Member's question : Energy Related Products (ERP) and Christmas lighting

Question : My question is around Energy Related Products (ERP) and Christmas lighting.  I think that many members will have had discussions and I suspect that members will have received quite a lot of conflicting opinions.

 

The question was actually raised on the Europa website FAQ’s but unfortunately I don’t think they actually answered the actual question raised.   My interest is based on a Notified Body opinion which I don’t think is actually correct.

 

Light sources with less than 60 lumen are excluded from the scope of the regulation. Does this mean that it does not matter how many light sources a luminaire has as long as all of them separately have a luminous flux of less than 60 lumen? If the light sources are attached to a luminaire and are not removable are you then supposed to add their luminous fluxes together to see if the requirement (less than a luminous flux of 60 lumen) is met? 

Answer 1

After a lot of internal discussions and with external testing houses and the Lighting association, we have interpreted the ERP regulation as per single light source. So per LED to be under 60 lumens. We have then asked suppliers to show testing for this and to be added to product specs. 

 

The ERP regulations at the time were more focused on the lighting chains such as the lighting strips you get with Philip hue etc.

 

We are constantly reviewing this to see if anything has changed to then reflect that in our approach. When speaking with the main suppliers in the market and reviewing the Christmas lighting marketing last year whilst everyone was trading peak, it seems most have gone down the same approach. 

Answer 2

We interpreted this as the whole chain not the individual LED.  If the whole chain is over 60 lumen and the colour is in scope of ErP we apply the required additional testing and ErP (Eco) labelling.

Answer 3

Short answer….Yes I believe you should sum the total of the LED’s.

 

Rationale

 

The EC_FAQ_EL- JAN 2023.pdf (europa.eu) states

 

 

(13) Question on multiple light sources in a luminaire each of them with less than 60 lumen (11-2012 – update 08-2019, update 2022)

Light sources with less than 60 lumen are excluded from the scope of the regulation. Does this mean that it does not matter how many light sources a luminaire has as long as all of them separately have a luminous flux of less than 60 lumen? If the light sources are attached to a luminaire and are not removable are you then supposed to add their luminous fluxes together to see if the requirement (less than a luminous flux of 60 lumen) is met?

 

(13) Answer on multiple light sources in a luminaire each of them with less than 60 lumen (11-2012 – update 08-2019, update 2022)

As explained in FAQ (1) of this section, a containing product is defined as: “a product containing one or more light sources, 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).”

 

What counts to define a product as a light source is the possibility to remove the light source for verification, without permanent damage to the contained light source (while if the containing product gets damaged is not relevant). If the light source(s) cannot be removed from the containing product without being permanently damaged, the entire containing product should be defined as a light source (including the registration in the products database EPREL and bearing an EU energy label). If we take the example of a luminaire with three light sources. If the three light sources are removable for verification purposes, then they are each of them in scope of the energy labelling regulation: each of them will need to be registered in EPREL and have defined the EU energy class. According to article 3.2, the supplier of containing products “shall:

(a) provide information on the contained light source(s), as specified in point 2 of Annex V (it applies from 1 March 2022);

(b) upon request by market surveillance authorities, provide information on how light sources can be removed for verification without permanent damage to the light source (it applies from 1 September 2021).”

 

This means that there is no obligation to generate the EU label for the contained light source(s) and/or print it on the package of the containing product. If the three light sources are not removable for verification purposes, the entire luminaire is a light source and in its entirety will need to meet the requirements of the regulation (thus the testing of the product will cover the three light sources on the luminaire altogether)

 

In order to answer the question if the lux should be summed you need to refer to question 5 in the FAQ which states:

 

The product brought to the market is e.g. the entire string of 5 m length. If that length gives more than 60 lumen, the product is a light source in scope.