Status

Regulations

For light sources, the current regulations are Energy Labelling (EU) No 2019/2015 and Ecodesign (EU) No 2019/2020. They came into effect in September 2021. Once the review process for those regulations is initiated, Topten will publish new policy recommendation on this page.

Types of Light sources

Energy labelling for light sources

A light source is a product whereby the light-emitting part cannot be easily removed – for example a light bulb, or a desk lamp with non-removable or ‘built-in’ LEDs. It is the manufacturer’s responsibility to ensure that a light source has the appropriate energy label printed on the product packaging.

Energy labelling for containing products

A containing product is a product that is designed to accommodate an easily removable light source – for example a desk lamp where the bulb can be removed by the user. The packaging for containing products does not display an energy label. However, if the containing product is placed on the market with an included light source, a reference to the energy label class of the included light source must be referenced in the technical documentation accompanying the product.

Removable by experts only

A light source is deemed as "removable" even if only an expert with specific tools and knowledge is able to do it. This means light sources in containing products often are not removable for the enduser, but there is no label for the luminaire as such (including the losses due to e.g. the design or lampshade).

Key policy recommendations

Energy-label must be mandatory also for light sources in a containing product

In order to ensure consumer-friendly information on energy efficiency of luminaires, it is absolutely necessary that also light sources in a containing product carry the label now only mandatory for the light source itself (unless built-in). From a consumer's point of view, light sources in a containing product which are only removable by an expert are the same as luminaires with built-in light sources. From a technical point of view, there is no need for a new measuring standard. The existing one can be applied to these types of lamps.

Measuring luminaires with an removable (by the enduser) light source to obtain luminaire efficiency

Luminaires with removable light sources can be measured and categorized in terms of their energy efficiency by using a reference light source (=bulb). This reference light source should be a suitable, standard bulb (frosted glass, 360° radiation, spots excluded) with a high enough luminous flux. This light source is measured on its own, as well as installed in the luminaire. Both Lumen-values are then but in relation to obtain information on the losses of light caused by the luminaire. The resulting luminaire efficiency is an indicator which can be used to compare these types of luminaires.

Repairs must be open to independent repairers

To lower the barrier for consumers to repair rather than replace their luminaire, the repair process must be fast, transparent, and affordable. This can only be achieved if independent repair shops have the possibility to handle repairs. Manufacturers oppose this stand and claim only authorized repair shops can deliver a safe and quality repair. As a consequence, they restrict distribution of parts, diagnostics, and repair tools.

The EU regulation should therefore (i) ensure that independent repairers can carry out repairs and (ii) clearly list what professional repairers need and need not to provide in order to be granted access to repair information through the manufacturers.

Reasonable pricing of spare parts

Prices must be fair and reasonable. They should not increase during the defined time period in which the spare parts must be made available. There should be a limit to the maximum cost of a spare part in relation to the cost of the luminaraire as a whole. At least, the regulation should add that prices for spare part should be “reasonable” or “proportionate”.

Empty A-Class when regulation enters into force

The energy efficiency classes should be defined in a way that the best class is empty when the regulation enters into force. According to the framework for energy labelling “a newly rescaled label should leave the top class empty to encourage technological progress”.

Policy Recommendations for Light Sources