1、 Core regulatory framework
LED lights enter the EU market, and energy efficiency compliance is jointly constrained by two core regulations:
The Ecological Design Regulation (EU) 2019/2020, also known as the Single Lighting Regulation (SLR), replaces the previous (EC) No 244/2009, (EC)
No 245/2009, and (EU) No 1194/2012, which stipulate minimum energy efficiency, functional performance, and environmental requirements from
the source of product design.
Energy Efficiency Labeling Regulation (EU) 2019/2015: specifies the energy efficiency labeling requirements for light sources, replacing the old version
(EC) No 874/2012 and adopting a new A-G grading system.
Framework Regulation (EU) 2019/2021: Provides upper level legal support for the above two regulations. This regulatory system has been in effect since
September 2021 and will remain fully implemented until 2026.
2、 Applicable product scope
The regulations cover all lighting products containing light sources, including LED bulbs, LED tubes, LED panel lights, tube lights, spotlights, fixtures
containing non replaceable light sources, and LED light strips/strips.
The following products are not within the mandatory scope: micro lamps with a luminous flux of less than 30lm, pure battery powered products
(excluding AC adapters), solar lamps, light sources in toys, LED chips and packaging, as well as special purpose light sources such as medical equipment
lights and stage lights.
3、 Key Energy Efficiency Indicators for 2026
Light efficiency threshold: The minimum light efficiency requirement for market access of general lighting LED products in 2026 is ≥ 120 lm/W
(corresponding to the new energy efficiency label D-level). Among them, directional LED light sources require a light efficiency of ≥ 120 lm/W,
non directional LED light sources require higher requirements, usually ≥ 140 lm/W, and the overall light efficiency of LED lamps needs to be ≥ 105 lm/W.
For EU projects in 2026, high-end commercial lighting typically needs to reach Class B (≥ 185 lm/W) or Class C (160-185 lm/W).
Standby power consumption: The power consumption in off mode or standby mode must be ≤ 0.5W; if the product has networking functions such as
Wi Fi/Bluetooth, the networking standby power consumption is usually ≤ 2.0W.
Strobe limitation: Short term flicker index PstLM ≤ 1.0, flicker effect visibility SVM ≤ 0.4. After 2024, this requirement has been fully enforced, and the
review efforts will be further strengthened in 2026.
Lifetime and luminous flux maintenance rate: Manufacturers must provide lifetime data of L70/B50 ≥ 6000 hours to demonstrate that the product retains
at least 70% of the initial luminous flux after the specified time. Some products require a durability test of 3600 hours.
Color rendering and color quality: The color rendering index (CRI) usually needs to be ≥ 80, and there are specific measurement requirements for R9 (high
saturation red); At the same time, there are strict testing standards for color temperature (CCT) and color consistency (MacAdam ellipse).
4、 New version of A-G energy efficiency rating
The EU will completely abolish the old A+++to D rating system from March 2021 and adopt a simplified seven level system from A (most efficient) to
G (least efficient). Due to the significant tightening of standards, many products previously labeled as A++may only be rated as D or E under the new system.
The energy efficiency classification of LED light sources in 2026 is roughly as follows: Class A requires ≥ 210 lm/W, Class B requires 185-210 lm/W, Class C
requires 160-185 lm/W, Class D requires 120-160 lm/W, Class E requires 85-120 lm/W, Class F requires 60-85 lm/W, and Class G requires<60 lm/W. D-level
products are the minimum threshold for market access, while G-level products are actually prohibited from entering the EU market.
5、 EPREL database mandatory registration
All LED products within the scope of energy efficiency labeling regulations must be registered in the European Energy Labeling Product Database (EPREL)
by suppliers before being first introduced into the EU market.
After successful registration, the system will generate a unique registration number and exclusive QR code, which must be printed on the energy efficiency
label. Consumers and market regulatory agencies can directly access the official database by scanning the code to verify product specifications and compliance
status.
Non EU manufacturers cannot register directly and must designate an EU Responsible Person as the responsible party to carry out the operation.
6、 Technical documentation and testing requirements
Enterprises need to commission third-party laboratories with ISO 17025 or CNAS/CMA qualifications to conduct comprehensive energy efficiency testing
in accordance with the latest coordinated standards. The core testing items include: turn-on mode power (Pon), luminous flux (Φ use), luminous efficiency
(lm/W), color rendering index (CRI), color temperature (CCT), power factor, displacement coefficient (cos φ 1), standby/networked standby power consumption,
PstLM and SVM flicker indicators, as well as luminous flux maintenance rate/lifespan testing, etc.
After the testing is completed, a complete technical documentation needs to be prepared, usually including: product description and model list, circuit diagram
and PCB layout, key component list (LED particles, driver power supply, etc.), test report, energy efficiency level calculation basis, declaration of conformity (DoC),
European representative information, and product manual and packaging samples. These technical documents must be kept for at least 10 years from the date
of product launch for market supervision agencies to conduct spot checks.
7、 Compliance certification process
The first step is product analysis and standard confirmation, clarifying whether the product belongs to a light source, lighting fixture, or independent control
device, and identifying the specific regulatory provisions applicable.
The second step is sample preparation and pre testing. It is recommended to conduct preliminary testing to evaluate whether key indicators such as light
efficiency and flicker meet the standards, in order to reduce the risk of formal testing failure.
The third step is formal laboratory testing, sending the sample to a qualified third-party laboratory for full testing and issuing a formal report.
Step four, prepare technical documentation (TCF) and organize a complete technical file archive based on test reports and product information.
Step five, the manufacturer signs the EC Declaration of Conformity (DoC) to confirm that the product assumes full compliance responsibility.
Step six, create an account in the EPREL system through an authorized representative of the European Union, enter the product model, technical parameters,
and upload technical documents.
Step 7: After the system review is approved, download the PDF of the energy efficiency label containing the QR code automatically generated by the system,
print and paste it on the retail packaging of the product, and upload the label image and product information table in the product information of e-commerce
platforms such as Amazon and TEMU.
The entire process can usually be completed within 7 to 15 working days with complete documentation and no need for product improvement; If rectification
is required, the cycle may be extended to about one month.
8、 Consequences of non-compliance
The registration of energy efficiency labels is a mandatory component of the CE certification system, which together with LVD safety and EMC electromagnetic
compatibility form a complete compliance framework. Products that are not registered or have false registration information will face risks such as customs
seizure, removal of e-commerce platform links, administrative penalties, and even product recalls.
Market regulatory agencies in EU member states, such as BAFA in Germany and ILT in the Netherlands, conduct regular spot checks. Enterprises that falsely
label energy efficiency, are unregistered, or falsify data can be fined up to 4% of their annual revenue, and each product model may face a penalty of 5000 to
50000 euros.
9、 Exemption situation and response
If the product falls within the scope of exemption (such as light flux<30lm, pure battery power supply, solar lamps, medical equipment special lamps, etc.), the
enterprise can apply for an exemption report as a compliance basis. When processing, it is necessary to provide product technical specifications (clearly indicating
luminous flux and power supply mode), circuit diagrams and structural diagrams, product photos (including nameplates), and instructions.
The testing agency issues a formal exemption statement based on regulatory provisions. Enterprises should clearly indicate the exemption basis on the instruction
manual or outer packaging, for example: "Exempted under (EU) 2019/2020 Art. 2 (1) (d)". When a product is misjudged by e-commerce platforms or customs as
requiring registration of energy efficiency labels, this exemption report can serve as a basis for appeal, helping to restore links or complete customs clearance.
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