A containing product is defined as: “a product containing one or more light sources, including, but not limited to, luminaires that can be taken apart to allow separate verification of the contained light source(s), household appliances containing light source(s), furniture (shelves, mirrors, display cabinets) containing light source(s).”
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(s) 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).
If we take the example of a luminaire with three light sources. If the three light sources are removable for verification purposes, then they are each of them in scope of ecodesign.
If the three light sources are not removable for verification purposes, the entire luminaire is a light source and in its entirety will need to meet the requirements of the regulation (thus the testing of the product will cover the three light sources on the luminaire altogether).
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.
As for separate control gears, they are only in scope of ecodesign, As for light sources, the definition in Article 2(1) in both acts is the same. However, Energy Labelling has less exemptions than Ecodesign: this means that some light sources that are exempted in the Ecodesign act, are required to have an EU Energy Label.
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.
Separate Control Gears (SCGs) embedded in a multifunctional control board of an appliance can be qualified as components or sub-assemblies within the meaning of Article 2(2) of the Ecodesign Directive if these are (i) intended to be incorporated into products and (ii) are not placed on the market and/or put into service as individual parts for end -users or if their environmental performance cannot be assessed independently.
The SCGs concerned are intended to be placed in inter alia home appliances. Their environmental performance cannot be assessed independently but only together with the home appliance. The SCGs concerned meet the definition of components/sub-assemblies under the Ecodesign Directive. The SCGs concerned therefore do not fall within the scope of the Commission Regulation (EU) 2019/2020.
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.
Yes. According to Regulation (EU) 2017/1369, Article 11, 13. (b) (ii), the supplier is exempt from the obligation to supply a rescaled label for units placed on the market or put into service before the four month period if the non-rescaled and the rescaled label require different testing of the model and if no units belonging to same model or equivalent models are placed on the market or put into service after the start of the four-month period.
Both the non-rescaled and the rescaled label of light sources require the measurement of the energy consumption in on-mode and the useful luminous flux to calculate the values for the label (not the product information sheet, but this is not referred to in the cited subparagraph). Thus, the testing of the model for the new label could be interpreted as not different from the old one, but this is not the case. Article 11, 13 (b) ii) is applicable in the case of light sources for the following reasons:
a) to determine the energy class, it is true that only two tests are needed (on power and flux - and old results can be used), but results would be used in a different formula. Moreover, to determine the Energy consumption kWh/1000h that goes on the label, the correction factor for external control gear differs (it is not defined in the latest Regulation for lighting (EU) 2019/2015) thus changing the calculation.
b) the rescaled label is required to have not only 1) the energy class and 2) energy consumption kWh/1000h, but also the QR code to the EPREL website. The other parameters to be inserted mandatory in EPREL, where at least some light source models might need new testing, are:
Standby power Networked
Standby power (for CLS)
Spectral Power Distribution Chromaticity coordinates (x,y)
R9 colour rendering ((O)LED)
Survival factor ((O)LED)
Lumen Maintenance Factor ((O)LED)
Displacement factor ((O)LED MLS)
Flicker metric ((O)LED MLS)
Stroboscopic effect metric ((O)LED MLS)
Excitation Purity (for CTLS) I
ndicative lifetime L70B50 ((O)LED)
Various parameters for NDLS GLS, HL, CFLi, LED > 12000 lm (not regulated in Ecodesign before)
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.
In order to comply with the Regulation (EU) 2019/2015 the important thing is to make sure that light sources are accompanied by a label in line with the specifications under Annex III. The requirements for the labelling of light sources do not necessarily impose packaging. In this respect and for each light source which is placed on the market as an independent product (i.e. not in a containing product) and in packaging, the label shall be printed on the individual packaging, in the format set out in Annex III.
Given that Article 4 (e) of the 2019/2015 Regulation also refers to labels on light sources attached to the packaging, the possibility to join or fasten the label to the packaging in a stable way exists. This could include sticking the label to the package.
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.
A non-mains light source (NMLS) does not include the control gear. For this reason, the power consumed by the separate control gear is not counted when determining the on-mode power of the light source (see Commission Regulation (EU) 2019/2020, Annex I(25)). The same applies for the endurance tests in Annex V: the procedure refers to failure of the light source and hence failures of the separate control gear should not be counted.
Any suitable control gear can be used during the tests. The manufacturer indicates the details of the required power supply (i.e. the required input to the NMLS, and thus the required output of the separate control gear). As also specified in Commission Regulation (EU) 2019/2020, Annex V(a)(iii): standards provide guidance on the supply voltage source. Suppliers and MSAs can use any suitable control gear to perform tests on the light source. This applies not only for the endurance testing of Annex V, but for all tests, including e.g. measurement of light source power, luminous flux, color-characteristics, etc. (as specified in standards).
If a failure occurs, it should be checked if this is due to the control gear, and if that is the case, the control gear should be replaced (or maybe the entire test should be repeated from the start with a new control gear and a new light source).
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.
Light strips/strings/chains are not as such exempted from EU Ecodesign: they are in scope if they meet the requirements of Article 2(1) of Commission Regulation (EU) 2019/2020. Annex IV of the Ecodesign regulation reads:
“For light sources with linear geometry which are scalable but of very long length, such as LED strips or strings, verification testing of market surveillance authorities shall consider a length of 50 cm, or, if the light source is not scalable there, the nearest value to 50 cm. The light source manufacturer or importer shall indicate which separate control gear is suitable for this length.”
The 50 cm length is intended as something to facilitate testing and not decisive for the scope. The product brought to the market is e.g. the entire string of 5 m length. If that length gives more than 60 lumen, the product is a light source in scope. If a length of 50 cm is tested, the result should be scaled up/down to the full product length.
Scaling up/down might create small discrepancies in the results (due to the voltage variation, small auto-shading effects when testing long lengths, and/or the use of a different control gear for the 50 cm length), but this is not necessarily a problem. According to the legislation, the Market Surveillance Authorities will perform verification testing at 50 cm: therefore, manufacturers/importers of light sources have to indicate which control gear is suitable for this length. If the verification for 50 cm leads to a flux < 60 lumen (for 50 cm), a scaling-up check (linear with length) could be done to see if the light source is in scope. Manufacturers/importers should provide their declared values (in the technical documentation) (also) for 50 cm.
When the scale up/down of the verification results is not possible, the final product is the one of 50 cm length. This is the case for light strings sold in undefined measures from a roll (i.e. where the customer can chose in the shop which measure to buy and the dealer cuts the requested piece). All values are related to 50 cm (because there is no other identifiable final product when the manufacturer/importer gives the roll to the dealer).
Battery-operated products are out of scope of both regulations.
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.
Article 2(1) in both the Ecodesign and Energy Labelling acts reads that: “(d) light-emitting parts contained in a light source from which these parts cannot be removed for verification as a light source” are not light sources. This definition is relevant for light strings/chains/strips: this light source cannot be dismantled up to the minimum light-emitting part, as the light-emitting part is not a light source: the light source in scope is the upper level, i.e. the entire light strings/chains/strips.
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.
Flash light sources are not as such exempted from EU Ecodesign: they are in scope if they meet the requirements of Article 2(1) of Commission Regulation (EU) 2019/2020.
If flash light sources can be set at the mode of steady light, this is the mode to be considered. If instead these lights only flash, this is normally due to some form of lighting control. The definition of ‘on-mode’ power (from Commission Regulation (EU) 2019/2020 Annex I (25)) says that lighting controls should be disconnected or switched off. This is also repeated in Annex I (29), in the definition for “Reference control settings”. If the control is instead fully integrated in the light source, we acknowledge that it might be difficult to switch it off. In general standards require light sources to reach a stable operation before starting the test. To be in this situation, it is important to know how to guarantee that a steady light is not possible.
Finally, if the lighting control cannot be disconnected or switched off, it is to be checked if the light source meets the definition for ‘scene-lighting or stage lighting use’ in Commission Regulation (EU) 2019/2020, Annex III.3(m) and (w)(2) (as amended by Commission Regulation (EU) 2021/341) or for 'signaling' (Annex III.3(a): in this case, only information requirements would apply.
In case the flash light source cannot in any way be forced to reach a steady state, this light source is not in scope because it is not possible to measure it according to the Regulation.
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.
Fluorescent UVA tubes are not phased out by the Ecodesign Commission Regulation (EU) 2019/2020, neither in 2021, nor in 2023. If they meet the definition of Article 2(1) for “light sources” they are in scope. The (x,y) chromaticity coordinates need to be checked in particular.
If they are in scope, it is to be checked if exemption from Annex III.3(b) or exemption from Annex III.3(c) may apply.
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.
Yes, a soldering tool be regarded as a common available tool.
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.
In Regulation (EU) 2019/2015 the word monochrome is used, with illustrations in Annex III and VII of the intended labels and arrows to be used. The pictures suggest that monochrome refers to black on white background but the term 'monochrome' does not exclude that different shades of black and white could be applied, provided that the information remains clearly legible.
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.
Flash light sources are not as such exempted from EU Energy Labelling: they are in scope if they meet the requirements of Article 2(1) of Commission Delegated Regulation (EU) 2019/2015.
If flash light sources can be set at the mode of steady light, this is the mode to be considered. If instead these lights only flash, this is normally due to some form of lighting control. The definition of ‘on-mode’ power (from Commission Delegated Regulation (EU) 2019/2015 Annex I (24)) says that lighting controls should be disconnected or switched off. This is also repeated in Annex I (27), in the definition for “Reference control settings”. If the control is instead fully integrated in the light source, we acknowledge that it might be difficult to switch it off. In general standards require light sources to reach a stable operation before starting the test. To be in this situation, it is important to know how to guarantee that a steady light is not possible.
In case the flash light source cannot in any way be forced to reach a steady state, this light source is not in scope because it is not possible to measure it according to the regulation.
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.
Yes. According to Regulation (EU) 2017/1369, Article 11, 13. (b) (ii), the supplier is exempt from the obligation to supply a rescaled label for units placed on the market or put into service before the four month period if the non-rescaled and the rescaled label require different testing of the model and if no units belonging to same model or equivalent models are placed on the market or put into service after the start of the four-month period. Both the non-rescaled and the rescaled label of light sources require the measurement of the energy consumption in on-mode and the useful luminous flux to calculate the values for the label (not the product information sheet, but this is not referred to in the cited subparagraph). Thus, the testing of the model for the new label could be interpreted as not different from the old one, but this is not the case. Article 11, 13 (b) ii) is applicable in the case of light sources for the following reasons:
a) to determine the energy class, it is true that only two tests are needed (on power and flux - and old results can be used), but results would be used in a different formula. Moreover, to determine the Energy consumption kWh/1000h that goes on the label, the correction factor for external control gear differs (it is not defined in the latest Regulation for lighting (EU) 2019/2015) thus changing the calculation.
b) the rescaled label is required to have not only 1) the energy class and 2) energy consumption kWh/1000h, but also the QR code to the EPREL website. The other parameters to be inserted mandatory in EPREL, where at least some light source models might need new testing, are:
Standby power
Networked Standby power (for CLS)
Spectral Power Distribution Chromaticity coordinates (x,y)
R9 color rendering ((O)LED)
Survival factor ((O)LED)
Lumen Maintenance Factor ((O)LED)
Displacement factor ((O)LED MLS)
Flicker metric ((O)LED MLS)
Stroboscopic effect metric ((O)LED MLS)
Excitation Purity (for CTLS)
Indicative lifetime L70B50 ((O)LED)
Various parameters for NDLS GLS, HL, CFLi, LED > 12000 lm (not regulated in Ecodesign before)
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.
An RGB LED module/strip is a light source in scope of Ecodesign if it meets the requirements of Commission Regulation (EU) 2019/2020, art.2(1). In this particular case, it falls within the scope of Ecodesign if it is ‘intended to be possibly tuned to emit light with the optical characteristics listed in points (a)-(d)’.
If the RGB LED models/strip meets the above requirement, all light source characteristics shall be reported for the ‘reference control settings’ (Annex I (29)).
If the light source in scope meets the definition of Annex I (8), it is a ‘color-tunable light source’ (CTLS).:
If the product and its controls are such that the R, G and B LEDs can be switched on/off only in alternation, (i.e. 5 seconds of red light, followed by 5 seconds of blue light and then 5 seconds of green light), then the product is not a light source in scope.
However, if the product can mix the colors contemporaneously so that it can be tuned to emit (white) light with chromaticity coordinates inside the range of art.2(1), it is a light source in scope and it would then indeed be a CTLS.
A test of the light source at reference control settings (providing Pon, Φuse, CRI, NDLS/DLS), together with the information on factors and parameters provided in Commission Regulation 2019/2020 Annex II point 1(a), will allow computation of Ponmax = C × (L + Φuse/(F × η)) × R, which can be compared with the measured Pon. The L70B50 lifetime is not necessary for this calculation. If the product is in scope, it also has to meet the functional requirements of Commission Regulation (EU) 2019/2020 Annex II point 2. This implies that an L70B50 lifetime has to be declared so that the lumen maintenance requirement of Table 4 is met.
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.
In Regulation (EU) 2019/2015 the word monochrome is used, with illustrations in Annex III and VII of the intended labels and arrows to be used.
The pictures suggest that monochrome refers to black on white background but the term 'monochrome' does not exclude that different shades of black and white could be applied, provided that the information remains clearly legible.
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.
The fact that the Energy label for luminaires is discontinued means that there has been no obligation for luminaires to bear an Energy label since 25 December 2019. This is stated in Article 9 of Commission Delegated Regulation (EU) 2019/2015 as follows:
'Delegated Regulation (EU) 874/2012 is repealed with effect from 1 September 2021, with the exception of paragraph 2 of Article 3 and paragraph 2 of Article 4 which are repealed with effect from 25 December 2019.' Therefore, there are no Energy Labelling provisions dedicated to luminaires after 25 December 2019. Stocks placed on the market before 25 December 2019 can stay indefinitely and there is no need to remove/cancel/hide the EU Energy label.
It is to be noted that certain luminaires could meet the definition of light source in the latest Energy Labelling act Commission Delegated Regulation (EU) 2019/2015 and thus be required to bear an Energy label according to it.
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.
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.