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Energy Efficient Products

Are RGB LED modules/strip in scope of EU Ecodesign?

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.