Ecodesign of Light Sources and Separate Control Gears

End of 2019, the European Commission issued regulation 2019/2020 laying down ecodesign requirements for light sources and separate control gears. As a result, lighting devices placed in the European Union market must meet strict guidelines.

Ecodesign of Light Sources and Separate Control Gears

Regulatory Framework for the Ecodesign of Light Sources and Separate Control Gears

Regulation 2019/2020 stems from Directive 2009/125/EU establishing a framework for the setting of ecodesign requirements for energy-related products.

It encompasses the ecodesign of two types of devices:

  • light sources; and
  • separate control commands.

The EU Definition of Light Sources

First, the European Commission defines a light source as “an electrically operated product intended to emit, or, in the case of a non-incandescent light source, intended to be possibly tuned to emit, light, or both’’. It issues two criteria to characterize such technology:

  1. The light source emits a precise spectrum of colors.
  2. The light intensity is limited to a specific minimal and maximal power limit.

Nevertheless, the light source definition does not include:

  • LED dies, and chips
  • Products containing light sources removable for verification
  • Products containing one or more removable light sources for verification
  • The light-emitting parts of a non-removable light source for verification
Ecodesign of Light Sources - Lamp
LED Environmental Compliance

The European Commission’s Definition of Separate Control Gears

Ecodesign separate Control Gears

The EU Regulation 2019/2020 qualifies separate control gear as a device that ‘’is not physically integrated with a light source and is placed on the market as a separate product or as a part of a containing product.’’ It is important to note that the regulation excludes power supplies under other ecodesign requirements under regulation 2019/1782.

Ecodesign of Light Sources and Separate Control Gears in a Nutshell

First of all, several solutions framing Ecodesign in the European market are already underway. Regulation (EU) 2019/2020 on light sources and separate control gears is one of those. One should expect regular amendments as technology evolves.

To illustrate the EU ecodesign requirements for light sources, we will test a white high-output linear fluorescent light source tube of 16 mm diameter (T5-HE LFL LED). Our goal here is to demonstrate whether the device passes the regulation test. Based on this example, we will be able to obtain as many values as possible to calculate the maximum allocated power.

As a side note, laboratory testing would also be necessary to determine actual figures.

Ecodesign of fluorescent light source

1. Disassembly Requirement for the Ecodesign of Light Sources and Separate Control Gears

Disassembly Ecodesign of Light Sources

The first obligation is to ensure easy disassembly of the applicable parts. The regulation aims to allow users to repair defective parts as needed. In this regard, the European Commission encourages two concepts put forward in Ecodesign:

  1. the integration into a circular economy;
  2. extension of product life span.

In the example of T5-HE LFL LED, we must give the user clear instructions on the disassembling procedure of the LED tube. As a result, the user should be able to replace the light element of the white container when necessary.

2. Maximal Authorized Power

This second requirement is to meet a maximum authorized power. The producer can find the maximal power of the device through these factors:

I. Corrective Factor Value (C)

It is a fixed value that only depends on the type of light source. Unique characteristics can lead to an increase in the C value.

In the case of our fluorescent tube, we are in the presence of a non-directed light source. It does not require a control system. In addition, the T5-HE LFL LED connects to a power supply without intermediate control gear.

Source: Regulation 2019/2020 - Table 2

Consequently, the Corrective Factor Value of the T5-HE LFL LED is 1.

II. Loss Factor at the Ends (L) and Energy Threshold (η)

Depending on the type of light, EU regulation for ecodesign of light sources provides values for end loss factors. Please refer to the table in Appendix 2 of Regulation 2019/2020. Here are the η and L values applicable to the T5-HE LFL LED example:

Threshold efficacy and Loss Factor - 2019/2020
Source: Regulation 2019/2020 - Table 1

III. Declared Useful Luminous Flux (φ)

The declared luminous flux is a little more complex to find. Indeed, this value represents the quantity of light intensity according to a given volume. Therefore, a laboratory measurement is necessary to determine it.


IV. Efficacy Factor (F)


  • 00 for non-directed light sources (SLND, using the total luminous flux)
  • 85 for directed lights sources (DLS, using the flow in a cone)


V. Color Rendering Index (R or CRI)

The color rendering index represents the ability of a light source to realistically render the colors of the visible spectrum when it reflects on an object. Some precise calculations are necessary to have the exact figure. Fortunately, an approximation according to the type of light is possible:


Light Source Type


Industrial white fluorescent tubes


Low and High-pressure sodium lamps (except white)


Clear mercury lamps


Standard LED lamps


Several fluorescent tubes


Some metal halide lamps


White high-pressure sodium lamps


High-fidelity LED lamps


Some metal halide lamps


Incandescent sources (conventional and halogen lamps)

The Calculation of the Maximal Authorized Power

Now that we have all the factors to hold the maximum authorized power of our device!  

Then, we should compare the maximum authorized power with the actual voltage and current values of our light source or control device. A voltmeter and an ammeter enable determining these figures and calculating the power.

The device complies if this actual power is lower than Maximal Authorized Power.

3. Ecodesign of light sources: the Minimum Energy Efficiency Requirement

light sources: the Minimum Energy Efficiency Requirement

With this third ecodesign requirement, the manufacturer must demonstrate a minimum level of efficiency in the full power mode of its devices. Here is how

  1. The producer must have access to an ammeter and a voltmeter.
  2. Then, the producer measures the current and voltage at two precise points:
    • the device input; and
    • output.


With these values, the manufacturer can know its energy efficiency by making a ratio between the wattage used on the device provided. Energy efficiency is simply the amount of power used over the amount supplied.

3. The manufacturer must ensure that most energy is converted to light to pass the regulation requirements.

4. The manufacturer must ensure that the efficiency achieved is by those issued in Appendix 2 of the Regulation 2019/2020 issued by the European Commission.

4. Functional Requirements for the Ecodesign of Light Sources

Functional Requirements for the Ecodesign of Light Sources

Here, light sources must meet so-called functional requirements. These obligations encompass several factors, such as:

  • Color rendering
  • Displacement factor
  • Lumen maintenance factor (for LED and OLED)
  • Survival factor (for LED and OLED)
  • Color consistency for LED and OLED light sources
  • Flicker for LED and OLED main light source (MLS)
  • Stroboscopic effect for LED and OLED MLS

5. Communication of Ecodesign Information

First, let’s present EPREL. This European Product Registry and Energy Labelling (EPREL) is the EU organization responsible for ecodesign monitoring. Its role is to ensure a European market that respects ecological preservation.

Since September 1st, 2021, EPREL requires manufacturers to disclose detailed product information as follows:


Information on Light Sources

               Light source disclosure requirements include:

  • The luminous flux
  • The correlated color temperature
  • The on-mode power expressed in W
  • The color rendering index

Information on Separate Control Gears

               EPREL requires manufacturers to communicate to potential buyers:

  • The type of light source(s) for which it is intended
  • The efficiency in full load, expressed in percentage
  • The standby power expressed in W
  • A QR-code redirecting to a free-access website of the manufacturer
  • And other disclosures

Finally, such information should appear on the light source or the separate control gear packaging.

Ecodesign Information lighting
Energy label for light source - European Commission

Do you have any questions about the EU Regulation 2019/2020 on the ecodesign of light sources and separate control gears? Contact our Enviropass ecodesign expert!