A Christmas gift to the lighting industry – selling products in Europe

Dec. 25, 2019

European regulation goes into effect 20 days after being published. As a result, the new Single Lighting Regulation (EU) 2019/2020 and the related Energy Labeling of Light Sources (EU) 2019/2015 came into force on Christmas 2019. Luckily, there is still time left until the Sept. 1, 2021 deadline to comply with the requirements.  The lighting industry should be aware of the changes, step by step.

Eco-design requirements for light sources and separate control gear (EU) 2019/2020

With the new standard, lighting products must comply to the European Eco-design requirements that are formulated in the three directives (EC) No 244/2009, (EC) No 245/2009 and (EU) No 1194/2012. All three must be in place by September 1, 2021, to be compliant with the above mentioned eco-design regulation (EU) No 2019/2020 – known as, Single Lighting Regulation (SLR). The previously known terms of lamps and luminaires will be replaced by light sources and containing products. This is happening because at the same time the European Commission is trying to motivate the manufacturers to commit themselves to a more circular economy approach where — like in the past — the lamps could be replaced and the housing was reused and, in case of recycling, easily disassembled. Now a luminaire with a nonreplaceable LED-module becomes a “light source” with all the consequences being formulated in the regulation. In general, all LED-based containing products will have to adhere to certain removability and replaceability requirements, unless a technical justification is provided. This technical justification needs to be part of the documentation, otherwise selling the product in Europe is prohibited. Additionally, various light source types will be phased out. For example, halogen R7s > 2700 lm lamps will be phased out starting September 1, 2021, and G9 -, G4 - and GY6.35 capped lamps and fluorescent T8 lamps will be phased out starting September 1, 2023.

It’s important to mention that if a light source is non-replaceable on a shelf or in an oven or refrigerator, these appliances or furniture become a light source and need to be in compliance with the regulation.

For most of the light sources, depending on the lumen output and the color rendering (CRI needs to be above 80), the minimum efficacy is now above 100 lm/W. The (network) standby power consumption needs to be less 0.5W. There are more functional requirements defined by the displacement, lumen maintenance and survival factor for LEDs and OLEDs. Defining a minimum of a six-step MacAdam ellipses in order to control the color consistency of the light source seems to be easily achievable and not expediently. On the other hand, flicker and stroboscopic effects are taken into account and these requirements are beneficial in creating better light quality.

In case of control gear, a minimum energy efficiency at full load is formulated depending on light source, type and wattage for which they are designed.

Energy Labeling of Light Sources (EU) 2019/2015

In line with the above-mentioned SLR, a new regulation covers the energy labeling of the light sources. A rescaling of the existing energy label from A++ to E was overdue, and one from A to G will replace it. For example, non-directional light sources will find themselves in group D or E after this regulation applies (Sept. 1, 2021). There is enough room and time for efficacy improvement until the 210 lm/W efficiency class A is reached.

Similar to the SLR, the energy labeling regulation applies on Sept. 1, 2021. It should be noted that §2 of Article 3 and 4 applies immediately. Consequently, luminaires should no longer be labeled regarding their energy efficiency. But on May 1, 2021, all light sources will need to be labeled and registered with their technical information in the European Product Registry for Energy Labelling (EPREL) database. This requirement already exists for lamps being marketed in Europe and is extended to the light sources. If a manufacturer decides to market a “luminaire with a non-replaceable LED-module,” it must be registered as a light source. Even if an appliance or furniture manufacturer decides to use non-replaceable modules, these products need to be registered by the time the database is available.

The intent is that the market surveillance authorities get the full picture of the product. End users get access to the public part of the database only to learn about the product efficiency. A mandatory Quick Response (QR) code on the new energy label leads to the specific product information page of the EPREL database.


How UL can help

We can support your needs in this transition and already perform all required tests for light sources necessary to complete the EPREL database when it becomes available.