Enviropass Logo

Ecodesign of Light Sources and Separate Control Gears

Effective 2019, the European Commission has 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 environmental 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 eco-design of two types of devices:

  • light sources; and
  • separate control gears like limiters or transformers.

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 chips and dies
  • Products containing one or more light sources that can be removed for verification
  • Any light-emitting parts of a light source that cannot be removed 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 other parts of a light source that may or may not be integrated into the final product. An example is external power supplies, which fall under their own ecodesign requirements (Regulation 2019/1782) regardless of the load.

This simple exception underlines why it is so important to understand our global markets. Several solutions framing ecodesign in the European market are already underway in accordance with Directive 2009/125. Regulation 2019/2020 is only one of these, and suppliers should expect regular amendments as technology evolves.

Ecodesign of Light Sources and Separate Control Gears: A Case Study

To illustrate the EU ecodesign requirements for light sources, we will consider a white high-output linear fluorescent light source tube of 16 mm diameter (T5-HE LFL LED). Our goal is to demonstrate whether such a device meets the requirements laid out in the regulation.

Using this example, we would begin by obtaining many different parameters so that we can calculate the light source’s maximum allocated power. In practice, laboratory testing will be necessary to determine actual figures.

In practice, laboratory testing will be necessary to determine actual figures.

Ecodesign of fluorescent light source

Step 1: Provide Clear Disassembly Requirements

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


In the example of T5-HE LFL LED, suppliers 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-emitting elements within the housing if necessary.

Step 2: Determine Maximal Authorized Power

The second requirement is to ensure the product does not exceed a maximum authorized power. Producers can find the maximal power of the device by determining these factors:

I. Corrective Factor Value (C)

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

In the case of the T5-HE LFL LED, it is a non-directed light source that does not require a control system, and it connects to a power supply without intermediate control gear. The associated C value is 1.00.

Corrective Factor Value
Source: Regulation (EU) 2019/2020 - Annex II, Table 2

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

Like the Corrective Factor Value, (EU) 2019/2020 provides values for end loss factors and threshold efficacies across different types of light sources. For example, the η and L values applicable to our T5-HE LFL LED are:

Threshold efficacy and Loss Factor - 2019/2020
Source: (EU) Regulation 2019/2020 - Annex II Table 1

III. Declared Useful Luminous Flux (φ)

The declared luminous flux is more complex to find, and relates directly to the construction of the light source and how its flux is directed. This value states a range in the quantity of emitted light intensity according to a given volume, and an appropriate laboratory measurement is necessary to determine it.

IV. Efficacy Factor (F)

The efficacy factor of a light source is a simple coefficient that is assigned based on the directionality of the light source:

  • F = 1.00 for non-directional light sources (NDLS, using total luminous flux)
  • F = 0.85 for directional light sources (DLS, using the flux in a cone whose vertex is located at the light source)

V. Color Rendering Index (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, although an approximation according to the type of light is also 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)

Successfully calculating the CRI allows us to find R, the CRI factor. Now we have all the factors we need to calculate the maximum authorized power of our device!

Maximal Power - Eco-design of light source
Source: (EU) 2019/2020 Annex II Sec. 1

We should compare our theoretical maximum authorized power with the actual voltage and current values of our light source or control device, using a voltmeter and ammeter to calculate the actual power consumed.

If the actual power is lower than Maximal Authorized Power, the device complies with regulations.

Step 3: Ecodesign of light sources: theMeet 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:

  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 the 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 Annex 2 of Regulation 2019/2020 issued by the European Commission.

Step 4: Demonstrate Mandatory 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

Step 5: Ensure Proper 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, all such information should appear on the light source or separate control gear packaging. In fact, the standards for energy labeling of light sources are distinct from ecodesign standards and comprise a separate document. Regulation (EU) 2019/2015 lays down these labeling guidelines for light sources, describing which important parameters need to be shared with consumers and retailers. The label shown here is a standard design put forth by the European Commission; it is only one example of labeling requirements that must be considered during a product’s life cycle.

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 eco-design expert!