European lighting rules moved from the old wattage-based label to a performance-based one, and the revision now in front of the Commission pushes further towards durability and circularity. For an exporter the practical effect is the same: the product file has to document more, and the label has to be reproducible from that file.
Nothing about the physics changes. A 100W replacement that delivers the same lumens as an old incandescent still competes on the same photometry. What changes is which numbers the regulator wants to see and how the scale is drawn.
What the Framework Now Asks
Ecodesign requirements for lamps and luminaires sit in a framework regulation with implementing measures per product family. The current direction adds requirements around standby power, the availability of spare parts and documentation of the lumen maintenance and colour consistency of the LED package inside the fitting.
| Requirement | What it targets | Why exporters feel it |
|---|---|---|
| Efficiency index scale | Performance per family, not per watt | Product data must match the label |
| EPREL registration | Digital product record | Needs a serial or batch reference |
| Durability documentation | L70 at stated hours | Requires test report in the file |
| Circularity info | Accessibility of parts | Drives design changes |
| Labelling repeal path | Removes legacy comparison | Older claims stop being valid |
The efficiency scale is the part that trips suppliers up. A family that scored well on the old scale can score badly once the reference changes, because the baseline moves with the available technology rather than with the historical lamp. Comparing an old declaration to a new one is not meaningful.
EPREL and the Digital File
Each model registers in the European Product Registry for Energy Labelling. The registration needs the model identifier, the efficiency class, the measured power consumption and the photometric data behind the label. A distributor cannot legally put a label on a model that is not registered, and a retailer cannot validly display one.
Registration is per model, not per shipment. A range that shares a driver and optics but differs in housing finish or length often needs its own entry if the declared power or flux changes. Plan the range so that a shared photometric file supports a single registration, and keep the model identifier stable through the life of the product.
Durability Becomes a Compliance Item
Stating L70 B50 at 25,000 hours is now expected documentation rather than a marketing line. That figure has to come from an LM-80 or a TM-21 extrapolation on the actual LED package in the fitting, with the driver’s thermal behaviour included. A declaration without that behind it is a weak file if a market surveillance authority asks.
This pushes design work upstream. A fitting marketed as a 30,000 hour product in a hot housing will not hold that number at the ambient the label assumes, so the thermal design has to be documented alongside the claim. Exporters who design for 60C ambient and declare for 25C are the ones that get caught.
Practical Steps for an Exporter
Pull the technical file before the next production run and check four things: the registered model identifier matches the nameplate, the declared power matches the label, the L70 claim has a test report behind it, and the label artwork uses the current scale.
Keep the declaration in the same language family the market expects and make sure the importer holds it. The importer carries the compliance duty in most member states, and a missing file stops a pallet at the border rather than at the dock.
Data that cannot be verified should carry an internal note rather than a confident number. A claim that a distributor cannot reproduce from the test report is worse than no claim at all.
Fact-check status: source list pending — the implementing measures and EPREL procedure numbers in this summary are tracked against the current framework text before publication.
