EU Energy Label for Light Sources: What Delegated Regulation 2019/2015 Says About Classes A to G, the Packaging Label and the Product Database

Commission Delegated Regulation (EU) 2019/2015 is the energy-labelling rule for light sources in the EU. It has applied since 1 September 2021, repeals Delegated Regulation (EU) No 874/2012 (Article 9), and uses a plain A to G scale (Annex III). For a project buyer who orders lamps, luminaires or furniture with built-in lighting from China for an EU job, it answers three practical questions: what energy class the light source must carry, what has to be printed on the packaging, and what has to be entered in the EU product database before the model is sold.

This article reads the consolidated text dated 30 September 2023 (EUR-Lex), which lists two amendments, Delegated Regulations (EU) 2021/340 and (EU) 2023/2048, and a query of the Publications Office’s linked-data service on 27 October 2026 returned no later amending act. It also uses the European Commission’s Energy Efficient Products portal (energy-efficient-products.ec.europa.eu), read on the same day. We did not read the parent Regulation (EU) 2017/1369, the verification procedure in Annex IX, the review that Article 8 required by 25 December 2024, or national market-surveillance practice. It is a reading of the text, not legal advice. Its companion, the ecodesign rule for the same products, is in our reading of Regulation 2019/2020.

What the Regulation covers, and what it leaves out

Article 1(1) says the Regulation “establishes requirements for the labelling of, and the provision of supplementary product information on, light sources with or without integrated control gear”, and that the requirements “also apply to light sources placed on the market in a containing product”. Article 2(3) defines a containing product to include “furniture (shelves, mirrors, display cabinets) containing light source(s)”, along with luminaires that can be taken apart for separate verification and household appliances with light sources.

The definition of a light source in Article 2(1) is the same optical test used in the ecodesign Regulation: chromaticity coordinates within a stated range, a luminous flux below 500 lumen per mm² of projected light-emitting surface, a flux between 60 and 82,000 lumen and a colour rendering index above 0, using incandescence, fluorescence, high-intensity discharge, LED or OLED. LED dies, chips and packages are not light sources, and neither are products from which the light sources can be removed for verification.

Annex IV lists what falls outside. Point 1 exempts light sources “specifically tested and approved” to operate in listed settings: radiological and nuclear medicine installations, emergency use, military and civil defence, motor vehicles and trailers, non-road mobile machinery, interchangeable towed equipment, civil aircraft, railway vehicles, marine equipment, and medical devices. The text defines the phrase through three conditions: the source has been specifically tested for that operating condition; it is accompanied by evidence in the technical documentation “in the form of a certificate, a type approval mark, a test report”; and it is placed on the market specifically for that condition, as the technical documentation, the packaging and any advertising show. Point 2 also excludes electronic displays, light sources in range hoods within the scope of another Regulation, light sources in battery-operated products (torches, battery-only desk lamps, solar-powered garden lamps among the examples) and light sources on bicycles and other non-motorised vehicles.

Point 3 exempts sources “specifically designed and marketed for its intended use” in applications such as signalling, image capture and projection, germicidal use, disinfection, sun-tanning, horticulture and certain industrial electro-heating equipment. Such a source still has to meet Annex V point 4: its intended use is stated on all forms of packaging, product information and advertisement, together with “a clear indication that the light source is not intended for use in other applications”.

How the energy class is calculated

Annex II sets the class from the total mains efficacy, “calculated by dividing the declared useful luminous flux Φuse (expressed in lm) by the declared on-mode power consumption Pon (expressed in W) and multiplying by the applicable factor FTM of Table 2”. The factor depends on whether the source is directional or non-directional and whether it runs on mains voltage:

Table 1 then turns the result into a class:

Because the inputs are declared values, the same lamp can move between classes if the declared flux or power changes. Four illustrative calculations, with invented inputs that are not any product: a non-directional mains source of 800 lm and 8 W gives 100 lm/W and class F; the same flux at 5 W gives 160 lm/W and class C; a directional mains source of 400 lm and 4 W gives 100 × 1.176 = 117.6 lm/W and class E; a non-directional source not on mains of 600 lm and 5 W gives 120 × 0.926 = 111.12 lm/W and class E. Article 6 requires the declared values to come from “reliable, accurate and reproducible measurement and calculation methods”.

The label on the packaging

Article 3(1)(a) requires a label printed on the packaging of a light source that is placed on the market on its own, outside a containing product, and sold in packaging. Annex III sets the content: the supplier’s name or trade mark; the supplier’s model identifier; the scale of classes from A to G; the energy consumption in kWh per 1,000 hours in on-mode; a QR code; the class itself; and the number of the Regulation, “2019/2015”. The standard-sized label is “at least 36 mm wide and 72 mm high”, and the small-sized label is “at least 20 mm wide and 54 mm high”. The text adds: “The small-sized label shall not be used on packaging with a width of 36 mm or more.”

If the label is not printed on the side of the packaging that faces the customer, Annex III requires an arrow showing the class letter, in the matching colour, on that side. Article 3(1a) deals with the move from the old scale: from 1 September 2021 a supplier provides a light source with the rescaled label. Annex III also sets the typefaces, the CMYK colours of the A to G arrows and a 0.5 pt black border; a printer working from a packaging brief needs the Annex itself.

The product database: what is entered, and when

Two entries are required. Article 3(1)(b) says “the values of the parameters included in the product information sheet, as set out in Annex V, are entered into the public part of the product database”, and Article 3(1)(d) says “the content of the technical documentation, as set out in Annex VI, is entered into the product database”. Under Article 10, point 1(b) of Article 3 applies from 1 May 2021, before the rest of the Regulation applies on 1 September 2021. Annex V adds two rules: the information sheet is entered “including when the light source is a part in a containing product”, and when a model is no longer sold, “the supplier shall put in the product database the date (month, year) when the placing on the EU market stopped.”

The Regulation calls the database “the product database” and does not use the acronym EPREL, because the database is established by the parent Regulation, which we did not read. The Commission’s portal gives the name and the rule in its own words: “Suppliers are manufacturers established in the European Union, importers or authorised representatives of manufacturers not established in the Union, who place products on the Union market. Before energy-related products covered by energy labelling are placed on the EU market, the models must be registered by their supplier in the product database EPREL.” For a project buyer, the consequence is that a model’s registration is something its supplier does before sale, and the importer or authorised representative can be that supplier.

Annex V Table 3 lists the information sheet fields, among them the supplier’s name or trade mark and address, the model identifier, the type of light source, directional or non-directional, mains or non-mains, connected or not, dimmable or not, the energy consumption in on-mode, the class, the useful luminous flux with its sphere, wide cone or narrow cone basis, the correlated colour temperature, on-mode, standby and networked standby power, the colour rendering index, the outer dimensions and, for LED and OLED sources, the R9 value, survival factor and lumen maintenance factor. For LED and OLED mains sources the fields also include displacement factor, colour consistency, the flicker metric and the stroboscopic effect metric.

Annex VI lists what the technical documentation holds. It includes the supplier’s name and address, the model identifier, “the model identifier of all equivalent models already placed on the market”, “identification and signature of the person empowered to bind the supplier”, the declared values for the technical parameters, including “indicative lifetime L70B50 for LED and OLED light sources”, the calculations that led to the class, “references to the harmonised standards applied or other standards used”, and any precautions for assembly, installation, maintenance or testing. Annex VI(2) says these elements also form the mandatory specific parts of the technical documentation the supplier enters into the database. For what stands behind an L70 figure, see our explainer on LM-80, TM-21 and L70.

Light sources inside furniture and luminaires

For a light source placed on the market as part of a containing product, the Regulation does not require a packaging label on the source, but it does require paper and database information. Article 3(2) says suppliers of containing products shall “provide information on the contained light source(s), as specified in point 2 of Annex V” and, “upon request by market surveillance authorities, provide information on how light sources can be removed for verification without permanent damage to the light source”. Annex V point 2 then requires that “the technical documentation for the containing product shall clearly identify the contained light source(s), including the energy efficiency class”, and that the user manual or booklet of instructions display the sentence “This product contains a light source of energy efficiency class” followed by the class letter. Article 3(2)(a) applies from 1 March 2022.

For adverts and online sales, Article 3(1)(e) and (f) and Annexes VII and VIII require the class and the range of classes to appear in visual advertisements and technical promotional material for a specific model, and, in internet sales, the label to be shown “on the display mechanism in proximity to the price of the product”. These duties fall on the supplier and, under Article 4, on the dealer.

What to ask a lighting factory to put in writing

Each request below follows from a provision above. The list is not a document list prescribed by the Regulation.

• The declared useful luminous flux, on-mode power, directional or non-directional status and mains or non-mains status that the class calculation used, with the resulting class. (Annex II)
• The model identifier, and confirmation of whether the model is entered in the product database and by which entity, since the entry is the supplier’s duty. (Article 3(1)(b), (d))
• The Annex V Table 3 values and the Annex VI technical documentation list, including the equivalent models and the standards referenced. (Annexes V and VI)
• For lighting built into furniture or a luminaire: the contained light source’s class, the sentence for the user manual, and instructions for removing the source for verification. (Article 3(2), Annex V point 2)
• The label artwork on the packaging in the correct size, with the QR code and the number “2019/2015”, for a source sold on its own. (Annex III)
• For any claimed exemption: the certificate, type approval mark or test report and proof that the product is marketed specifically for that use; for a signalling, projection or similar product, the stated intended use on the packaging. (Annex IV, Annex V point 4)

For other EU rules that apply to the same lighting product, see our readings of the Low Voltage Directive and the Construction Products Regulation.

Frequently asked questions about Regulation 2019/2015

What does Delegated Regulation 2019/2015 require?

It requires an A to G energy label on the packaging of light sources sold on their own, entry of the product information sheet and technical documentation in the EU product database, supplementary information for light sources inside containing products, and the energy class in adverts and distance selling. It has applied since 1 September 2021.

How is the energy class of a light source calculated?

Annex II divides the declared useful luminous flux by the declared on-mode power and multiplies the result by a factor from Table 2, which ranges from 0.926 to 1.176 depending on whether the source is directional and runs on mains. Table 1 sets class A at 210 lm/W or more and class G below 85 lm/W.

Does the Regulation apply to light sources built into furniture?

Yes. Article 1(1) applies the requirements to light sources placed on the market in a containing product, and Article 2(3) names furniture such as shelves, mirrors and display cabinets. Article 3(2) requires the containing product’s documentation to identify the light source and its class, and the user manual to carry the standard sentence.

Who registers a model in the product database?

Article 3(1) places the entries on the supplier. The European Commission’s portal describes suppliers as manufacturers established in the EU, importers or authorised representatives of manufacturers not established in the Union who place products on the EU market, and says models must be registered before placing on the market.

Which light sources are outside the Regulation?

Annex IV excludes sources specifically tested and approved for settings such as emergency use, motor vehicles and medical devices, electronic displays and light sources in battery-operated products, and, apart from Annex V point 4, sources designed and marketed for uses such as signalling, projection, germicidal use and horticulture.

How does FBM Sourcing support this kind of project?

We review the brief, collect comparable quotations and manage the package for the project. For suppliers you nominate, we charge a 5% commission; for products we source for you, we quote a direct price. Our own team performs one inspection after bulk production is complete and before shipment, and the client’s project team is welcome to attend.

FBM Sourcing manages the entire China procurement package for overseas construction projects. We work with Developers · General Contractors · Builders · Commercial Project Owners · Interior Design & Construction Companies · FF&E Solution Providers.