{
  "type": "problem",
  "slug": "led-lighting",
  "lang": "en",
  "url": "https://www.conphora.com/solutions/problem/led-lighting/",
  "markdown": "https://www.conphora.com/solutions/problem/led-lighting.md",
  "title": "We sell LED lamps or luminaires",
  "description": "The rules for LED lamps and luminaires: ecodesign Regulation (EU) 2019/2020, the A to G energy label, EPREL registration, electrical safety and EMC.",
  "answer": "LED lamps and luminaires must meet the Low Voltage and EMC Directives, ecodesign Regulation (EU) 2019/2020 for light sources and energy labelling Regulation (EU) 2019/2015. A lamp sold on its own carries the A to G label on its packaging and is entered in the EPREL database before its first unit is placed on the market. A luminaire has no label but gives information on its light sources.",
  "theme": {
    "id": "batteries-electronics",
    "label": "Batteries and electronics"
  },
  "roles": [
    {
      "id": "manufacturer",
      "label": "Manufacturer"
    },
    {
      "id": "importer",
      "label": "Importer"
    }
  ],
  "regulations": [
    "LVD",
    "EMC",
    "ErP",
    "ELR"
  ],
  "path": [
    "regulation-library",
    "product-validation"
  ],
  "trigger": "A retailer asks for the EPREL registration and the product information sheet, or a buyer asks whether your luminaire needs an energy label",
  "keep": "Documents on the ecodesign conformity assessment and the declaration for 10 years after the last product was manufactured (Directive 2009/125/EC Article 8(3)); EPREL compliance data for 15 years after the final unit of a model was placed on the market (Regulation (EU) 2017/1369 Article 4(6))",
  "why": [
    {
      "text": "A lamp or luminaire is regulated from three sides: electrical safety and EMC, ecodesign, and the energy label. Ecodesign for lighting is set by Regulation (EU) 2019/2020, which lays down requirements for placing light sources and separate control gears on the market, including those placed on the market in a containing product (Article 1(1)), and applies from 1 September 2021 (Article 11). Its conformity assessment follows Article 8 of the Ecodesign Directive, through internal design control or a management system (Article 5(1)).",
      "sources": [
        1
      ]
    },
    {
      "text": "The packaging tells the buyer what the lamp does. A light source placed on the market on its own, in packaging displayed at the point of sale, shows among other things the useful luminous flux in a font at least twice as large as the on-mode power, the colour temperature, the beam angle for directional lamps, the electrical interface, the L70B50 lifetime for LED and OLED, the on-mode and standby power, the colour rendering index and any dimming limits (Annex II, point 3(b)).",
      "sources": [
        1
      ]
    },
    {
      "text": "The energy label is set by Delegated Regulation (EU) 2019/2015 under the framework Regulation (EU) 2017/1369. Suppliers of light sources sold on their own print the A to G label on the packaging, enter the product information sheet parameters and the technical documentation into the product database, and give dealers electronic labels and information sheets (Article 3(1)). Suppliers of containing products provide information on the contained light sources (Article 3(2)). Light sources do not include products from which the light sources can be removed for verification (Article 2(1), as amended by Delegated Regulation (EU) 2021/340).",
      "sources": [
        2
      ]
    },
    {
      "text": "The product database is EPREL in practice. Before placing on the market a unit of a new model covered by a delegated act, the supplier enters the model's information in the public and compliance parts of the database (Regulation (EU) 2017/1369, Article 4(1)), and keeps it in the compliance part for 15 years after the final unit (Article 4(6)). A change relevant to the label or the information sheet makes a new model (Article 4(4)).",
      "sources": [
        3
      ]
    },
    {
      "text": "Ecodesign implementing measures adopted under Directive 2009/125/EC continue to apply after the Ecodesign Directive was repealed by Regulation (EU) 2024/1781 from 18 July 2024; for them the directive's provisions on CE marking, conformity assessment and penalties remain in place until the measures are repealed (Regulation (EU) 2024/1781, Article 79(1)(b)).",
      "sources": [
        5
      ]
    }
  ],
  "steps": [
    {
      "name": "Decide whether you sell a light source or a containing product",
      "text": "A light source is an electrically operated product meant to emit light within the optical limits of the regulations. A containing product, such as a luminaire, an appliance or furniture with lights, contains one or more light sources or separate control gears. Light sources do not include products from which the light sources can be removed for verification, so a product whose light sources cannot be removed is assessed against the light source definition itself.",
      "item": "regulation-library"
    },
    {
      "name": "Meet the ecodesign requirements and the packaging information",
      "text": "Regulation (EU) 2019/2020 applies the requirements of its Annex II from the dates in that annex, also to light sources placed on the market in a containing product. A light source sold on its own shows on its packaging the useful luminous flux, colour temperature, beam angle where relevant, electrical interface, L70B50 lifetime for LED, on-mode and standby power, colour rendering and any dimming limits."
    },
    {
      "name": "Label the packaging and register the model in EPREL",
      "text": "For a light source sold on its own in packaging, the supplier prints the A to G label on the packaging, enters the product information sheet parameters and the technical documentation into the product database before placing the first unit of a new model on the market, and gives dealers an electronic label and information sheet."
    },
    {
      "name": "Give the light source information for a luminaire",
      "text": "A supplier of a containing product provides information on the contained light sources as set out in Annex V, point 2, of Regulation (EU) 2019/2015, and on request of a market surveillance authority explains how the light sources can be removed for verification without permanent damage. The information duty applies from 1 March 2022."
    },
    {
      "name": "Cover electrical safety and EMC in one declaration",
      "text": "A mains lamp or luminaire must meet the safety objectives of the Low Voltage Directive and the essential requirements of the EMC Directive. Draw up the technical documentation, sign one EU declaration of conformity that names every act concerned, and affix the CE marking.",
      "item": "product-validation"
    },
    {
      "name": "Show the class wherever you sell or advertise",
      "text": "Visual advertisements and technical promotional material for a specific model, including online, show the energy efficiency class and the range of classes on the label. Online dealers show the label and information sheet as set out in the regulation, and platforms that host sellers enable that display."
    }
  ],
  "documents": [
    {
      "name": "Technical documentation for the light source",
      "from": "The manufacturer, importer or authorised representative",
      "ground": "Regulation (EU) 2019/2020 Article 5(2) to (4)"
    },
    {
      "name": "EPREL entry with product information sheet and technical documentation",
      "from": "The supplier",
      "ground": "Regulation (EU) 2017/1369 Article 4(1); Regulation (EU) 2019/2015 Article 3(1)(b) and (d)"
    },
    {
      "name": "Energy label on the packaging and electronic label for dealers",
      "from": "The supplier",
      "ground": "Regulation (EU) 2019/2015 Article 3(1)(a) and (g) and Annex III"
    },
    {
      "name": "EU declaration of conformity",
      "from": "The manufacturer",
      "ground": "Low Voltage Directive Article 15; Directive 2009/125/EC Article 5"
    }
  ],
  "risks": [
    {
      "title": "Testing costs can come back to you",
      "text": "Market surveillance authorities have the right to recover from the supplier the costs of document inspection and physical product testing in case of non-compliance with the energy labelling rules (Regulation (EU) 2017/1369 Article 8(5)).",
      "source": 3
    },
    {
      "title": "One failed model takes its twins with it",
      "text": "Corrective or restrictive measures extend to all units of a non-compliant model and its equivalent models, except units the supplier shows to be compliant (Regulation (EU) 2017/1369 Article 10(5)).",
      "source": 3
    },
    {
      "title": "Authorities can require corrective action, up to withdrawal",
      "text": "The market surveillance articles of Regulation (EU) 2024/1781 apply to products regulated by implementing measures under Directive 2009/125/EC (Article 79(2)). Where authorities have sufficient reason to believe that such a product presents a risk and find it non-compliant, they require corrective action within a reasonable period, which may include preventing it from being made available, withdrawal or recall (Regulation (EU) 2024/1781 Article 69(1); Regulation (EU) 2019/1020 Article 16(3)).",
      "source": 5
    }
  ],
  "faq": [
    {
      "q": "Does a luminaire need an energy label?",
      "a": "Not a label of its own. The energy labelling regulation for light sources discontinued the luminaire label; the supplier of a containing product gives information on the contained light sources instead (Regulation (EU) 2019/2015, recital 11 and Article 3(2))."
    },
    {
      "q": "The LEDs in our luminaire cannot be removed. What then?",
      "a": "Light sources do not include products from which the light sources can be removed for verification (Regulation (EU) 2019/2015, Article 2(1), as amended by Delegated Regulation (EU) 2021/340), so a product whose LEDs cannot be removed is assessed as a light source itself, with the label and database duties that follow. The ecodesign rules also require containing products to allow light sources and separate control gears to be replaced with common tools, unless the technical documentation justifies otherwise, and to be removed without damage for verification (Regulation (EU) 2019/2020, Article 4(1))."
    },
    {
      "q": "Since when do these rules apply?",
      "a": "Both Regulation (EU) 2019/2020 and Regulation (EU) 2019/2015 apply from 1 September 2021; the database entry under Article 3(1)(b) of Regulation (EU) 2019/2015 applied from 1 May 2021, and the information duty for containing products under Article 3(2)(a) from 1 March 2022 (Article 11 and Article 10 respectively)."
    },
    {
      "q": "Did the new Ecodesign Regulation replace these rules?",
      "a": "No. Regulation (EU) 2024/1781 repealed the Ecodesign Directive from 18 July 2024, but the directive's provisions on conformity, CE marking and penalties continue to apply to products regulated by its implementing measures until those measures are repealed (Regulation (EU) 2024/1781, Article 79(1)(b))."
    },
    {
      "q": "What must our marketplace listing show?",
      "a": "The dealer provides the label and product information sheet in distance selling, and visual advertisements show the energy class and the range of classes (Regulation (EU) 2019/2015, Article 4(b) and (c)). A hosting platform enables the display of the electronic label provided by the dealer (Article 5)."
    }
  ],
  "sources": [
    {
      "title": "Regulation (EU) 2019/2020 laying down ecodesign requirements for light sources and separate control gears (consolidated text of 1 September 2021)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R2020-20210901",
      "accessed": "2026-10-04"
    },
    {
      "title": "Delegated Regulation (EU) 2019/2015 on energy labelling of light sources (consolidated text of 30 September 2023)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R2015-20230930",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2017/1369 setting a framework for energy labelling (consolidated text of 1 May 2021)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02017R1369-20210501",
      "accessed": "2026-10-04"
    },
    {
      "title": "Directive 2009/125/EC establishing a framework for the setting of ecodesign requirements for energy-related products",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/eli/dir/2009/125/oj",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/eli/reg/2024/1781/oj",
      "accessed": "2026-10-04"
    }
  ],
  "related": [
    "ecodesign-requirements",
    "power-adapter-imported",
    "weee-registration",
    "emc-test-failed"
  ],
  "reviewer": "Conphora compliance team",
  "reviewedAt": "2026-10-04",
  "notice": "General information, not legal advice."
}