Energy Labelling for Lighting Products

For customers, EU rules on lighting products are visible as an energy class and a QR code – but for companies, they are primarily about product data management that removes friction from sales and reduces market surveillance risks. The Energy Labelling Regulation (2019/2015) defines what you must communicate about a light source and how you must communicate it (energy label, product information sheet, EPREL). The key is to identify whether the product is a light source or a containing product and to ensure that the information is consistent across the packaging, the product data sheet and the online store.

Light source, control gear or containing product

Light source means an electrically operated product that emits light. Its performance and energy class are indicated by the energy label. Control gear is intended to convert mains electricity into the electrical format required by the light source. A containing product, in turn, is a product that contains one or more light sources and/or control gears and can be taken apart so that the light source can be verified separately. In practice, this distinction determines which product the energy label and EPREL registration apply to – and what information you must provide to the customer.

The Energy Labelling Regulation (2019/2015) primarily applies to light sources and, in certain cases, separate control gear. A luminaire is often a “containing product”, in which case it typically does not have its own energy label. However, the light sources used in the luminaire must still be compliant and the relevant information must be available. If the light source cannot be removed without permanent damage, the entire product may need to be assessed as a light source. This directly affects what testing and documentation are required and on what basis the product can be marketed.
If you place separate control gears on the market or sell luminaires that include control electronics, make sure you understand which requirements and declarations apply to the full product configuration. Even a minor added feature (for example, wireless control) may change what must be measured and declared.

Labelling, product information and EPREL

Under Energy Labelling Regulation 2019/2015, the most important thing is to ensure that the correct energy class and correctly presented product information appear in all channels: packaging, product cards, online stores, brochures and quotation attachments. When the energy label and product information sheet are in order and the product model is listed in EPREL, it is easy for customers to compare options – and easy for you to respond quickly to customer information requests.

Who is responsible – and for what?

Manufacturer is responsible for ensuring that the energy labelling information (class, consumption and other parameters) is correct. The manufacturer is responsible for EPREL registration, producing the energy label and product information sheet, and compiling the technical documentation. The manufacturer is also responsible for ensuring that the data provided to the supply chain (label, product information sheet and marketing elements) is up to date and consistent with the actual product.

When a light source comes from outside the EU, the importer is often the operator who, in practice, ensures that it can be legally sold in the EU. The importer ensures that the product model is listed in EPREL, that the energy label is correct, and that the minimum requirements are met. If these are not in place, the risks include sales interruption, product returns or corrective revisions to campaign materials. The importer’s role is also to ensure traceability and document availability for market surveillance purposes.

Dealer is responsible for ensuring that the energy label and product information sheet are displayed correctly in sales channels. The dealer must not present contradictory or misleading energy efficiency information. The dealer must also cooperate with the authorities and respond to identified non-conformities.

Practical checklist: how to make your product market-ready (and keep it that way)

Energy Labelling Regulation (EU) 2019/2015 is not just mandatory paperwork. When measurement data, calculations, EPREL and sales-channel content are built into one consistent process, compliance becomes a competitive advantage: products reach the market faster, customers get clear information, and the supply chain avoids costly correction cycles. If you want to minimise risk, focus on the following:

1. Start with the classification: is it a light source or a containing product? This decision determines the compliance pathway.
2. Measurement results and calculations: collect the data needed to substantiate the energy class.
3. EPREL before listings: make sure the model is registered and that the QR code/product information is correct before the product is published in sales channels.
4. Use the same data in all channels: the same energy class and the same values on the packaging, in the product information sheet, in the online store and in campaigns.
5. Agree on roles and responsibilities: who maintains EPREL data, who provides labelling materials and who is responsible for test reports.
6. Keep an “audit pack” ready: compiled technical documentation saves time when a customer or authority requests verification.

How can SGS help?

SGS Fimko has decades of experience in the testing and certification of luminaires. We can verify that retail packaging meets the labelling requirements of the Regulation and that the contents of the technical documentation comply with the Regulation. We can determine the energy efficiency class of a luminaire or light source through accredited testing.

We can also perform the following photometric measurements:

• CRI measurement
• Colour consistency
• Beam angle
• Correlated colour temperature (K)
• Peak luminous intensity

Contact us and we will help you ensure that your light source, luminaire or containing product is compliant and suitable for the market.