Are fluorescent UVA tubes in scope of EU Ecodesign?

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.}