A guide into stress-free product compliance

Energy labels for lighting

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.

Who has to do what and when?

Energy labels for luminaires have been cancelled per 25 December 2019, but energy labels for ‘light sources’ remain. 
Energy label Regulation (EU) 2019/2015, Ecodesign Regulation (EU) 2019/2020 and the European Product Database for Energy Labelling (EPREL) will cause many changes for lighting products on September 1st, 2021.

Not all “lamps” are included, we have summarised the included and excluded ones in the following five questions. 

1 - Do all the following optical characteristics apply to the light source ? 

There are four highly technical, optical criteria that define which light sources need an energy label. Only light sources that fit within ALL of the following four optical characteristics are included, others are exempted. 
It applies to all light sources with “incandescence, fluorescence, high-intensity discharge, inorganic light emitting diodes (LED) or organic light emitting diodes (OLED), or their combinations as lighting technology”.
Just a few light sources are exempted based on these criteria.

a. Chromaticity coordinates x and y in the range 0,270 < x < 0,530; and - 2,3172 x2 + 2,3653 x - 0,2199 < y < - 2,3172 x2 + 2,3653 x - 0,1595.

These chromaticity coordinates enclose ‘white’ light. Examples of light sources outside these coordinates are ultraviolet (blue), infrared (red, gold), grow lights (purple) and collagen (pink) lamps. Light sources with changing colours including white light are not exempted. 

These chromaticity coordinates have not changed in comparison to the previous lighting regulation(s).

Note: High-pressure sodium (HPS) light sources that do not fulfil this condition (a) are still considered as light sources.

b. Luminous flux < 500 lm/mm2.
This criterium excludes light sources with a very high flux density: concentrated light sources such as for instance laser sources and photographic flash tubes. The best LED light sources currently on the market achieve up to 300 lm/mm2.

c. Luminous flux between 60 and 82000 lumen.
Light sources below 60 lumen: very weak light sources including a large variety of dashboard, status, display, panel or pilot lights and some purely decorative lamps. A LED light of 1 W electrical power emits about 80-100 lumens. 

Light sources above 82000 lumen: these are very powerful lamps such as sports lighting; theatre, stage or studio lighting and some outdoor and industrial applications.

d. Colour rendering index (CRI) > 0.
Light sources with colour rendering index below 0 are rare; examples are monochrome lasers and low pressure sodium lamps.

If "Yes", then it is a light source and must be registered.
(Unless one of the following exemptions applies).

2 - Is it used with one of the following products ?

Regulation (EU) 2019/2015 does not apply to light sources used in or on the following products:

  • Electronic displays; 
  • Range hoods; 
  • Battery-operated products; operating only on the voltage supplied from the battery in the same product, without being connected (directly or indirectly) to the mains electricity supply; 
  • Bicycles and other non-motorised vehicles;  
  • Spectroscopy and photometry equipment. 

The intended use must be indicated on the packaging, in the product information and in the advertising. With a clear indication that the light source is not intended for other applications.

If "Yes", then this light source is NOT in the scope and does NOT have to be registered.

3 - Is it intended for one of the following applications ?

Light sources used for the following applications are excluded by Annex IV of Regulation (EU) 2019/2015. 
But the light sources shall be approved for the mentioned use according to the related specific legislation.

  • Emergency lighting; 
  • Medical devices (Regulation (EU) 2017/745) including in vitro diagnostic devices (Regulation (EU) 2017/746); 
  • Motor vehicles (Regulation (EC) 661/2009); 
  • Two- or three-wheel vehicles and quads (Regulation (EU) 168/2013); 
  • Agricultural and forestry vehicles (Regulation (EU) 167/2013) and interchangeable machinery (Directive 2006/42/EC); 
  • Non-road mobile machinery (NRMM Regulation (EU) 2016/1628).

Annex IV of Regulation (EU) 2019/2015 exempts even more light sources for very specific applications. 

These exceptions are not detailed here in order to keep it brief with a focus on mainstream lighting products. 

Nevertheless some examples are: traffic signalling, image capture and projection, certain ultraviolet light sources, germicidal (disinfection) use, fly trapping, ozone generation, sun-tanning, horticulture, works of art, military or defence, marine, railway, aviation, radiological and nuclear medicine. 

If "Yes", then this light source is NOT in the scope and does NOT have to be registered.

4 - Is it a ‘containing product’ ?

The answer to this question is often more complicated than might be expected at first sight.

The initial definition was amended in Regulation (EU) 2021/340 and now reads as follows: 
Containing product’ means a product containing one or more light sources, or separate control gears, or both, including, but not limited to, luminaires that can be taken apart to allow separate verification of the contained light source(s), household appliances containing light source(s), furniture (shelves, mirrors, display cabinets) containing light source(s).

If the light source and separate control gear cannot cannot be taken apart from a containing product for verification, then the entire containing product is to be considered a light source. Therefore, as long as light sources can be removed without permanent damage and thus a verification is possible, the containing product itself is NOT to be considered a light source. Upon request by market surveillance authorities, suppliers shall provide information on how light sources can be removed for verification without permanent damage to the light source.

User information

If a light source is placed on the market as a part in a containing product, then:

  • The technical documentation for the containing product shall clearly identify the contained light source(s), including the energy efficiency class(es); 
  • The following text shall be displayed, clearly legible, in the user manual or booklet of instructions: ‘This product contains a light source of energy efficiency class <X>’, where <X> shall be replaced by the energy efficiency class of the contained light source. If the product contains more than one light source, the sentence can be in the plural, or repeated per light source, as suitable. 

If "Yes", then it is a containing product and NOT a light source and does NOT have to be registered.

5 - Is it a component of a light source ?

The following components or parts are excluded:

  • LED die or LED chip: “a small block of light-emitting semiconducting material on which a functional LED circuit is fabricated”; 
  • LED package: “a single electric part comprising principally at least one LED die; that does not include a control gear or parts of it, a cap or active electronic components and is not connected directly to the mains voltage. It can include one or more of the following: optical elements, light converters (phosphors), thermal, mechanical and electric interfaces or parts to address electrostatic discharge concerns. But any similar light-emitting devices that are intended to be used directly in an LED luminaire, are considered to be light sources and not excluded.”
  • Product containing light source(s) that can be removed for verification are excluded, the (removed) light sources are not  excluded.
  • Light emitting parts of a light source that cannot be removed for verification as a light source.

In other words the Regulation applies only to light sources as a whole, not to its components and not to the enclosure or housing if that can be removed from the light source.

If "Yes", then it is a component and NOT a (whole) light source and does NOT have to be registered.

If the light source must be registered, what are the steps to be taken?

EPREL DATABASE

Specifically for the EPREL database, you as a supplier (manufacturer, authorised representative or importer) must:

  • Enter the parameters of the product data sheet according to Annex V in EPREL (public part); 
  • Enter the contents of the technical documentation according to Annex VI in EPREL (conformity part); 
  • Consider a product as a new model if the changes made are relevant to the label or product information sheet; 
  • Provide the information in the conformity part of the EPREL database for 15 years after the last unit of a model has been placed on the market; 
  • The information in the public part of EPREL must never be deleted!

The EPREL product database can be accessed via the following link: https://energy-label.ec.europa.eu

To enter product data into the product database for the first time you need to create an account. After logging in, you will be asked to register as a "supplier" (manufacturer, importer, authorised representative). Guidance (“wiki”) provided by the European Commission is available after login. 

SUPPLIERS

Besides EPREL, further obligations for suppliers are:

  • Ensure that each unit has a correct label on the packaging;
  • Provide the product information sheet in printed form upon trader request (5 days);
  • In visual advertising or technical promotional material, including on the Internet, provide information on the energy efficiency class and the available range by means of an “arrow illustration”: Energy labels for lighting - energy efficiency class icon
  • Provide traders with an electronic label and an electronic product information sheet; 
  • Provide a new label as a sticker in the same size as the existing one at the trader's request.

TRADERS

Traders (shops, websites) have the following obligations:

  • Display the label clearly visible at the point of sale, also online (website, online shop); 
  • Provide customers with the product data sheet (in physical form on request);
  • In visual advertising or technical promotional material, including on the Internet, provide information on the energy efficiency class and the available range by means of the  “arrow illustration”; Energy labels for lighting - energy efficiency class icon
  • Replace existing labels on point-of-sale light sources with the rescaled labels in such a way that they cover the existing label, even if it is printed on or attached to the packaging before March 1st, 2023 (18 months period); 
  • In online trading, only a 14-day implementation period applies from 1 September 2021!

Final remark:
The legislation mentioned in this article is extensive and comprehensive. Summarising the contents implies omitting parts, including parts that may be relevant in certain situations. This article is intended to provide a quick overview of the use of EPREL with regard to light sources and has been prepared to the best of our knowledge. 

Refer to the following legislative documents for all details. Choose the latest consolidated version.


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