More and more fluorescent tubes are being replaced by LED tubes. There are many different opinions on yes or no for these kind of products. In this blog I would like to address the issue coming from the ErP directive. This directive has some distinct requirements for these kind of products.
Under which implementing measure do these products fall. That is one you have to check. These products are generally constructed in a way that they might be considered directional but they also can be constructed as non-directional. In both cases the DIM II applies being the IM for directional lamps. Strange as it may sound but this IM is also containing correction especially for LED products that where not covered in DIM I.
First thing to be assured of is if this product is sold by more than 200 per year. If less are sold this IM is not applicable. Most of these products are intended to be sold in much higher numbers so generally they will have to comply.
Annex III states the requirements. For these kind of tubes special requirements are set with regard to marketing of these products. Clause 3.2 starts with the sentence that this clause is applicable to those tubes that replace fluorescent tubes without integrated ballasts. So basically the linear fluorescent tubes are meant here. The compact fluorescent that are in most cases supplied with an integrated ballast are not meant here.
Basically a claim that the tube replaces the original fluorescent tube may only be made if:
– the LED tube emits light in all directions with a maximum difference of 25% of the average around the tube.
– the total light emitted from the LED tube must be at least the same as the light emitted from the fluorescent tube it intends to replace.
– the wattage of the lamp may not be higher than the wattage of the lamp it replaces.
So these are quiet some strong requirements. The first one might one of the most difficult ones. Generally LED tubes are emitting the light in one direction (up to 180 deg). The construction, tube with integrated ballast, is almost requiring this construction.
The second and third point seem to be somewhat logical but in the real world this is also in many cases not the case. Yes the power is generally less but in many cases also the light output is less. Is this a problem? No not always. The light is more effectively coming out of the luminaire and is many cases that is already ok. The directive however sets different requirements.
So what to do. There are different ways to tackle the issue. First it is possible to construct a tube that complies with these requirements. Than there will be no discussion on selling the product as a replacement tube however you also need to comply with the technical requirements and that does mean that a design is needed to handle the heat in a proper way and that might be a challenge. The other way is not to market as fluorescent tube replacement.
When does this requirement come into effect? That is already in stage 1 and stage one has already started on the first of September 2013. So products must already comply with this requirement.