Lately we had some interesting discussions on labels on LED luminaires. It seems strange but the labelling directive does not really encourage manufacturers to use the best LED possible. Why not? So what is going on.
The labelling directive does give requirements for labelling luminaires. It is clear and understandable that you have to mark luminaires with the type of lamps that can be used. For example a luminaire could be marked suitable for lamps A++ to E. So here no issue.
The problem starts when the luminaire is specifically for LED. In that case there there are two possibilities. First is that the luminaire has integrated LED modules. Which by the way does not necessarily mean that they are not replaceable to make it more complicated. Anyway the other option is replaceable LED modules.
In case op replaceable LED modules you have the situation that you need to mark the luminaire and have to provide a separate label for the light source. The label for the light source indicates the energy class exactly and the label for the luminaire will indicate the range in which the light source needs to be.
In case of luminaires with non replaceable LED modules. So what is that exactly? What is non replaceable?
The directive states that modules that are not intended to be replaced by end users are excluded for labeling. This means that the module does not have to be labelled. However if the module is sold as spare part it needs to be labelled. But when is a LED module non-replaceable. In the end every part can be replaced however difficult that may be.
There we might have a part of the solution to the question. A modules can be considered replaceable if it is easily possible for the end-user to replace the module and if it is encouraged to do so. Lets take a closer look at that.
Looking at conventional light sources they are in general (few minor exceptions) replaceable with using a tool. It might be so that you need to open a cover with a screwdriver but the light source can be taken out with the use of a tool. In LED technologie that is not often the case. There are some specific modules where you can argue that a end user could be considered to be able to replace the module, i would consider the twistable modules from Zhaga as a candidate for that.
So replaceable means with a kind of cap? Or would wires also be considered. In my opinion modules that have a connector that is plugged in can be considered easily replaceable as well. Sure there are grey area’s as well but the principle should be “easily” and “end-user”. Those are key. The definition of a lamp leaves that possibility open as well.
So this would mean that non-replaceable would be a module that is screwed into the luminaire. The method of connection to the supply is not a real criterium.
So in the case where the module is non-replaceable you need to mark the luminaire with the label and this label is defined in the regulation. But it requires to mark the luminaire with a label showing A++ to A lamps. The strange thing however is that the requirements allow the lamps to be EEI index 0,50 which means directly that when you have a LED lamp with a EEI between 0,4 and 0,5 you have a light source that normally would have to be labelled B.
So in the case of non-replaceable LED modules you can have a luminaire that is marked A++ to A while the actual index would be B.
Lets take a look at the verification method that must be used by the authorities. Annex V gives the requirements. If you look at the procedure for luminaires it says that a luminaire is considered to comply with clause 3 and for if, among others, the luminaire is compatible with the lamps claimed according to 2.2(IV)(a)(b). This part is about replaceable lamps and not integrated LED. C is about integrated LED but that one is not assessed.
In the end it is to be expected that all LED lamps will go into the A class or better and than the issue will be solved but currently the issue is debatable.