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.