ErP (EU) 2019/2020 for Light Sources: What Suppliers Must Register

One regulation, two regimes

Regulation (EU) 2019/2020 — the "single lighting regulation" or SLR, the ecodesign chapter of what buyers casually call ErP — applies to light sources and separate control gears placed on the EU market, in force since 1 September 2021, replacing the older ecodesign rules for lamps. It is one of two regimes that govern EU lighting paperwork. The second is the energy labelling regime (the rescaled A-G label under Regulation (EU) 2019/2021) and its EPREL registration database. The distinction trips up suppliers constantly: ecodesign (2019/2020) sets the performance floor a product must meet; labelling (2019/2021 plus EPREL) sets the information product that must exist before the product is offered for sale. A light source can pass every performance test and still be illegal on the EU market if its EPREL registration is missing.

Scope notes that save arguments: luminaires as housings are not light sources and generally do not carry their own EPREL registrations, but the replaceable light sources and separate control gears inside them do fall under the regulation's requirements when placed on the market. AURELUX labels ErP/EPREL status per product on EU-bound programs — conformity here is organized through certified partner factories, verified per order.

The requirements that actually decide market access

The regulation's Annex II sets the performance floor. In buyer's terms, the tests that matter most:

Figures above summarize the regulation's structure for buyer use; exact constants live in the Annex tables and are updated by amending regulations — verify against the current text at design time.

On the phase-out side, the SLR plus related acts ended most mercury-containing fluorescent exemptions on a dated schedule — the practical reality is that fluorescent replacements for EU channels are a closing door, and LED retrofit lines are the only durable answer. Verify current exemption dates rather than relying on older summaries.

EPREL registration: the part most often missed

Every light source within labelling scope must be registered in EPREL — the European Product Registry for Energy Labelling — before it is placed on the EU market, with the label and product information sheet generated from the registration. Registration is the duty of the supplier: the EU-based manufacturer, the importer who places a non-EU product on the market, or the authorised representative acting for one. This is the practical answer to the question every non-EU supplier faces: a Chinese factory cannot simply self-register; the registration duty lands on its EU importer or appointed responsible entity — which is why serious export programs define that role contractually before the first shipment. The registration carries the model's measured data: flux, on-mode power, efficacy, CRI, CCT, flicker and stroboscopic metrics, lifetime claims — the same numbers the test reports hold, which is one more reason the test program should be designed once, correctly, for both regimes.

What buyers should receive in the document pack

• Test reports covering the Annex II metrics — efficacy, CRI, PstLM, SVM, survival and lumen maintenance — naming the exact model and standard versions.
• EPREL registration evidence: the registration number or a database extract for the model, not a promise that "registration is in progress".
• The energy label and product information sheet as generated from EPREL, in the languages the sales channel requires.
• Consistency across report, registration, label and carton — same model, same ratings, same numbers.
• Status labeling per product: which SKUs are light sources in scope versus luminaires or gears, because the duties differ.

The safety-and-substances half of EU compliance (LVD, EMC, RoHS) is covered separately in our CE guide; the destination map sits on the certifications page. For product-side implications — which commercial lines this pressure reaches first — see the commercial lighting catalog.

Building the test program once, correctly

The efficient way through the SLR is to design the laboratory program for both regimes at the same time, because the same measurements feed the ecodesign file, the EPREL registration and the energy label. The working sequence: classify the model (light source type, directional or not, control gear or integrated); run the Annex II metric set — on-mode power against the formula, CRI, CCT, PstLM, SVM, displacement factor, standby, survival and lumen maintenance at the defined checkpoints; and capture the outputs in the exact fields EPREL expects, so registration becomes data entry rather than a second test campaign. Labs that work regularly on EU lighting export recognize this combined package and quote it as one scope; labs that quote "ErP testing" and "EPREL testing" separately are inviting you to pay twice for overlapping measurements.

Two boundary notes complete the program design. Product families: like CE, ecodesign tolerates well-argued family testing — one driver family, a bounded flux range, identical construction — and the family definition should come from the lab in writing, because the registration structure in EPREL must mirror it model by model. Revisions: any change to the LED package, driver or optical stack is a new technical reality and potentially a new registration; the change-notification clause from your supplier agreement is what makes that visible before shipment rather than after a market-surveillance letter. For buyers assembling the full EU pack, this test program sits alongside the safety-and-substances suite described in our CE guide — different regulation, largely the same laboratory, and a coherent single briefing to both saves weeks.

Who feels the regulation most? Three groups. Importer-distributors of lamps and retrofit sources carry the sharpest duties — they are the "supplier" placing product on the market, and the registration, label and information-sheet obligations land on their desk with their name on them. Project buyers specifying complete luminaires feel it indirectly but constantly, because the replaceable sources and drivers inside their schedules must each clear the same bars, and a tender line as simple as "sources to be SLR-compliant with EPREL registration" quietly disqualifies a third of the quotations. And exporting factories feel it as a documentation capability: the plants that serve the EU in volume maintain Annex II test data as a product asset, refreshed on revision, which is why the EU-ready answer to "can you provide flicker data?" arrives in hours rather than weeks. AURELUX's per-product ErP/EPREL status labeling exists precisely to make that capability visible at the schedule level, before commitments are made.

Common mistakes

• Testing for ErP but never registering. Performance without EPREL is not market access; it is a report in a drawer.
• Assuming the factory registers. The duty sits with the EU-side supplier — importer or authorised representative. Contract the role.
• Registering the family, shipping a variant. EPREL is per model; an unlisted variant is an unregistered product.
• Ignoring SVM. The stroboscopic metric caught a wave of otherwise-fine drivers after its deadline; test it from the start.
• Conflating luminaire and light-source duties. Housings and sources carry different obligations; label the SKUs accordingly.