Energy labeling: EU energy label for luminaires discontinued as of 25 December 2019

Category: compliance Industry: consumer goods Author: Year:
Philipp Reusch

As of 25 December 2019, the provisions of relevance for suppliers and dealers with regard to the EU energy label will cease to apply for luminaires. This is set down in the new Delegated Regulation of 11 March 2019 (Regulation (EU) 2019/2015). Luminaires are the overall product, and include a socket where lamps can be plugged in. The provisions will continue to apply for the lamps themselves.

What do suppliers and dealers have to keep in mind?

Due to the repeal of the labelling requirements for luminaires, suppliers and dealers offering luminaires on their own, without lamps, need to keep the following in mind:

  • The energy label and information relating to the label may not appear in any advertising (including the website).
  • The label and information relating to the label may not appear in the product description or in the product's technical data (exception: see the final point).
  • No energy label may be attached or affixed to the product at the point of sale. No energy label may be placed on the packaging of the luminaires or in the documentation contained in the packaging. This applies for all luminaires which are placed on the market as of 25 December 2019. Luminaires which were on the market before that date do not have to be modified to conform with these rules.

Background

The energy labeling provisions can be found in EU Framework Regulation 2017/1369, which has been replaced by Delegated Regulations for specific product groups. Until now, the provisions relating to luminaires have been found in Delegated Regulation (EU) No. 874/2012, whose Article 3 II and Article 4 II will be repealed as of 25 December 2019. Otherwise, the provisions of the new Implementing Regulation will not take effect until 1 September 2021. The labeling requirement for vacuum cleaners ceased to apply at the start of 2019, but this was not related to the issuance of a new Delegated Regulation, but to the Judgment of the ECJ in the case of Dyson Ltd, vs. the European Commission (Judgment of 8 November 2018, Case No. T-544/13).

Summary

Suppliers and dealers should keep in mind that labelling requirements for luminaires will cease to apply as of 25 December 2019 and make appropriate preparations. The provisions for lamps will continue to apply and are not affected by the repeal. It is not clear why EU lawmakers have allowed a gap to arise in the time periods of the labeling requirements, as this will create unnecessary uncertainty.

[December 2019]