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.