EU Commission Releases Revised Draft Regulations on Energy Labeling and Ecodesign of Lighting Products
In the wake of the news which emerged a week ago that the EU Commission intends to revive the proposed ecodesign and energy labeling package, and will not abandon the initiative as was widely feared, the Commission has released for feedback a revised draft regulation on the energy labeling of light sources, to repeal Delegated Regulation (EU) No 874/2012, and a revised draft ‘single lighting’ ecodesign regulation repealing Commission Regulation (EU) No 1194/2012.
Energy labeling of lighting products
A preliminary draft was released last December, requiring new rescaled energy labels for lighting products and specific product information to be registered in the new energy labeling product database, as mandated under the framework energy labeling Regulation (EU) 2017/1369.
Importantly, the energy efficiency classes set out in Table 1 mirror those set out in last year’s draft.
A number of changes are however noteworthy regarding the revised proposal:
The latest draft would add 3 further exemptions to the rules, such that they would not apply to light sources specifically tested and approved to operate in:
– railway vehicle lighting as set out in Directive 2008/57/EC of the European Parliament and of the Council;
– marine equipment as set out in Directive 2014/90/EU of the European Parliament and of the Council;
– medical devices as set out in Council Directive 93/42/EEC10 and in vitro medical devices as set out in Directive 98/79/EC of the European Parliament and of the Council.
Moreover, it is now proposed that the delegated regulation would not apply to light sources in range hoods within the scope of Commission Delegated Regulation (EU) No 65/2014 and light sources in battery-operated products including, but not limited to: torches, mobile phones with an integrated torch light, toys including light sources, desk lamps operating only on batteries, armband lamps for cyclists, solar-powered garden lamps (the first draft restricted this exception to what it described as ‘portable battery-operated containing products’).
In terms of the label, the following alterations are evident:
Formatting and color scheme change
Illustrative standard label and small packaging label both supplied.
Interestingly, a new label information requirement has been introduced. Point 1.3 of Annex III now requires that the number of the enacted regulation be printed on the label, along with the following information: supplier’s name or trade mark; supplier’s model identifier; the energy efficiency class; the head of the arrow containing the energy efficiency class shall be placed at the same height as the head of the arrow of the relevant energy efficiency class; the QR-code, linking to the model information available in the public part of the product database; the energy consumption, expressed in kWh of electricity consumption per 1000 hours of light source in on-mode operation.
The specific details of the label design have now been worked out and appear in Point 2.3 of Annex III, with aspects such as dimensions, typeface, background, border and color described.
The draft is now subject to a 4-week feedback period, running from 9 October 2018 to 6 November 2018.
Ecodesign of lighting products
As expected, the revised draft bears visible signs of the Commission’s commitment, renewed just recently, to developing a circular economy.
In terms of differences with last December’s draft, exemptions have, similarly with the energy labeling requirements, been altered. The exemptions section has been supplemented with the addition of marine equipment, as set out in Directive 2014/90/EU, medical devices, as set out in Council Directive 93/42/EEC and in vitro medical devices as set out in Directive 98/79/EC.
However, in contrast to the earlier draft the following exclusions have been removed, and would appear to be within the scope of the draft: HID light sources with specific effective ultraviolet power >2 mW/klm, HID light sources with color temperature Tc > 7000 K and light sources with a beam angle of less than 10˚.
Additionally, as has occurred with the labeling draft, the exclusion for light sources and separate control gears in battery-operated products is no longer specifically described as limited to portable battery-operated products.
Ecodesign requirements have been moved from Annex III into Annex II, and are presented as 3 types: energy efficiency requirements for both light sources and separate control gear, functional and information requirements.
Perhaps the most notable divergence from Regulation (EU) No 1194/2012 is the inclusion of a separate Article focsed on promoting the removability of parts for testing and dismantling from containing products at end of life. Article 4 instructs that manufacturers and importers of containing products shall ensure that light sources and separate control gears can be removed without being permanently damaged for verification purposes by market surveillance authorities. Manufacturers and importers of containing products shall ensure that light sources and separate control gears can be dismantled from containing products at end of life. Moreover, instructions must be available on request. Manufacturers and importers of containing products must provide information about the replaceability or non-replaceability of light sources and control gears by endusers or qualified persons without permanent damage to the containing product.
The requirements are scheduled to apply with effect from 1 September 2021.