Ecodesign Directive 2021

Introduction / General Information

The General Ecodesign Directive 2009/125/EC is a Europe-wide directive that defines the requirements for the environmentally friendly design of energy-related products within the European Union. It will be replaced by Commission Regulation (EU) 2019/2020 from October 1, 2019, establishing ecodesign requirements for light sources and separate control gear. The new regulation will apply from September 1, 2021.

The new Commission Regulation (EU) 2019/2015, which deals with the labelling of light sources, will also come into force on September 1, 2021.

The chart shows the development of the Ecodesign Directive and Regulation on Labelling of Light Sources since the first implementation in 2009/2010.

Ecodesign Regulation EU 2019/2020

The new EU 2019/2020 Ecodesign Regulation (Single Lighting Regulation – SLR for short) sets EU-wide rules to improve product performance, including lighting. It applies to light sources and separate control gear, as mentioned above.

The SLR defines a light source as “an electrically operated product intended to emit light, using incandescent, fluorescent, high pressure discharge, inorganic light emitting diode (LED) or organic light emitting diode (OLED), or combinations thereof as lighting technology”. A containing product, on the other hand, is defined as a product that contains one or more light source(s) or separate control gear, or both. Examples of containing products are luminaires that can be taken apart to allow separate inspection of the contained light source(s); e.g. household appliances that contain light source(s) and furniture (shelves, mirrors, display cases) that contain light source(s). As you can see, the definitions of terms are very complex and there are many exceptions and specificities. For detailed advice, please feel free to contact our experts at

As the SLR sets minimum energy efficiency requirements, any product that does not meet these requirements will be phased out, starting with products such as compact fluorescent lamps in 2021 and followed by products such as T8 fluorescent lamps in 2023. When this process is complete, these light sources will need to be replaced with new energy-efficient light sources and the lighting systems will need to be renewed.

The new directive also emphasises the idea of sustainability and the recyclability of products. Thus, manufacturersimporters and authorised representatives of surrounding products must ensure that light sources and separate ballasts can be easily replaced with commercially available tools without permanent damage to the containing product. In addition, they shall provide instructions on how to “remove” a light source, explained by means of drawings, text, pictures, etc. If the technical documentation provides a technical justification in relation to the function of the surrounding product showing why the removal of light sources and separate ballasts for inspection is not appropriate, then the whole (surrounding) product shall meet all performance/information requirements.

Regulation EU 2019/2020 also requires that manufacturers, importers and authorised representatives of surrounding products provide information on the interchangeability or non-interchangeability of light sources and ballasts by end-users or qualified persons. This information shall be provided both on the packaging and in the operating instructions, typically in the form of a pictogram. However, these symbols shall not be used when containing products that represent a light source (e.g. luminaires).

To sum up the new directive (SLR):

All containg products shall have replaceable light sources and control gear (unless there is a technical explanation that this is not the case).
If the light source and control gear of the containing product cannot be removed for verification, the containing product shall be considered as the light source for all requirements of the Regulation (energy performance requirements, information requirements, etc.) and the corresponding energy labelling requirements. Information on the interchangeability or non-interchangeability of the light source and ballast shall be provided on the packaging of the containing product (only for products sold directly to end-users).

Commission Regulation (EU) 2019/2015

Regulation (EU) 2019/2015 (Energy Labelling Regulation: ELR for short) covers light sources, which include lamps, modules and even some products (there is no energy label requirement for luminaires), and demands that manufacturers provide more information about their energy performance and functional parameters.

One of the main objectives of the new regulation is to provide the customer/end-user with the necessary information to choose energy efficient products. Therefore, the regulation primarily requires specific product information to be provided via a consumer-friendly energy label. Manufacturers must also provide information on the class of the product and other relevant technical information.

As the regulation applies to the entire supply chain, there are different requirements as to what information must be provided and 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. In addition, the supplier must provide a printed version of the product information sheet upon request from a distributor (the information must always be available electronically).

Distributors (i.e. retailers), on the other hand, must follow their own requirements. For example, the energy label must be visibly displayed on the packaging of a light source, and in the case of distance selling, the label and product information sheet must also be made available. Advertising for a product must not only state the energy efficiency class of the product, but also the range of energy efficiency classes listed on the label.

The regulation also contains specific obligations for online traders and hosting platforms. For example, online traders must display the energy label and the product information sheet on the website where the product is offered.

By specifying the size that an energy label must have (72 x 36 mm or 54 x 20 mm), the regulation also defines the minimum size that a package may have (i.e. not smaller than 54 x 20 mm). All labels created on the basis of the old regulation must be replaced by new labels before March 1, 2023. If you intend to cover an old label with a new label, you must ensure that the new label completely covers the old label. (Note: Energy labels are no longer required for luminaire packaging).

In addition to the labels themselves, the Regulation requires that all information contained on a product’s energy label and in its technical documentation is also entered into the European Product Database for Energy Labelling (EPREL). Like the label and documentation itself, entering the required data into EPREL is a prerequisite for selling a product on the European market. Already since January 1, 2019, the registration of lamps in EPREL 1.0 and the provision of product information is mandatory. The requirement for an energy label on luminaires was withdrawn as of December 25, 2019.

Although the details are not yet clear, EPREL 2.0 will also be mandatory for light sources and products that are considered to be a light source from September 1, 2021.

Why are the new regulations necessary?

The reason for these reforms is the considerable energy savings to be achieved, which according to estimates could amount to more than 260 TWh per year in 2030. This would correspond to a reduction in greenhouse gas emissions of around 100 million tonnes per year. Energy consumption from lighting could also be reduced by up to 41.9 TWh per year by 2030. In comparison, the annual electricity consumption of products within the scope of this regulation in the European Union in 2015 was about 334 TWh, which is 12.4% of the total electricity consumption of all 28 member states and the equivalent of 132 million tonnes of CO2.

The mandatory Ecodesign requirements apply to products placed on the market in the European Union irrespective of their place of installation and use and should therefore not depend on the application in which they are used.

The enactment of this regulation was necessary in order to comply with the new scaling scheme (return to the rating from A to G). The deadline for the new energy efficiency labels for light sources is March 1, 2021 – Light sources include the following items:

  • Lamps (light bulbs)
  • LEDs and LED modules
  • Luminaires for which the light source cannot be removed