Another chapter in the discussion regarding Ecodesign. Today let us discuss luminaires. Starting from the first of march in 2014 luminaires must be accomplished by a label according to the labelling implementing measure 874/2012. What does this mean? I see many things happening at the moment and question is are things being done as required.
The IM requires that a label is being visible during sale. The end-user must be able to see the energy consumption of the product when he is deciding on the product to buy. The label must therefore be placed near the product on display or on the box. It is not required to print the label on the box. Reason is that it will be impossible in many cases to provide a label on the box in all the languages of the union. And there we have already the first issue at hand.
Several manufacturers print the label on the box, in one language and provide a translation next to it. The directive however states the format in which the label needs to be made and that is fixed. Placing translations next to the label are therefore not according to the directive. The legislator did think about the issue and therefore he made it possible not to print it on the product but it is simply required to supply the label to the retailer. The retailer is than required to display the label. This is already common practice in the whitegoods industry where the same problem occurred.
The manufacturer can still sell his product with a light source included. There are also requirements made for that. The luminaire can be marked with several energy classes, showing which energy class light sources can be used. F.E. A++ to E can be marked. The light source that can be included in the box the manufacturer is limited. He is allowed to put in a source that is in one two highest classes he marks. This means in this example that he can only supply a light source of class A++ or A+. This could be an obstacle for selling the product at low prices where you would normally see manufacturers include a low priced light source. This is now going to be more difficult (or simply change the label).
Than the light source itself can be supplied with the product without packaging. This is allowed if the label of the supplied source is included in the packaging or printed on the packaging. Just a minor detail but still a issue to consider when designing the product.
But that is not all. The requirements also state that when advertisement is made, quotes are made or a tender; in which energy related information or price information is give the information in the label must also be supplied. This will have some impact i guess. The sales systems now need to be amended with the information that is in the label and on every quote this information needs to be printed. Also when brochures are made containing these products the information must be printed as well. In this case the label itself does not need to be printed, the text must be there.
This is not only the supplier / dealer contact but also the dealer / end-user contact. So this will have impact on the it systems for many companies.
I wonder how this will look next year at the light and building. Will the information be available at all stands? Still a lot of work to do I guess.