The Ecodesign and Energy labelling regulation entered the last phase of the revision last week. Simultaneously the new obligation to register in the Energy labelling database (EPREL) will enter into force on January 1st, 2019. Which consequences will this have for lighting products?
Currently there are two ongoing developments within Ecodesign and Energy labelling: the periodical revision of the Ecodesign & Energy labelling regulation and the development of a new Energy labelling database (EPREL). Both products have sustained delays of several months, which can cause unclarity on the correct interpretation of the regulation. Below an overview of the main discussion points of the moment.
Introduction of a new obligation to register
The EPREL-database is a new obligation from January 1st 2019 onwards regarding all products that are subject to energy labelling regulation. The obligation entails an upload of energy labelling data and technical documentation per product type by manufacturers and suppliers. Upon the launch of the final database on December 14th 2018 is will be possible to start with the upload of technical data and documentation of the models that are placed on the market from January 1st 2019. Units that are placed on the market between the 1st of August 2017 and the 1St of January 2019 will have to be added to the database by June 30th 2019. To prepare it is strongly advised to already start testing in the currently available EPREL testing environment. This environment is not secure; it is therefore also strongly advised not to test with 'real data'.
A manual for testing the registration procedures can be found in this article.
Change in the Ecodesign and Energy labelling scope
Which products are subject to the EPREL obligation to register is dependent on the way the scope is defined in the regulation. Currently the Energy labelling regulation EU 874/2012 is in force for lighting products. Simultaneously there are revisions ongoing of the Ecodesign and Energy labelling regulation for lighting products. The proposals that are currently on the table within these revision processes propose a merge of the now separate regulations for domestic non-directional, domestic directional and street lighting to one new definition for 'light sources', independent of whether the product is a lamp or a luminaire. Within the definition luminaires are generally only considered a 'light source' in case the 'light source' cannot be removed from the luminaire. Especially in case of the Energy labelling regulation this has important consequences for the obligation to register in EPREL. It means that at the moment the new regulation applies, part of the luminaires will no longer have to be registered.
More information on the current Ecodesign and Energy labelling developments can be found in this article.
Luminaires in or out of the EPREL database
Normally both lamps and luminaires would have to be registered in the EPREL database from January 1st 2019 as a consequence of the current Energy labelling regulation. A large number of luminaires could then be taken out of the EPREL database as soon as the new regulation applies. To prevent unnecessary work the European Commission has decided to not make the option to register luminaires available in the EPREL database. Concretely this means that from January 1st 2019 only lamps that are placed on the market and fall within the scope of the Energy labelling regulation (874/2012) will need to be registered in the final EPREL database. Additionally the lamps that have been placed on the market between August 1st 2017 and January 1st 2019 will need to be added to the database by June 30th 2019.
Once the new regulation enters into force, 'light sources' will have to be registered in the EPREL database. Depending on the exact final wording in the approved regulation this will probably mean that next lamps also luminaires from which a 'light source' cannot be removed will be subject to the obligation to register in EPREL. From which date this obligation will enter into force, depends on the way it will be described in the new regulation upon official publication. With the closing of the public consultation this week the revision has now entered the final phase. This means that prior to publication the Member States will discuss the proposals for both Ecodesign and Energy labelling and vote on their approval. Agoria has the possibility to provide consultation to the federal government on this matter based on concrete proposals for adjustments.
More information on the obligations for lighting and EPREL can be found in this article.
'Entry into force' date for the new regulation
Another discussion points within the Ecodesign and Energy labelling revisions is the date on which the new regulation will enter into force. This date is partly determined by the time that is needed for companies to take the necessary preparations to meet the requirements.
In the proposals of November 2017 the date was defined as 1st of September 2020 for the Ecodesign requirements. For the Energy labelling regulation there was no date specified yet in this proposal. Because of the sustained delays in the revision process during the months that followed, the following new data were proposed:
- In the current proposal for Ecodesign the date was changed to September 1st, 2021
- In the current proposal for Energy labelling September 1st 2021 is included as the entry into force date with May 1st 2021 as the deadline for the obligation to register in EPREL and June 1st 2022 as the deadline for rescaling of the energy label.
The industry has however indicated that these new dates are quite short notice. It is therefore expected that the entry into force date will be an important point of discussion during the last phase of the revision proces. You can find the current versions of the proposals via de links to the public consultations in this article.
Volume of required information to register in EPREL
The final point on which there is still a lot of discussion is the required information that should be included in the EPREL database according to the Energy labelling regulation. In the most recent proposal of October 2018 it concerns parameters that are specified for the product sheet. There are about 30 ranging from the applied light technology to the 'lumen maintenance factor' to instructions on how 'non-lighting' of 'control parts' of a 'light source' can be removed. The industry has indicated that currently the number of parameters on which data is required is too high and is questioning the usefulness of a number of parameters.
The Ecodesign and Energy labelling proposals have entered the last phase of the revision proces last week. In this phase Member States will discuss the proposals and cast their votes. The discussions of the Member States will take place in the second half of December. Agoria has the possibility to provide consultation to the Member States on the proposals provided that it concerns concrete proposals for adjustments.
In the text above you were able to read what the main discussion points are.
Do you have any concrete feedback or concrete text proposals? Please pass this on to Charlotte van de Water before December 1st (firstname.lastname@example.org).