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LightingEurope represents leading European lighting manufacturers and national lighting associations, committed to innovation, sustainability and efficient lighting practices.

Lobbying Activity

LightingEurope Urges Including Smart Luminaires in EU Green Taxonomy

21 Nov 2025
Topic — The consultation reviews the EU taxonomy environmental delegated act to update screening criteria.
Message — LightingEurope requests explicitly recognizing controllable LED-based luminaire manufacturing as a sustainable activity. This would accelerate smart lighting adoption and ensure clear market rules.12
Why — The industry would avoid unfair disadvantages and gain equal access to sustainable finance.34
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Lighting industry urges mandatory acceptance of product-specific emission data

30 Oct 2025
Topic — The consultation establishes a Union framework for calculating the life-cycle carbon footprint of buildings.
Message — The organization requests that the EU mandates Member States to accept product-specific data. They also advocate for using established lighting-specific standards for operational calculations.12
Why — Standardized rules would prevent market fragmentation and protect the competitive position of sustainable manufacturers.34
Impact — Sustainably operating manufacturers lose if generic default values mask their products' superior performance.5
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LightingEurope demands clarity on new cyber resilience compliance rules

13 Oct 2025
Topic — The EU is proposing a digital omnibus to simplify various technology regulations.
Message — The industry seeks clarity on how new cyber rules interact with existing radio laws. They request precise definitions for product modifications and practical guidance for risk assessments. Consistent terminology across EU legislation is also requested.123
Why — This would reduce administrative costs by preventing the need for duplicate product certifications.45
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Meeting with Christel Schaldemose (Member of the European Parliament, Shadow rapporteur)

7 Oct 2025 · Omnibus

Meeting with Nikola Minchev (Member of the European Parliament) and Deutsche Sozialversicherung Europavertretung

2 Oct 2025 · Exchange of views

Meeting with Rosalinde Van Der Vlies (Director Energy)

9 Sept 2025 · The European Lighting Sector: State of Play, opportunities and challenges within the EU policy context

LightingEurope demands withdrawal of EU common specifications proposal

2 Sept 2025
Topic — A proposal to digitalize product information and align technical specification rules.
Message — The organization calls for the total withdrawal of the common specifications proposal to protect industry competitiveness. While they welcome digitalization, they want a better definition of safety-critical information that must remain on paper.12
Why — The industry would avoid new administrative burdens and unworkable technical mandates.3
Impact — International standards bodies lose influence as Europe moves toward parallel systems.4
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LightingEurope urges withdrawal of EU proposal for common specifications

2 Sept 2025
Topic — The European Commission seeks to digitalise product information and align technical standardisation rules.
Message — LightingEurope demands the withdrawal of the common specifications proposal to protect the existing standardisation system. They support digitalising product data to reduce paper-based burdens and simplify compliance checks.123
Why — Digitalisation would decrease operational costs and make updating technical product documentation easier.4
Impact — European exporters face harm if technical requirements decouple from international standardisation frameworks.5
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Response to Revision of the Standardisation Regulation

18 Jul 2025

Please find attached LightingEurope's position to the European Commission's call for evidence in view of the revision of Regulation (EU) No 1025/2012.
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Lighting industry opposes mandatory audits for unsold goods reporting

10 Jul 2025
Topic — New EU rules requiring companies to disclose data on destroyed unsold consumer products.
Message — LightingEurope calls for the removal of mandatory third-party auditing for reporting unsold consumer products. They propose a risk-based, ex-post verification approach by national authorities to ensure cost-effective enforcement.12
Why — Removing mandatory audits prevents significant financial burdens and reduces administrative complexity for businesses.3
Impact — Auditing firms lose guaranteed revenue if third-party verification is no longer mandatory for companies.4
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Response to European Affordable Housing Plan

3 Jun 2025

Dear Sir or Madam, please find enclosed the response from LightingEurope, the industry association representing the lighting industry.
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LightingEurope demands adequate consideration for lighting in building methodology

7 May 2025
Topic — The Commission is revising the methodology for calculating cost-optimal building energy performance levels.
Message — LightingEurope reemphasizes the necessity of adequate consideration for lighting in this methodology. They urge the Commission to reference standards that include lighting elements.12
Why — This would foster a regulatory environment that promotes growth for European lighting manufacturers.3
Impact — Environmental groups lose as energy targets are weakened by the methodology's limited scope.4
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Meeting with Gheorghe Piperea (Member of the European Parliament, Shadow rapporteur)

6 May 2025 · Product Safety and regulatory Compliance in e-commerce and non-eu imports (2025/2037(INI)) - S. De Meo

Meeting with Christel Schaldemose (Member of the European Parliament)

6 May 2025 · e-commerce

Response to Technical description of important and critical products with digital elements

18 Apr 2025

We thank the European Commission for this opportunity to provide our feedback to an essential Implementing Regulation of the CRA. LightingEurope would like to request clarification regarding the classification of 10. Physical and virtual network interfaces under Class I (Important Products) in Annex I of the draft Implementing Regulation on product categories for the Cyber Resilience Act (CRA). The ambiguity in the current definition has led to divergent interpretations from our members, particularly for gateway devices (e.g., DALI, BLE) with IP-enabled ports (Ethernet/Wi-Fi). Our understanding is that the core functionality of a gateway device like DALI is specifically to allow IP traffic on one side of the gateway device to have meaningful implications and effects on the non-IP side. This close relationship between IP traffic and the functionality enabled on the non-IP side makes the current definition of 10. Physical and virtual network interfaces uncertain. Please see our detailed request in the attached document following the format provided for the consultation. LightingEurope is the voice of the lighting industry, based in Brussels and representing 32 companies and national associations. Together these members account for over 1,000 European companies, a majority of which are small or medium-sized. They represent a total European workforce of over 80,000 people and an annual turnover exceeding 15 billion euro. LightingEurope is committed to promoting efficient lighting that benefits human comfort, safety and well-being, and the environment. LightingEurope advocates a positive business and regulatory environment to foster fair competition and growth for the European lighting industry. More information is available at www.lightingeurope.org.
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LightingEurope wants luminaire manufacturing included in EU green taxonomy

25 Mar 2025
Topic — The initiative simplifies reporting requirements for companies under the EU's sustainable finance taxonomy.
Message — The association requests that manufacturing controllable LED-based luminaires be classified as a green activity. They also seek specific exemptions for certain chemicals to align with existing electronic regulations.12
Why — This change would provide luminaire manufacturers with equal access to sustainable finance opportunities.3
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Response to Review of ecodesign and information requirements for external power supplies (EPS)

16 Dec 2024

Please see the attached file for the full LightingEurope's feedback.
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Meeting with Laura Ballarín Cereza (Member of the European Parliament)

28 Oct 2024 · E-commerce and priorities for the mandate 2024-2029

Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur)

9 Oct 2024 · discussion on Green Claims Directive

Meeting with Stefano Cavedagna (Member of the European Parliament) and FoodDrinkEurope

9 Oct 2024 · Introductory meeting - discussion about the next legislative proposals

Meeting with Bruno Tobback (Member of the European Parliament)

9 Oct 2024 · Lighting

Meeting with Francesco Torselli (Member of the European Parliament)

9 Oct 2024 · Incontro conoscitivo per discutere delle nuove proposte regolatorie in tema di commercio internazionale

Meeting with Oliver Schenk (Member of the European Parliament)

8 Oct 2024 · level playing field for online marketplaces and effective enforcement

Meeting with Ana Vasconcelos (Member of the European Parliament)

3 Oct 2024 · DSA

Meeting with Cyrus Engerer (Member of the European Parliament, Rapporteur)

13 Mar 2024 · Green Claims Directive

Lighting industry urges reversal of cadmium quantum dot ban

18 Dec 2023
Topic — EU decision on exemption for cadmium in LED lighting technology.
Message — LightingEurope wants the Commission to reconsider its decision not to grant an exemption for cadmium quantum dots in LED lighting. They argue the technology delivers 10% energy efficiency improvements and would save more cadmium through reduced power production emissions than it places on the market.123
Why — This would allow them to commercialize an innovative technology and gain competitive advantage in global markets.45
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Response to Verification of suppliers and other operational aspects for the functioning of product database - EPREL

20 Nov 2023

This paper has been prepared by LightingEurope in response to a working document for the second draft of a future Commissions proposal Implementing Regulation laying down operational details for the European Product Registry for Energy Labelling and the Commissions Ecodesign Consultation Forum that took place on 6 October 2023. We welcome the act as a mean to clarify some critical aspects of the database. As lighting products are the largest category of products present on EPREL, we would like to share some comments and proposals. Feedback is provided on an article-by-article-basis.
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Response to Mercury – review of EU law

11 Aug 2023

LightingEurope welcomes the European Commissions ambition to reduce the mercury amount that is put on the global market to limit environmental and social impacts. From our side, we are working in the Global Lighting Association with organisations from other regions to forge an industry consensus for a global ban of general lighting mercury containing lamps that works for all regions. We do, however, share the consultant's fear regarding the net effect on global mercury use if there is a misalignment between EU phase out dates and Minamata, specifically for manufacturing and export. We therefore plea for the Commission to align their phase out dates with Minamata. We also want to take this opportunity to highlight a specific mistake that was made in the manufacture and export prohibition date of HPS lamps (Annex (3) - new entry 5a). Please see the details in our attached statement. We implore the European Commission to correct the Annex to ensure that the Mercury Regulation remains aligned with the existing HPS exemptions and their expiry dates under the RoHS Directive to avoid conflicting legislation and legal uncertainty.
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Meeting with Jakop G. Dalunde (Member of the European Parliament, Shadow rapporteur)

20 Jul 2022 · ESPR (Staff Level)

Meeting with Seán Kelly (Member of the European Parliament)

12 Jul 2022 · Fit for 55 Package

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

In December 2020, the EU agreed to reduce greenhouse gas emissions by 55 % in 2030. As buildings use 40 % of energy and produce 36 % of greenhouse gasses in Europe, an earlier targeted review of the Energy Performance of Buildings Directive (EPBD) is needed to achieve those objectives. Modernised lighting can significantly contribute to the energy savings in buildings, and thus also assist in the reduction of greenhouse gas emissions. Lighting accounts for around 20 % of the total cost-effective electrical energy savings potential in non-residential buildings: by including lighting systems in the EPBD, an additional 29 TWh/y can be saved by 2030 (up to 56 TWh/y in 2050). The World Health Organisation estimates that people spend approximately 90 % of their time indoors in residential and non-residential buildings, and the Covid-19 crisis has highlighted the importance of indoor comfort and wellbeing. Beyond the energy savings, including lighting systems in the EPBD will also improve the visual comfort, wellbeing, and productivity of building users. For the targeted revision of the EPBD, we recommend to: - Include requirements for the optimisation and utilisation of automatic lighting controls; - Include lighting inspection requirements; - Include minimum requirements for IEQ; - Include UV-C disinfection technology; and - Include the Lighting System Design Process. For more details, please read the attached position paper.
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Response to Recommendation for strengthened actions against antimicrobial resistance

23 Mar 2022

LightingEurope calls on European policymakers to actively support and stimulate the uptake of UV-C disinfection technologies to combat AMR, especially in health facilities and hospitals and to ensure that EU and national financial instruments are available to support their installation. UV-C disinfection technology is an effective tool in combating micro-organisms and viruses and an established technology for disinfection. It has been applied extensively since 1910 when it was found to be an effective tool in preventing the spread of disease. Already in 1999, the World Health Organisation officially endorsed its usage against tuberculosis, an infectious disease second only to Covid-19 in its lethality. Drug-resistant tuberculosis (TB) is a major contributor to antimicrobial resistance, with about half a million people falling ill each year with the drug-resistant strain worldwide. Today, UV-C disinfection technologies are already a valuable assistant in the battle against the current Covid-19 pandemic and they will also come to play an indispensable role for major health concerns such as AMR where a pure focus on regulating prudent antibiotic use will not be sufficient to tackle the health crisis. Studies confirm that UV-C light is effective in reducing health care-acquired infections, such as methicillin-resistant Staphylococcus aureus (MRSA) and can be a good alternative to chemical disinfectants.
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LightingEurope urges alignment of RoHS and Ecodesign timelines for fluorescent lamps

12 Jul 2021
Topic — RoHS exemptions for mercury in fluorescent lamps for general lighting purposes.
Message — The organization requests the European Commission align RoHS exemption timelines with Ecodesign regulations to create a single clear timetable. If alignment is not possible, they ask for a public statement clarifying which timeline takes precedence for each product type.12
Why — This would provide regulatory clarity for manufacturers worldwide and their European customers.3
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LightingEurope urges alignment of RoHS and Ecodesign timelines for fluorescent lamps

12 Jul 2021
Topic — EU restrictions on mercury in fluorescent lamps under hazardous substances regulations.
Message — The organization requests the European Commission align RoHS exemption timelines with existing Ecodesign regulations to avoid market confusion. They ask for a clear statement indicating which timeline takes precedence for each product type.12
Why — This would provide regulatory clarity and reduce compliance uncertainty for manufacturers worldwide.3
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LightingEurope urges alignment of RoHS and Ecodesign timelines for fluorescent lamps

12 Jul 2021
Topic — Regulation on mercury exemptions for fluorescent lamps under hazardous substance rules.
Message — The association requests the Commission align RoHS exemption timelines with existing Ecodesign regulations to create a single clear phase-out schedule. If alignment is not possible, they want an official statement clarifying which timeline takes precedence for each product type.12
Why — This would eliminate regulatory confusion and provide manufacturers clarity on product availability timelines.34
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LightingEurope seeks technical correction to UV lamp exemption wording

12 Jul 2021
Topic — EU regulation exempting mercury use in special-purpose discharge lamps under RoHS.
Message — The organization requests correction of a technical error in the exemption wording. They note that the Annex incorrectly describes 'high-pressure sodium vapour lamps emitting in the UV spectrum' which do not exist. They ask the Commission to use the correct wording from the main text instead.123
Why — This ensures the regulation accurately reflects existing lamp technologies their members produce.4
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Response to Ecodesign and energy labelling working plan 2020-2024

2 Jun 2021

LightingEurope supports the Consultant’s conclusion not to select street lighting systems equipped with photovoltaic panels (PV) to be part of the 2020-2024 ecodesign and energy labelling working plan. As regards the horizontal requirements proposed by the Consultants, LightingEurope favours the approach of setting requirements only in product-specific regulations. Below some initial comments of LightingEurope members to the proposed horizontal requirements. Durability: • Light sources already have durability requirements under Ecodesign – LightingEurope members are of course committed to applying them. • We are concerned that if information requirements on durability would be applied to lighting products, such information could not be validated. • Please note that there is no single meaningful metric available to express the durability of a lighting product. Lightweight design: The difficulty is how to apply such a rule to products that can be very varied, even in a single product category: • Some products are fully integrated and lighter while others can be disassembled and are heavier. This requirement could therefore conflict with repair requirements. • Some products are very simple and consist of a single component. • Weight also depends on material choices, and some robustness, durability or safety requirements may in turn require heavier materials. Recycled content, as regulated in the UK and Italy with percentages of recycled plastics: The properties of recycled materials may not be appropriate for all applications. Products that are expected to operate in specific conditions will need to satisfy specific requirements and may require materials that are not flammable, that are resistant to water, direct sunlight, extreme heat etc. It is not yet clear whether recycled plastics will be available in sufficient quantities to allow a requirement on the percentage of recycled plastics to be fulfilled. We ask how enforcement authorities will check that individual products comply with such a requirement. To our understanding and in particular in the case of plastics, there is no technical or scientific solution to characterize recycled content, as both the virgin and the recycled material share the same atomic structure.
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Response to Mercury – review of EU law

1 Apr 2021

LightingEurope Contribution to the EU Mercury Regulation 2017/852 Roadmap Consultation Recommendation The intention of Regulation (EU) 2017/852 of 17 May 2017 on mercury is to transpose the Minamata Convention on Mercury into EU law; its provisions “are aimed at ensuring the fulfilment by the Union and the Member States of the obligations of the Convention concerning trade of mercury”. LightingEurope recommends that the European Union aligns at international level, and as part of the ongoing negotiations on the Minamata Convention on Mercury, on the most environmentally and economically effective manner of reducing and eliminating the presence of mercury in mercury added products (MAPs) on the international market. We continue to remain available to share data, facts and technical expertise about the presence of mercury in lighting products, their manufacture in the EU, the availability of substitutes and alternative technologies and the pace of transitioning to LED substitutes in the EU and globally.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

In December 2020, the EU agreed to reduce greenhouse gas emissions by 55 % in 2030. As buildings use 40 % of energy and produce 36 % of greenhouse gasses in Europe, an earlier targeted review of the Energy Performance of Buildings Directive (EPBD) is needed to achieve those objectives. Modernised lighting can significantly contribute to the energy savings in buildings, and thus also assist in the reduction of greenhouse gas emissions. Lighting accounts for around 20 % of the total cost-effective electrical energy savings potential in non-residential buildings: by including lighting systems in the EPBD, an additional 29 TWh/y can be saved by 2030 (up to 56 TWh/y in 2050). The World Health Organisation estimates that people spend approximately 90 % of their time indoors in residential and non-residential buildings, and the Covid-19 crisis has highlighted the importance of indoor comfort and wellbeing. Beyond the energy savings, including lighting systems in the EPBD will also improve the visual comfort, wellbeing, and productivity of building users. The energy savings and Indoor Environmental Quality (IEQ) benefits can only be achieved by following the Lighting System Design Process. This allows for tailoring the lighting systems to the specific building and user needs. In the targeted revision of the EPBD, LightingEurope recommends to: - Include requirements for the optimisation and utilisation of automatic lighting controls; - Include lighting inspection requirements; - Include minimum requirements for IEQ; - Include UV-C disinfection technology; and - Include the Lighting System Design Process. For more information about our recommendations, please see our enclosed position paper.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

LightingEurope, the federation of lighting manufacturers and their supply chain in Europe, is concerned about the rationale behind the proposals concerning lighting as tabled in Annex I and Annex II of the proposed delegated regulation on Taxonomy. The criteria as currently drafted for lighting appliances are restrictive to the point that, due to the limits imposed on the new energy classes by the Energy Labelling Regulation (EU) 2017/1369, no products in the market will currently qualify. We question why investors should finance products that are not supposed to exist for a number of years, which is today difficult to forecast. We also doubt that the expression ‘lighting appliances’ is enforceable, as this term is not defined in the current Ecodesign (R. 2019/2020) and Energy Labelling (R. 2019/2015) regulations on light sources. We propose the following changes to the texts in both Annexes: Annex I and Annex II 3.4. Manufacture of energy efficiency equipment for buildings Draft text (f) lighting appliances rated in the top two energy labelling class in accordance with Regulation (EU) 2017/1369 Proposed Amendment: (f) light sources and containing products using light sources rated in the top four energy labelling classes Motivation: 1. We propose to change “lighting appliances” to “light sources and containing products using light sources”. Reasons: the term lighting appliance is not defined in the current Ecodesign (R. 2019/2020) and Energy Labelling (R. 2019/2015) regulations on light sources. We recommend therefore to align this text with the existing sectorial legislation. Moreover, in current R. 2019/2015, only light sources are energy rated and therefore the text should be adapted accordingly. 2. We propose to extend the “top two energy labelling classes” to “the top four energy labelling classes”. Reason: rescaling of the light source energy label classes under Regulation 2019/2015 (effective from 1 September 2021) means that no light sources in the top two energy classes are expected for several years, the new scaling being designed to accommodate technical progress during the next 10 years. In conclusion we propose that item (f) shall be reworded as follows: (f) Light sources and containing products using light sources rated in the top four energy labelling classes in accordance with Regulation (EU) 2017/1369.
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Response to Ecodesign omnibus amendment of 2019 regulations

3 Nov 2020

LightingEurope would like to share a number of comments on the Omnibus amendments to the regulations on light sources. Please find attached our comments. LightingEurope is the voice of the lighting industry, based in Brussels and representing 33 companies and national associations. Together these members account for over 1,000 European companies, a majority of which are small or medium-sized. They represent a total European workforce of over 100,000 people and an annual turnover exceeding 20 billion euro. LightingEurope is committed to promoting efficient lighting that benefits human comfort, safety and well-being, and the environment. LightingEurope advocates a positive business and regulatory environment to foster fair competition and growth for the European lighting industry. More information is available at www.lightingeurope.org
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Response to Energy labelling omnibus amendment of 2019 regulations

3 Nov 2020

LightingEurope would like to share a number of comments on the Omnibus amendments to the regulations on light sources. Please find attached our comments. LightingEurope is the voice of the lighting industry, based in Brussels and representing 33 companies and national associations. Together these members account for over 1,000 European companies, a majority of which are small or medium-sized. They represent a total European workforce of over 100,000 people and an annual turnover exceeding 20 billion euro. LightingEurope is committed to promoting efficient lighting that benefits human comfort, safety and well-being, and the environment. LightingEurope advocates a positive business and regulatory environment to foster fair competition and growth for the European lighting industry. More information is available at www.lightingeurope.org
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

LightingEurope takes this public consultation as an opportunity to share some preliminary remarks and questions for the consideration of the European Commission ahead of the drafting of the proposal for a Regulation. LightingEurope makes general remarks on the following issues in its detailed paper attached to this consultation: 1. Proliferation of information requirements 2. Adopt a product-specific approach - Environmental impact of lighting known to be dominated by use-stage energy consumption 3. Lack of Enforcement of Existing Rules Ahead of the preparation of the proposal for a Regulation, LightingEurope asks the European Commission to address the following questions: - How does this proposal relate to and complement the other information requirements announced in the Circular Economy Action Plan (European Dataspace for Smart Circular Applications, Product Passports, harmonized systems to track and manage information on substances, etc.), as well as other existing/upcoming information requirements (EPREL and SCIP databases)? - An Impact Assessment is a must in Better Regulation – as part of it, we ask the Commission to demonstrate how, from the experience of the ~457 information requirements mentioned in the Roadmap, such tools have supported users in making informed choices? What would be the added value specifically of a PEF for helping consumers make informed choices? We note that ANEC recently commented on the Circular Economy Action Plan Roadmap that LCA indicators do not serve the purpose of addressing misleading green claims.3 - The Impact Assessment should aim to answer what are the information requirements users actually search for and need in order to make informed purchases. Before new rules are created, the Commission should ensure that such information requirements are necessary, proportionate and justified. How will the Commission ensure that products that will be phased out in the short term under EU rules will not be subject during that short time to additional assessments and requirements? This will create additional unnecessary burden and generate no value. - How will the Commission and Member States ensure that these information requirements are enforceable? We ask that the upcoming Regulation contains an article with a clear legal obligation for Member States to carry out market surveillance activities to ensure the enforcement of the new information requirements. - What experiences do Member States and the Commission have with the enforcement of such information requirements? These experiences must be drawn upon before proposing new legislative requirements. (e.g. do Member States have sufficient resources, testing capacities, etc.) For further information on this topic, please review the attached paper with this consultation and contact Ourania Georgoutsakou, Secretary General, (Ourania.georgoutsakou@lightingeurope.org) and Roumiana Santos, Senior Policy Officer (Roumiana.santos@lightingeurope.org). LightingEurope is the industry association that represents the lighting industry in Europe. We are the voice of more than 1,000 lighting companies that employ more than 100,000 Europeans and create an annual European turnover of over € 20 billion. Our daily mission is to advocate and defend the lighting industry in Brussels, while reconciling it with ongoing EU policy aims. In doing so, we are dedicated to promoting efficient lighting practices for the benefit of the global environment, human comfort, and the health and safety of consumers. More information is available on: www.lightingeurope.org.
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Response to Implementation modalities of the smart readiness indicator for buildings

16 Jul 2020

The SRI offers a possibility to obtain significant energy and cost savings and to make advances in the comfort and wellbeing of building users. Nevertheless, we notice that the draft delegated and implementing acts on the SRI do not use this potential optimally and in some cases even deviate from what has been agreed upon during the stakeholder meetings and intermediate reporting during the study process on the SRI. This is a worrying development, as the currently proposed regulations risk an increasingly fragmented European market for building smartness and its assessment, which will make it even more challenging to generate a European level playing field in the future. Below are the LightingEurope comments to the draft implementing act, as shared for the public consultation on 18 June 2020. - Article 3 on the accreditation and qualification of SRI experts The mentioned qualifications are dependent on the complexity of the assessments that need to take place, and those assessments are no longer fixed due to the optional aspects for Member States included in the draft text. In such a situation, how is it possible to tell if the qualifications are appropriate? Such options to deviate from a common EU scheme should be reduced as much as possible, and preferably not be permitted at all. - Article 5 on the coupling with the EPC and its inspection LightingEurope would like to point out that we support the possibility offered in this Article to couple the SRI with the Energy Performance Certificate. We believe that this will create an additional demand for the SRI. - Annex.3(c) on the SRI monitoring and implementation The type of building (as referred to in Annex IX of the delegated act) must be mentioned in the reporting to the EU. The reason is that this will enable an in-depth analysis of the use of the SRI in the EU building stock. Please see the enclosed LightingEurope Position Paper for further information.
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Response to Establishment of a smart readiness indicator for buildings

16 Jul 2020

The SRI offers a possibility to obtain significant energy and cost savings and to make advances in the comfort and wellbeing of building users. Nevertheless, we notice that the draft delegated and implementing acts on the SRI do not use this potential optimally and in some cases even deviate from what has been agreed upon during the stakeholder meetings and intermediate reporting during the study process on the SRI. This is a worrying development, as the currently proposed regulations risk an increasingly fragmented European market for building smartness and its assessment, which will make it even more challenging to generate a European level playing field in the future. Below are the LightingEurope comments to the draft delegated act, as shared for the public consultation on 18 June 2020. - Preamble, para. 16 The SRI does not cover cybersecurity aspects as explained in this paragraph. In order to reflect the actual state of affairs of cybersecurity in the SRI, we propose to replace “should” by “may” in the second sentence of this paragraph, so that the text would become as follows: “The smart readiness indicator may help to inform building owners and users of those risks.” - Article 6(5) on the optionality of the SRI The current text may lead to every Member State having a different approach to the SRI, which will result in the SRI being different from one country to another. As industry needs a uniform system throughout the EU, LightingEurope strongly urges to adopt a common approach. We therefore propose to adapt the first sentence as follows: “Member States may decide to terminate the implementation of the scheme at any time without providing any justification to that end.” In case any Member State, for whatever reason, decides to still adopt a system deviated from the SRI, it should be called something different than SRI and also be clearly distinguishable in other terms (e.g., rating, symbolism, etc.). - Annex I.7(b-g) on the SRI certificate This Annex is missing the formulas, removing the option to have an overview. It is therefore not possible to assess and comment this section. We need to be able to see the formulas before we can state whether this section can be supported or not. - Annex III on weighting of impact criteria The default values agreed upon in VITO’s Topical WG B on calculation methods should be included in this Annex. Without those values, this Annex will be difficult to implement. - Annex V on weighting of technical domains By giving Member States the possibility to determine their own weighting factors, a risk is created of an unequal SRI implementation from one country to another with a non-level playing field. This can be avoided by including the weighting factors that already have been agreed upon amongst a variety of stakeholders in VITO’s Topical WG B on calculation methods. Additionally, the Union guidance mentioned in this Annex should be included as an integral part of this Annex. - Annex VI on the services catalogue LightingEurope does not see a need for Member States to create their own smart services catalogue, as this will lead to a further fragmentation of the EU construction, renovation, and building market. In fact, there already exists a smart services catalogue that has been discussed, reviewed, aligned, and agreed upon between stakeholders and Member States during stakeholder meetings and consultations. This document was subsequently also tested, and there is a consensus on its composition. We therefore believe that it should at least be referred to in this Annex and made available on a publicly accessible (web)site, from where it can be updated, if needed, and also consulted by Member States and stakeholders. We also suggest removing Annex VI.5, as it will lead to fragmentation of the SRI across the EU and severely reduce its value. Please see the enclosed LightingEurope Position Paper for further information.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

5 Jun 2020

It is estimated that people spend approximately 90 % of their time indoors in residential and non-residential buildings. The yearly renovation rate of the building stock varies from 0.4 to 1.2 % in EU Member States. But if Europe is to fulfil its 2050 climate and energy goals, this rate will need at least to double to reach 3 % per year. Renovation is at the heart of the European Green Deal and has been identified as a key driver for the European society and economy post Covid-19. LightingEurope strongly supports the call for scaling up renovation rates across Europe. With 97 % of EU buildings in need of renovation, we believe that the upcoming Renovation Wave Initiative represents a unique opportunity to not only ensure the energy efficiency of buildings but also to address the wellbeing of occupants through a better indoor environmental quality, both of which lighting contributes to. LightingEurope recommends: 1) A focus on non-residential buildings (public and commercial buildings), as already set out in the Energy Performance of Buildings Directive. We believe that public buildings, in particular, should lead by example. 2) The use of LED lighting, in combination with controls and sensors. By switching from incandescent lamps to energy efficient LED lamps, it is estimated that Europeans have benefited from up to 90 % savings. Furthermore, lighting systems, in addition to allowing for large energy savings (see dedicated section), also offer significant benefits to the building users as regards their visual comfort, wellbeing, and productivity. 3) A full renovation of luminaires to include controls and sensors, with minimum SRI level – see below. “Just relamping” – simple replacement of a lamp – should be avoided. Replacing luminaires or introducing a whole new lighting design should be stimulated as this will lead to greater benefits in terms of energy savings and indoor environmental quality. 4) The Smart Readiness Indicator (SRI) should be applied across the EU to maximise its energy savings potential and capture all the benefits it can bring to the wellbeing and performance of building occupants. Renovations should lead to a certain minimum SRI score – see below. 5) The introduction of mandatory minimum requirements on Indoor Environment Quality (IEQ). Instructions for lighting can be found in EN 12464-1 and should be referenced to in the Renovation Wave Initiative. 6) Access to public financing should be subject to the fulfilment of certain conditions. An obligation to include lighting renovation to obtain full subsidy should be introduced. Conditions to be fulfilled: 1) Lighting should comply with EN 12464-1. 2) Use of controls and sensors, with minimum SRI level: • For lighting service 1a (occupancy control for indoor lighting), a minimum functionality level of 2 (automatic detection) should be required, as level 2 functionality is simple to implement and is based on established technologies that provide good additional levels of energy saving and user satisfaction as compared to level 1; and • For lighting service 2 (control artificial lighting power based on daylight levels), a minimum functionality level of 3 (automatic dimming) should be required, as level 3 functionality is simple to implement and is based on established technologies that provide good additional levels of energy saving and user satisfaction as compared to level 2. Please see enclosed paper for more information.
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Response to A new Circular Economy Action Plan

20 Jan 2020

LightingEurope represents the lighting manufacturing supply chain. The membership consists of 34 members, both companies that manufacture and supply lamps, luminaires, control gear and other materials and components for lighting products, as well as national associations representing such companies. Together we represent over 1000 companies in Europe, over 100.000 jobs and 20 billion Euro annual turnover. LightingEurope views the Circular Economy as a key opportunity for delivering growth and more value of lighting to society; it is one of the 4 pillars listed in the LightingEurope Strategic Roadmap for 2025. When applying the principles of the Circular Economy to lighting products, it is important to do it in the right way. As the industry transitions away from conventional technologies to LEDs, intelligent lighting systems and human centric lighting, LightingEurope members are working together to shape the framework for the circular economy for new lighting technologies, products, business models and supply chains. The attached position paper addresses the proposals included in the European Commission’s Roadmap on a Circular Economy Action Plan. It covers the points mentioned below: General recommendations 1) Balance information requirements. 2) EU product rules must be designed to consider product’s diversity. 3) Simplify EU rules. Existing EU Policies need to be aligned better, to avoid conflicting policies over the same products. 4) Increase enforcement of existing EU rules by supporting Member State Authorities to prevent harmful products from being placed on the market. 5) EU Policies must support the EU Industry as a Global Competitor. Recommendations for lighting products I. Our engagement to inform consumers: a pictogram for containing products II. What if a Sustainability Score is set for all products? For additional information on the LightingEurope pictograms for containing products on replaceability, LightingEurope guidelines on the Ecodesign Reg. 2019/2020 on light sources (check comments on art. 4 of the Regulation) are available at the following link: https://europeanlightingpriorities.eu/guidelines.php
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Response to Review of energy labelling requirements for lighting products

31 Oct 2018

LightingEurope, representing the lighting industry in Europe, would like to thank the European Commission for the opportunity to comment on the proposed review of energy labelling requirements for lighting products. LightingEurope welcomes the discontinuation of the label for luminaires, as we believe that it does not provide any relevant information when evaluating a luminaire and has no other benefit for consumers. We fully support the proposal to limit the energy label to light sources. LightingEurope proposes additional revisions in order to clarify the text and ensure the proposal is feasible and easy to enforce. The scope has to be reduced to end-user replaceable light sources that are not marketed as part of a containing product (except when they are offered for sale, hire, or hire purchase or displayed separately to the end-user, for example as spare parts). LightingEurope urges the legislator to exempt in particular emergency lighting from energy labelling obligations, including EPREL, as emergency lighting is not intended for illumination but rather to ensure the safety of humans in case of emergencies. We also recommend more flexibility when it comes to the labelling format. As the energy label has to be printed on the packaging and lighting products come in multiple shapes and sizes. LightingEurope recommends maintaining the option of a complete horizontal label and a greyscale complete label. LightingEurope is very concerned with the proposals for EPREL. Uploading product information related to hundreds of thousands of light source models, including lamps and modules sold between 1 August 2017 and 1 January 2019, is unfeasible in light of the current timeline and state of preparedness of the database, and may result in involuntary incompliance. The necessary guidelines and infrastructure does not yet exist for suppliers to start registering and uploading information. The current planning foresees that this will only be possible from 14 December 2018. Eight working days is too short for industry to upload all information before the deadline of 1 January 2019. Additionally, in the second phase of EPREL starting from September 2021, the information requirements in their current format go far beyond the necessity of informing end-users and market surveillance authorities about the energy usage of lighting products and the level of details is far too complex. We need a much more pragmatic approach for dealing with data requirement. We therefore propose to limit the information requirements to what is necessary for end-users to be informed about the energy usage of lighting products.
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Response to Review of ecodesign requirements for lighting products

31 Oct 2018

LightingEurope, representing the lighting industry in Europe, would like to thank the European Commission for the opportunity to comment on the eco-design legislative review for light sources, in which the Commission proposes important changes compared to the current legislation. LightingEurope fully supports the Commission’s Circular Economy proposals in Article 4 – the proposed rules provide clear requirements for manufacturers and for consumer choice. A mandatory removability requirement that applies to all lighting products and all lighting applications is not feasible and would have led to the unnecessary ban of lighting products that otherwise achieve the objectives of the circular economy in terms of durability, material efficiency, etc. LightingEurope supports increased enforcement of the eco-design rules and therefore proposes shorter and cheaper testing methods. The current testing method of 21 weeks (which is 5 months) is too long, and we propose further simplifying and introducing a 500 h or 1,000 h early failure test. Additionally, the proposed +/- 5% tolerances for luminous flux are industrially not feasible at all. Instead, LightingEurope proposes a one-side tolerance that is feasible for manufacturers and market surveillance authorities. LightingEurope calls for a more pragmatic and realistic timetable for the transition to substitute technologies and products. A premature phase-out of some lighting technologies (e.g. T8) will have a negative economic, social, and environmental impact on industry and end-users, including insufficient capital to invest in substitute technologies and products. This will increase precautionary purchases of old technologies, significant amounts of unnecessary waste and job losses due to a reduction of industrial activities in Europe. Another major concern has been brought forward by various other industries, which need specific lighting products for specialised industrial applications. Those irreplaceable light sources are at risk under the currently proposed eco-design requirements. Examples are standby requirements used in DMX/RDM applications for stage lighting, LED high luminance light sources in the entertainment industry, R7s halogen lamps for stage and studio lighting, and E27 halogen lamps for heating. Specialised applications have to be exempted under the list of special purpose lamps. Related to abovementioned is the need to align with other legislative reviews, in particular the revision of RoHS requirements. LightingEurope calls for a pragmatic and consistent transition timetable between eco-design and RoHS legislation when requiring a phase-out of lighting products from the market. Various editorial and technical corrections will be sent directly to the European Commission and the Member States in a separate file.
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LightingEurope calls for more efficient EU hazardous substance exemptions

12 Oct 2018
Topic — Evaluation of EU rules restricting hazardous substances in electrical and electronic equipment.
Message — LightingEurope requests an optimized application process to reduce the administrative burden on manufacturers. They advocate for increased transparency through progress updates and clear timetables for exemption reviews. They also seek better alignment between RoHS and other EU laws to eliminate overlapping requirements.1234
Why — Streamlined procedures would lower compliance costs and eliminate the business uncertainty caused by delays.56
Impact — Environmental advocates may see weaker protections if innovation justifications permit restricted substance use.7
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LightingEurope seeks longer lead exemption for medical lamps

16 Jul 2018
Topic — This consultation addresses environmental rules regarding lead use in discharge lamp phosphors.
Message — LightingEurope requests extending medical lamp exemptions until 2023 and immediate entry into force. They want to ensure necessary lamps are available to hospitals for skin disorder treatments.12
Why — The industry would gain legal clarity and uninterrupted access to the medical market.3
Impact — Hospital dermatology departments lose access to essential equipment if the exemption expires early.4
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Meeting with Miguel Arias Cañete (Commissioner)

12 Jul 2018 · Ecodesign

Meeting with Jyrki Katainen (Vice-President)

12 Jul 2018 · Eco-design

LightingEurope urges continued lead exemption for lamp marking

15 Mar 2018
Topic — The consultation concerns renewing RoHS exemptions for lead and cadmium in printing inks.
Message — LightingEurope requests adding lighting products to the exemption to fulfill legal safety obligations. They argue they are replacing lead but are not yet completely ready.12
Why — This would allow manufacturers to avoid costly and technically incompatible substitution requirements.34
Impact — Environmental groups lose because hazardous lead continues to be used in lamps.5
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Response to Review of energy labelling requirements for lighting products

23 Feb 2018

LightingEurope, representing the lighting industry in Europe, would like to thank the European Commission for the opportunity to contribute to the Impact Assessment on the energy labelling legislative review for light sources. We understand that the Commission’s proposals will introduce important changes compared to the current legislation. We understand that the Commission will propose to discontinue energy labelling of luminaires, currently included in the term “containing product.” LightingEurope welcomes the Commission’s proposal as we believe that a luminaire label has no benefit for consumers, as it does not provide any relevant information when evaluating a luminaire and it is not relevant when buying a different type of containing product (e.g. furniture or home appliance). LightingEurope calls on the Commission to undertake a detailed Impact Assessment of two particular aspects in the draft proposal: the impact of labelling on containing products and the impact of EPREL for lighting products. LightingEurope is still finalising detailed comments on the possible impact of labelling on containing products and will share it with the Commission as soon as possible. Concerning the impact of EPREL for lighting products, uploading product information related to hundreds of thousands of light source models, including lamps and modules sold between 1 August 2017 and 1 January 2019, is unfeasible with the current timeline and may result in involuntary incompliance. This situation becomes much more complicated now that containing products are being taken into consideration in the proposed Delegated Act. Containing products include several types of appliances with a light source, such as luminaires, furniture, household appliances, etc. Due to its wide scope and the complexity of the variety of actors involved, the total amount of containing product models cannot be calculated. The Impact Assessment on the Delegated Act on labelling should evaluate the following: 1) Impact of database requirements on Europe’s lighting manufacturing industry, with hundreds of thousands of products placed on the market every 6 months. The Impact Assessment should consider two scenarios in particular: a) introducing and maintaining all the information requirements currently proposed by the Commission; and b) introducing a limited set of data requirements (only those needed to generate the label) as proposed by LightingEurope. LightingEurope estimates that Europe’s luminaire manufacturing industry consists for 90 % of SMEs. 2) Additional costs and benefits of including luminaires that will probably go out of scope of the future energy labelling regulation in a period of 18 months. The Impact Assessment should evaluate if there is a clear value in uploading information concerning a category that will be out of scope with the next regulations.
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Response to Review of ecodesign requirements for lighting products

23 Feb 2018

LightingEurope, representing the lighting industry in Europe, would like to thank the European Commission for the opportunity to contribute to the Impact Assessment on the Ecodesign and Energy Labelling legislative review for light sources. We understand that the Commission’s proposals will introduce important changes compared to the current legislation. LightingEurope calls on the Commission to undertake a detailed Impact Assessment for two particular aspects in the draft proposals, based on the feedback received during the Consultation Forum of 7 December 2018: the phasing-out of some lighting technologies (mainly non-LEDs) and the introduction of Circular Economy requirements, as both will have a strong impact on industry and end-users. LightingEurope calls on regulators to adopt a pragmatic and realistic transition timetable to substitute technologies and products and to include Circular Economy requirements in legislation for lighting products. Concerning in particular Circular Economy requirements, LightingEurope proposes the introduction of requirements that are in line with those developed in CEN/CENELEC JTC10 and require removability for the purpose of verification by market surveillance authorities and recycling at end-of-life. For more information on LightingEurope's comments on the Inception Impact Assessment on Ecodesign requirements for lighting products, please consult attached file.
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LightingEurope urges EU to exempt cadmium quantum dots for lighting

1 Mar 2017
Topic — EU review of hazardous substance restrictions for lighting and display applications.
Message — The organization requests exemptions for cadmium-based quantum dots in lighting, citing significant reductions in energy consumption. They also propose clearer technical wording for existing display lighting exemptions.123
Why — This enables the lighting industry to commercialize efficient new products and recoup R&D investments.45
Impact — Environmental health goals are undermined by allowing hazardous cadmium in consumer lighting products.6
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