Wp eu p_lighting

Eco-Design Directive (EuP):
Analysis of Lighting Implementing Measures

244/2009: Non-directional household lamps
245/2009: Street & office lighting

Intertek
70 Codman Hill Road, Boxborough, MA 01719

www.intertek-etlsemko.com/EuP 1-800-967-5352 icenter@intertek.com

Analysis of the Lighting Implementing Measure

Table of Contents

Section Page

Introduction 3

1. The EuP Directive in Brief 4

EuP Scope: Product, Market, Process 4
EuP Adoption/Timeline 5

2. Reg 244/2009 for Non-directional Household Lamps 6

Definition of “non-directional” household lamps 6
Detailed phase-out plan/table 7
Important dates 8
Requirements for non-directional lamps 8
Products not covered under the regulation 9
Efficiency of lamp technologies table 10

3. Reg 245/2009 for Office Lighting & Public Street Lighting 11

Eco-design requirements 11
Important dates 12
Practical applications of the requirement 12
Products not covered under the regulation 13

4. Verification Procedure for Market Surveillance Purposes 14

For lamps 14
For ballasts and luminaires 14

5. Intertek’s EuP Services 15

www.intertek-etlsemko.com/EuP 2


Eco-design Directive 2005/32/EC

EC Reg No. 244/2009 – Part 1
Non-directional household lamps

EC Reg No. 245/2009
Fluorescent lamps without integrated ballast, for high
intensity discharge lamps, and for ballasts and
luminaires able to operate such lamps

Introduction

The Eco-design Directive for Energy-using Products (EuP) 2005/32/EC
requires manufactures and importers to demonstrate compliance with the
Directive’s product category-specific requirements outlined in the
Implementing Measures (IMs). The EuP Directive is CE Marking legislation,
but differs from other EU legislation as it’s intended to encompass the entire
life cycle of energy using products.

The Directive’s IMs provide the specific compliance requirements, segmented
by approximately 30 product categories with more product categories to be
identified in the future.

The Implementing Measures for Non-directional Household Lamps
(244/2009) came into effect on April 13th, 2009. According to the endorsed
regulation applied to non-directional household lamps, all incandescent lamps
will be phased out from the EU market in 4 stages, the first starting in
September 2009 and the last finishing in 2012. Stages 5 and 6, which are
effective in September of 2013 and 2016 respectively, focus on more
ambitious functionality requirements and raising the minimum level to class B
for clear lamps, and phasing out class C retrofit halogen lamps.

The EU has also released the Implementing Measure for Office & Public
Street Lighting, which became effective on 13 April 2009. Commission
Regulation (EC) No. 245/2009 covers implementing eco-design requirements
for:

• Fluorescent lamps without integrated ballast
• High-intensity discharge lamps
• Ballasts and luminaries able to operate such lamps

This Regulation will replace Directive 2000/55/EC in regard to energy-
efficiency requirements for ballasts for fluorescent lighting one year after entry
into force.



1. The EuP-Directive in Brief

General lighting is the fifth product group drawn to vote within the framework
of the EU Directive on Eco-design, also known as the EUP Directive (Energy
using Products) 2005/32/EC, which entered into force in August 2007 and
applies throughout the EU. The Directive aims to reduce the energy use and
other negative environmental impacts throughout the life cycle of products
powered by electricity, fossil or renewable fuels.

The Directive means that manufacturers must take into account energy use
and other environmental factors in the product design. Both producers and
importers will be affected by the Directive. In order to CE mark products, and
thus sell the products on the European market, the Directive requires
adaptation of your products after the "Implementing Measures" that are
currently being developed for different products. The first phase of the EuP
Directive involves around 30 product categories and more are likely to be
affected in the future.

The main purpose of the EuP Directive is to:

• Reduce energy consumption
• Reduce negative environmental impacts
• Promote a sustainable environment

EuP Scope: Product, Market, Process
The Directive applies to all products and/or product groups that require
energy in order to function as intended (excluding vehicles that transport
humans or goods--cars, trains, ships, and airplanes). The products should
fulfill the following criteria in order to be included in an action or to be self-
regulating:

1. The product should represent a significant volume of sales and trade
within the EU, namely, exceeding 200,000 market units across all
manufacturers (this applies to the entire product group rather than
individual products or models, or market volume of an individual
manufacturer).

2. The product should, in view of the quantities put on the market and/or
used, have a substantial environmental impact within the EU.

3. There should be significant opportunities for improving the product’s
environmental impact without incurring unreasonable costs, in view of the
fact that:



a. There is no other relevant common legislation for dealing with the
problem in a suitable manner and it cannot be solved by market
forces.

b. There is a large difference in the environmental performance of
different Energy using Products on the market with equivalent
functions.

c. A special method is used to assess whether and to what extent
different Energy using Products fulfill these criteria and to outline
which eco-design requirements can be established for each specific
product.

The basic elements of the Eco-design requirement are compiled by a number
of groups of experts engaged by the Commission, which then put forward
proposals for product requirements. The Commission reviews these on a
product by product basis and sends its proposals for product requirements in
a consultation document to all EU Member States. The Implementing
Measures will be introduced for each product group either through national
law or through a daughter directive under the Eco-design Directive for Energy
using Products (EuP).

EuP Adoption
So far, Implementing Measures for standby/off mode, simple set top boxes,
street and office lighting, non-directional household lamps and external power
supplies have been adopted.



2. Regulation 244/2009 for Non-directional Household Lamps

Reportedly, lighting represents up to one-fifth of a household's electricity
consumption. There is a four to five-fold difference between the energy
consumption of the least efficient and the most efficient lighting technologies
available on the market. This means that upgrading the lamps could reduce a
household's total electricity consumption by up to 10-15% and save 50€ per
year per household (taking into account the purchasing cost of lamps).1

This has led many countries to ban incandescent light bulbs to save energy.
Brazil and Venezuela were the first countries to start phasing out of
incandescent lamps in 2005. Australia and New Zealand have made the
decision to phase out incandescents by 2010 and Canada by 2012.

The EU regulation 244/2009, which was published on 24 March 2009,
imposes new eco-design requirements for non-directional household lamps.
The measures will apply to such lamps placed on the EU market, even when
they are marketed for non-household use or when they are integrated into
light fixtures intended for general illumination. Product information
requirements are additionally set out for special purpose lamps.

As a result of the regulation, EU citizens are expected to save close to 40
TWh (roughly the electrictity consumption of Romania, or of 11 million
European households, or the equivalent of the yearly output of 10 power
stations of 500 megawatts) and reduce CO2 emission by about 15 million tons
of per year. The regulation is expected to return about 5-10 billion euros to the
EU economy annually.

Definition of "Non-directional" Household Lamps
The regulation covers "non-directional" lamps typically used in households for
general illumination purposes. In addition to incandescent bulbs, these
include halogen lamps and compact fluorescent lamps, among others. Non-
directional lamps emit light equally in all directions, as opposed to directional
lamps (such as reflector lamps/spots) where the light is directed by a reflector
at a given angle.

All non-directional household lamps will have to comply with the same
minimum energy efficiency requirements. Because these requirements are
set at levels that present-day incandescent bulbs and conventional halogen
lamps cannot meet, both incandescent and halogen lamps have been
targeted for phase out.

1
Assuming 20 lamps in the household, which are initially all incandescent lamps and
changed to compact fluorescent lamps of equivalent light output.



In addition to minimum energy efficiency, requirements are also set for
functionality of the concerned lamp types (e.g. lifetime and lighting
performance), and product information for consumers. The requirements for
product information are to enable consumers to better select the appropriate
lamps for a given purpose among the alternatives to incandescent lamps.

Detailed Phase-out Plan of Inefficient Lamps
There are six different stages within the regulations for non-directional
household lamps which extends from September 2009 through September
2016.

The cut-off date for the Stage 1 requirement is 1 September, 2009. After that
date, any product falling into the scope of the regulations sold on the EU
market has to meet the EuP Directive. If your product does not meet the
regulations, you are not able to CE mark and sell your product in the EU.

Grey cells indicate that the technology is still available at the given time, white cells mean that
the technology is phased out according to the provisions given in the "Requirement" column.

Table from http://europa.eu
1
First level of functionality requirements introduced in first stage. LEDs are exempted from all
functionality requirements.
2
Refers to lamp energy label class. Correction factors apply to certain lamps, allowing them to
be B-class.
3
Minimum requirement for all lamps: E class. F and G lamps phased out.
4
Only special cap halogen lamps are allowed to be class C.



Inefficient, non-clear (non-transparent) lamps will be phased out beginning 1
September 2009. Non-clear lamps will be required to be A-class according to
the EU lamp energy label (or slightly less efficient for certain lamps such as
those with external envelope).

Inefficient clear (transparent) lamps will be phased out progressively, starting
with the highest wattage (100 W incandescent bulbs and above) in 2009.

From September 2009, lamps equivalent in light output to 100 W transparent
incandescent bulbs and above will have to be at least class C (improved
halogens instead of incandescent bulbs).

By the end of 2012, the other wattage levels will follow and will also have to
reach at least class C. The most commonly used bulbs, the 60 W, will remain
available until September 2011 and 40 W and 25 W bulbs until September
2012.

The regulation will only apply to the products that are "placed on the market"
(sold by the manufacturer or importer) after the deadline for the requirements.
Therefore, for Stage 1, all 100 W incandescent bulbs that were already on the
shelves of the retailers or in retailer stocks before 1 September 2009 can
continue to be sold until they run out.

Each stage also has requirements for lamp efficiency, lamp functionality and
product labeling and marking information. Some products will be phased out
if they do not meet the lamp efficiency requirements.

Important Dates

The requirements are introduced in steps according to the schedule below:

• First phase: 1 September 2009
• Second phase: 1 September 2010
• Third phase: 1 September 2011
• Fourth phase: 1 September 2012
• Fifth phase: 1 September 2013
• Sixth phase: 1 September 2016

Unless a requirement is superseded or this is otherwise specified, it shall
continue to apply together with other requirements introduced at later stages.

Requirements for Non-directional Lamps for Household Use

• Lamp Efficacy. Requirements call for the lamps to fall into Class A of
energy efficiency.
• Lamp functionality. Requirements mainly involve the testing of lumen
maintenance, number of switching cycles, starting time, power factor,
color rendering, etc.



• Product information. Requirements for information to be visibly
displayed prior to purchase to end-users on the packaging or website,
including the lamp mercury contents if applicable.

Products Not Covered Under the Regulation

The requirements set out in the regulation do not apply to the following
household and special purpose lamps:

• Lamps with Chromaticity Coordinates
x < 0.200 or x > 0.600
y < -2.3172x² + 2.3653x – 0.2800 or
y > -2.3172 x² + 2.3653x – 0.1000.

• Directional Lamps
– Having at least 80% light output within a solid angle of π sr)
(corresponding to a cone with angle of 120° ).

• Directional Lamps
– Having at least 80% light output within a solid angle of π sr)
(corresponding to a cone with angle of 120° ).

• Lamps w/ Luminous Flux < 60 lumens or > 12,000 lumens.

• Lamps having:
– 6% or more of total radiation of the range 250-780 nm in the range of
250-400 nm.
– The peak of the radiation between 315-400 nm (UVA) or 280-315 nm
(UVB).

• Fluorescent Lamps without Integrated Ballast.

• High-Intensity Discharge Lamps.

• Special Purpose Lighting
– LED Traffic Signals, Terrarium Lighting, Household Appliances.

• Incandescent Lamps with E14/E27/B22/B15 caps, with a voltage equal
to or below 60V and without integrated transformer are exempt in
Stages 1- 5, but not Stage 6.

• Incandescent Lamps with S14, S15, or S19 Caps are exempt in Stages
1-4, but not Stages 5 & 6.



Efficiency of Lamp Technologies Compared with Incandescent Lamps
(E-class)

The following chart compares the potential energy savings of various lamp technologies with
traditional incandescent lamps:

Lamp Technology Potential Energy Class
Energy
Savings
Incandescent lamps - E, F, G
Conventional halogens (mains voltage 230 V) 0 – 15 % D, E, F
Conventional halogens (low voltage 12 V) 25% C
Halogens with xenon gas filling (mains voltage 230 V) 25% C
Halogens with infrared coating 45% B (lower end)
CFLs with bulb-shaped cover and low light output, 65% B (higher
LEDs end)
CFLs with bare tubes or high light output, LEDs 80% A



3. Regulation 245/2009 for Office Lighting and Public
Street Lighting

The draft for product requirements for street lighting was completed in June
2007, and the proposed eco-design requirements are based on the following
trends:

• The market for lighting products is extensive and is expected to
increase from about 1.6 billion points of light in 2005 to 2.3 billion in
2020. The requirements are expected to increase to more light in
existing installations.

• Lighting affects the environment in several ways, including its energy
consumption and mercury content. If the number of points of light
increased to 2.3 billion, but no specific requirements are made to
decrease energy consumption, then energy consumption is expected
to increase from 200 TWh to 260 TWh and the use of mercury to
increase from 12.6 tonnes to 18.6 tonnes in 2020. Light spread is,
however, difficult to measure.

The European Commission decided to merge street and office lighting into a
joint proposal for the tertiary sector. The outcome is regulation 245/2009
which came into force on April 13, 2009. The regulation 245/2009 for office
and public street lighting sets requirements for Fluorescent Lamps without
Integrated Ballast, High-Intensity Discharge Lamps and associated Ballasts
and Fixtures for Fluorescent and HID Lamps.

There are however several limitations, for instance very small HID lamps
(high-intensity discharge) now increasingly popular in the retail sector are not
covered. In addition, no reflector lamps are covered since they are to be
covered under a separate piece of legislation due out in late 2009.

Eco-design Requirements 245/2009:
The requirements are divided into the following categories:

• Demands on the lamps: Lamp efficacy, performance and product
information.
• Demands on the ballasts: Energy performance and product
information.
• Demands on the luminaires: Energy performance and product
information.



The specific requirements for each category are summarized as follows:

Requirements on lamps

• Lamp efficacy: Measured in lumen per watt (lm/W). Detailed values
for different lamp types and wattages.
• Lamp performance: Different parameters for different lamp types. The
parameters are colour rendering index (Ra), lamp lumen maintenance
factor and lamp survival factor.
• Lamp product information: Manufacturers shall provide information
on free-access websites and in other forms they deem appropriate.
That information shall also be contained in the technical documentation
file drawn up for the purposes of conformity assessment. The
information shall consist of a number of parameters, e.g. nominal and
rated lamp wattage, nominal and rated lamp luminous flux, rated lamp
efficacy.

Requirements on ballasts

• Energy performance: This is the ratio between input and output power.
There are also requirements for power consumption when the lamp
doesn’t emit any light.
• Product information; entails that manufacturers of ballasts shall provide
at least the following information on free-access websites and in other
forms they deem appropriate. That information shall also be affixed in a
distinct and durable form to the ballast. It shall also be contained in the
technical documentation file drawn up for the purposes of conformity
assessment.

Requirements on luminaires

• Energy performance is requirements for power consumption when the
lamp doesn’t emit any light. Also demands for compatible with ballasts
complying with the 3rd stage requirements.
• Product information: Manufacturers of luminaires for fluorescent lamps
without integrated ballast with total lamp lumen above 2 000 lumen
shall provide information on free-access websites and in other forms
they deem appropriate. This information shall also be contained in the
technical documentation file drawn up for the purposes of conformity
assessment, e.g. maintenance manual and disassembly instructions.

Important Dates

• The regulation is adopted by the commission and published on 24
March 2009.
• Entry into force on 13 April 2009.
• First stage requirements are mandatory from 13 April 2010.



Practical Applications of the Requirements

• "Fat" linear T12 (and T10) halo phosphate lamps will be banned from
2012 with the exception of lamps for special purposes.

• Minimum rated efficacy values will be imposed on various lamp types
including T8 and T5 linear lamps, High-Pressure Sodium Lamps, and
Metal Halide Lamps.

• Minimum lumen maintenance levels will be imposed on various lamp
types including single and double-capped fluorescent lamps, high-
pressure sodium lamps, and metal halide lamps.

• Beginning in 2017, (eight years after the regulation takes effect) all
fluorescent lamps must be designed to work with electronic ballasts.

• Beginning in 2012, new luminaries must be sold with electronic
ballasts. Starting in 2017, magnetic ballasts will not be permitted even
for replacement in existing luminaries.

• 90 % of the HPS (high-pressure sodium) lamps should have a life time
of more than 16000 hours.

• Metal halogen lamps should have a minimum life time of 12000 h for
80% (frosted) and 90% (clear).

• Specific requirements on directional light sources for street lighting
luminaries (not only HID) to reduce light pollution.

• Minimum performance requirements for all HID lamps to minimize
mercury content.

• The products covered are used in offices and on streets, and in other
applications, including industrial plants, shops, public buildings, etc.

Products Not Covered Under the Regulation
The requirements set out in the regulation shall not apply to the following
lamps and special purpose lamps:

• Lamps that are not White Light Sources
• Directional Light Sources
• Lamps intended for use in other applications than general lighting and
lamp incorporated into other products not providing a general lighting
function.
• Lamps having:
– 6% of total radiation of the range 250 -780 nm between 250 - 400 nm



– 11% of total radiation of the range 250-780 nm between 630–780 nm
– 5% of total radiation of the range 250-780 nm between 640 – 700 nm
– Peak Radiation between 315 – 400 (UVA) or 280 – 315 nm (UVB)
• Double-Capped Fluorescent Lamps having Specific Diameters
– A diameter of 7 mm (T2) and less, a diameter of 16 mm (T5) and
lamp power P ≤ 13 W or P > 80 W,
– A diameter of 38 mm (T12), lamp cap G-13 Medium BiPin base, +/–
5 m (+magenta, –green) color compensating filter value limit (cc).
CIE coordinates x=0,330 y=0,335 and x=0,415 y=0,377, and
– A diameter of 38 mm (T12) and equipped with an external ignition
strip.
• Single capped fluorescent lamps having a diameter of 16 mm (T5)
2G11 4 pin base, Tc = 3 200 K with chromaticity coordinates x=0,415
y=0,377 and Tc = 5 500 K with chromaticity coordinates x=0,330
y=0,335.
• High intensity discharge lamps with Tc > 7000 K.
• High intensity discharge lamps having a specific effective UV output >
2 mW/klm; and high intensity discharge lamps not having lamp cap
E27, E40, PGZ12.
• Emergency lighting luminaries and emergency sign luminaries within
the meaning of 2006/95/EC.
• Luminaries covered by the requirements of Directives
94/9/EC,1999/92/EC, 2006/42/EC, 93/42/EEC, 88/378/EEC and
luminaries integrated into equipment covered by these requirements.

4. Verification Procedure for Market Surveillance Purposes
(Reg 244/2009 & Reg 245/2009)

The Regulations provide that the relevant authorities in Member States will be
required to test randomly selected samples. The following procedures are
applicable to regulations 244/2009 and 245/2009.

For lamps: A batch of 20 lamps of the same model and manufacturer shall
be randomly selected and tested. The batch shall be considered as complying
with this regulation when the mean value does not differ more than 10% from
applicable limits. Otherwise, the model shall be considered not to comply.

For ballasts and luminaires: One single unit will be tested. The model shall
be considered to comply with this regulation when the results do not exceed
the limit values. Otherwise, three more units shall be tested. The model shall
be considered to comply with this Regulation if the average of the results of
the latter three tests does not exceed 10% of the limit values. Otherwise, the
model shall be considered not to comply.



5. Intertek’s EuP Services
The EuP Directive is an expansive piece of environmental legislation; and if
taken on alone by manufacturers can seem onerous to achieve and difficult to
document compliance for legal CE Marking. Intertek’s depth of experts in
environmental legislation and product compliance have untangled the EuP
Directive and its implementing measures to help manufacturers realize the
most cost-efficient, easy to understand and simple path to compliance and
market access. Intertek’s EuP solutions are broken into two categories:

1. EuP Compliance

• EuP Pre-Compliance Verification: Learn how your product measures
up against proposed and future EuP regulations for R&D purposes,
compliance planning and to determine market readiness.
• EuP Compliance Verification: Receive full verification to the
appropriate EuP Implementing Measures and Intertek will deliver a test
report for your product’s technical file and Statement of Compliance for
legal CE Marking. We’ll also advise and provide you with the most
cost-effective path to compliance with other New Approach Directives.

2. EuP Training & Consulting

• EuP Training & Consulting: Learn WHAT your quickest and most
cost-efficient compliance options are. We’ll tell you IF, WHEN, and
HOW EuP will affect your product.
• EuP Eco Software Analysis: Let Intertek perform an analysis of your
product’s Ecological profile according to the EuP directive
specifications.

For More Information
If you have any questions or would like to start a new project, visit
www.intertek-etlsemko.com/EuP or call one of our EuP Testing Centers:

Americas Germany Sweden
+1 800 967 5352 +49 711 27311 0 +46 8 750 00 00
icenter@intertek.com info.etls-germany@intertek.com info-sweden@intertek.com

Asia Pacific Italy UK
+86 21 6127 8200 +39 432 653 411 +44 1372 370900
ce.asiapacific@intertek.com info.etls-italy@intertek.com electrical.uk@intertek.com


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