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.