Οι κανονισμοί SLR – ELR και η βιομηχανία φωτισμού
Η γενική γραμματέας της LightingEurope, κ. Ουρανία Γεωργουτσάκου, γράφει στο περιοδικό «Ηλεκτρολόγος» για όσα πρέπει να γνωρίζει η βιομηχανία φωτισμού σχετικά με τους κανονισμούς οικολογικού σχεδιασμού και ενεργειακής επισήμανσης της Ευρωπαϊκής Ένωσης (ΕΕ).
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The SLR, ELR, and You
What the Lighting Industry Needs to Know about the EU’s Ecodesign and Energy Labelling Regulations
In December 2019, the European Commission published the new Single Lighting Regulation (SLR) (i.e. Ecodesign Regulation for lighting) and the Energy Labelling Regulation (ELR). In February 2021 few more requirements and corrections have been introduced in both Regulations, by the Regulation (EU) No 2021/341, which amends the SLR and by the Regulation (EU) No 2021/340, which amends the ELR.
Whereas the SLR sets product-specific performance requirements for energy-using and energy-related products, the ELR lists the labelling requirements for selling those products on the EU market.
After nearly five years of negotiations, the SLR and ELR will apply from 1 September 2021, except for the removal of labelling requirements for luminaires which already took effect on 25 December 2019. Both will have significant consequences for the lighting industry.
ELR applies to light sources only, while SLR applies to light sources and separate control gear, with luminaires (now generally identified as containing products) only being indirectly addressed. Nevertheless, luminaire manufacturers must review the rules and ensure that their products comply with the new requirements.
Ecodesign – Improving Product Performance
The Ecodesign Regulation (SLR) establishes EU-wide rules for improving product performance of light sources and separate control gear.
Similar to the ELR, the SLR defines a light source to include lamps, modules, and even some containing products. A containing product is defined as a product containing one or more light source(s), or separate control gears, or both. This includes luminaires, household appliances and furniture containing light source(s). The supplier of a containing product must ensure that the light source and separate control gear used in their containing product complies with all relevant EU legislation – including the SLR and the ELR.
As the SLR sets minimum mandatory requirements for energy efficiency, any product that fails to meet these requirements will be phased out, starting with products like CFLi lamps and halogen R7s > 2700 lm lamps on 1st of September 2021. As this phase-out happens, these light sources will need to be replaced with new energy-efficient light sources and lighting installations will have to be renovated.
The new SLR introduces several elements of the circular economy. For example, manufacturers, importers, and authorised representatives of containing products must ensure that light sources and separate control gears can be easily replaced using commonly available tools and without permanently damaging the containing product. Furthermore, they also need to ensure that light sources and separate control gears can be removed without being permanently damaged for verification purposes by market surveillance authorities. If the light sources cannot be removed for verification without damaging one or more of them, then the whole containing product is penalised because it will be tested as a light source and would need to comply with the requirements of the light sources set by the SLR and the ELR.
The SLR also requires that manufacturers, importers, and authorised representatives of containing products provide information about the replaceability or non-replaceability of light sources and control gears by end-users or qualified persons.
For your convenience, LightingEurope has developed pictograms covering the required information on replaceability/non-replaceability, which are freely available on the LightingEurope website for all companies to download and use.
ELR – Empowerment through Information
The ELR pertains to light sources, which includes lamps, modules, and even some containing products (there is no energy label requirement for luminaires) and requires manufacturers to provide more information about their energy performance and functional parameters.
The Regulation requires that specific product information be provided via an energy label. The ELR also requires that the manufacturer provides information on the product’s class, along with other relevant technical information.
As the Regulation applies to the entire supply chain, there are different requirements for what information must be provided by whom. For example, suppliers (i.e., manufacturers, authorised representatives, and importers) must place an energy label on the packaging of all independently packaged light sources.
Dealers (i.e., retailers), on the other hand, must follow their own set of requirements. For instance, advertisements promoting a product have to include not only that product’s energy efficiency class, but also the range of energy efficiency classes listed on the label. Given the large number of light sources with the old label that are already at points of sale, the legislator has set the deadline for relabelling on 1 March 2023. This 18-month timeline allows retailers to sell older products with the old label until that date.
The EU Reg. 2021/340 has introduced a bit more flexibility to manufacturers of new models of light sources, offering them the opportunity to rescale the label in advance of the 1st of September, if they wish to. By consequence, these products can also be registered in EPREL with a date of placement on the market starting from the 1st of July, but the dealer shall not offer those light sources for sale before 1 September 2021.
In addition to the labels themselves, the ELR requires that all the information included on a product’s energy label and in its technical documentation also be entered into the European Product Database for Energy Labelling (EPREL) before the product can be sold on the EU market.
The Voice of the Lighting Industry
As the voice of the lighting industry, LightingEurope is dedicated to helping companies understand and apply these complex new rules. That is why we developed and published a set of detailed Guidelines on both the SLR and ELR and on the EPREL database, that are freely available to the members of our lighting associations.
To learn more about how LightingEurope can help you navigate regulatory changes and ensure you have the information you need to make informed investment decisions, visit us at www.lightingeurope.org.
