RETROFIT LEDtubes

Product complianceconsiderations andCE marking for significant
modifications

At Signify, we’re proud to take a leading role in sustainability.
Not just in terms of the products, systems and services we provide,
but also in the way we conduct our business. So, in addition todelivering light that is energy efficient, saves resources, andimproves lives, we are 100% carbon neutral in our operations andrecycle up to 91% of our manufacturing waste. We also uphold thehighest product compliance standards in all the markets in which
we operate.
As the global leader in lighting, Signify is also committed to theLEDification of the lighting market to support our sustainability
commitments – and deliver on the promises of our Brighter Lives,Better World 2025 program.

Our policy is 100% product compliance

We are committed to manufacturing and supplying
lighting products that comply with all applicable laws
and regulations imposed by relevant government
bodies.
It’s a promise that we do not take lightly. In orderto verify the safety and performance of ourproducts, we adhere to internationally-recognized
guidelines, such as those defined by the International
Electrotechnical Commission (IEC).

The importance of the CE markFor all products sold within the European Economic
Area (EEA), it is mandatory to display the CE mark.
This is a visible sign that the manufacturer of theproduct declares conformity with all relevant
essential requirements when it is operated as
stipulated in specification and design-in guides.
In terms of Signify’s lighting products, these relevant
requirements include the following Directives:• Low Voltage Directive (LVD) - for safety• Energy Related Products Directive (ErP) - for ecodesign requirements• Restriction of Hazardous Substances Directive(RoHS) - to restrict hazardous materials

Blue Guide: CE marking
According to the Blue Guide, the CE mark indicates,
but does not prove, that a product complies withEU product rules and conforms with harmonization
legislation when placed on the EU market until it hasreached the end user.
The aim of this legislation is to ensure thefree movement of products and a high level ofprotection throughout the EEA and Turkish markets.
This is irrespective of whether the product has
been manufactured in the EEA, Turkey or anothercountry altogether.

What about retrofit LEDtubes?

The responsibility for compliance is relatively
straight-forward when it comes to the safety andperformance of new products that are placed on themarket. But what about retrofit solutions? What are
your liabilities if you simply replace a conventional
lamp with a LED lamp?
A good example of this is Signify’s range of Retrofit
LEDtubes. These plug and play replacements
enable existing luminaires to be retrofitted with a
LED alternative in order to create a more energyefficient, longer-lasting and less costly solution.
Furthermore, less waste is generated as the existing
luminaire will still be in use.
As you would expect from the global leader in lighting,
we ensure that our retrofit solutions comply with
the ErP and RoHS Directives. In addition, they alsosatisfy other important considerations, such as
safety requirements. Our Retrofit LEDtubes havebeen tested and approved by an independent
third-party test house against EN/IEC 62776:2015 –Double-capped LED lamps designed to retrofit linear
fluorescent lamps – Safety specifications.
This harmonized standard specifies the safety andinterchangeability requirements, together with thetest methods and conditions required to demonstratecompliance. It is applicable for double-capped LED
lamps (with GS and G13 caps) such as LEDtubes
that are intended as replacements for fluorescentalternatives (with the same caps).
It is important to note that this safety standard
also covers the replacement conditions, as well as
the information and marking requirements for any
additional steps in the process. For example, if astarter needs replacing, or if a safety check needs
to be carried out to determine whether the wrong
combination of lamp and starter has been used.

Retrofit LEDtubes and modified luminaires

Significant modifications

Our assessment indicates that modified products
fitted with Retrofit LEDtubes do not significantly
impact compliance with the safety standards andtherefore no new conformity assessment is required.
But with the condition that installation and rewiring
must be done in accordance with the instructions
supplied by Signify.

If that is the case, when a significantly-modified
luminaire is made available again, it would therefore
require re-assessment to confirm compliancewith legislation. Depending on the risk level, thisis best done via conformity verification testing of
the modified product by a third-party test house.
Although it is not necessary to execute the full
conformity assessment, attention must be given towhat impact the modification has on the product.

There is also another scenario to consider. In somecases, double-capped LEDtubes may be used asa replacement for conventional lamps in existing
luminaires that have been modified in some way.
For example by being rewired to improve energy
efficiency. We have assessed this proposition
carefully to see if it still meets the requirements ofthe safety standards of the modified luminaire.

Please note: the execution of the rewiring is theresponsibility of the customer, not Signify, and should
always be carried out by a qualified professional,
as stipulated in our instruction guidelines.

Responsibility for compliance

It is clear from the Blue Guide that the manufacturer
or importer is responsible for ensuring a productcomplies with relevant EU regulations before placing
it on the market. When this is confirmed, the CE markcan be affixed, and the Declaration of Conformity(DOC) set up. Once that product reaches the end
user, it is no longer considered a new product andthe legislation no longer applies.
Maintenance activities, such as changing a lightsource or starter, or carrying out repairs, are notconsidered to alter the original function of theluminaire and therefore responsibilities and liabilities
remain the same. Even if original spare parts are nolonger available and have to be replaced by upgradedparts, this is still considered maintenance.

However, if a product undergoes significant
modifications, it might be considered as a newproduct. In this case, the installer can be consideredas the manufacturer since the new parts they
install will, in effect, create a new LED luminaire.
This responsibility only comes into effect when
the installer – after the significant modification –transfers the new LED luminaire to the new owner.

The modification instructions should ensure thatno new hazardous risks, such as safety or EMI, areintroduced unintentionally. The instructions should
also cover all reasonable aspects related to themodification. Examples of this include, but are notlimited to:• Modifications (in-field) carried out by qualified
professionals• Risks that may occur due to the modification andthe method of mitigation• Any restrictions that should prevent modification
being carried out• Verification checks after modification to confirm
to safety standards

Product change

Is it a new product?

New conformity assessment?

Real life example

Exchanging faulty components
or components that reach endof life.

No.

No.

-Exchanging a tubular fluorescentlamp with a LEDtube, which
complies to EN IEC 62776.

No. This is considered productmaintenance .

No. EN IEC 62776 defines allnecessary requirements toensure the safe retrofit ofTLED lamps.

Installer or building owner buys(retrofit) LEDtubes and change
them without any modification inluminaire.

Owner changes the productto significantly improve
performance e.g. higher lumen
output, or to add functionality
e.g. wireless control gear.

Yes. If the owner places theproduct on the market again.

Yes. By the party executing
the change.

Installer or building owner change
the luminaires significantly andplaced the luminaire back on themarket again.

No. If the product is modified forthe owner’s use (and there is nochange of ownership).

No. Product safety is theresponsibility of the owner
and installer. The original
manufacturer is no longer liable.

Installer or building owner buys
LEDtubes. Wiring change is madeby installer. Luminaire does notchange from owner.

Product is removed frommarket, is changed significantly(refurbished) and placed back on
the market. This means a changeof ownership.

Yes.

Yes.

Installer removes luminaires andchanges them significantly inworkshop. If the installer places theluminaire back into the ceiling, itmeans placing back on the market.

Table 1

Conclusion

LEDification plays a vital role in improving thesustainability of lighting products, systems andservices. Our assessment indicates that modified
luminaires fitted with retrofit LEDtubes do notsignificantly impact compliance with the safety
standards and therefore no new conformity
assessment is required. But with the condition that
installation and rewiring must be done in accordancewith the instructions supplied by Signify.
If you have any more questions regarding productdeclarations, or the performance and complianceof our products, please contact your sales
representative. We will be happy to help you.

Frequently asked questions
Q: What is the impact of plug and play retrofit LEDs
on safety and performance?
A: The electrical safety of the TLED is tested against
the applicable standard. In the case of a plug andplay retrofit, the performance impact is limited. It
may be necessary to check the weight and thermal
management of the retrofit TLED. When re-lampingwith modification (rewiring), the installation
instructions should be followed. In both cases, thatis plug and play or rewiring, the energy efficiencyof the LED solution will be better than that of aconventional light source.
Q: Is CE still valid?
A: The CE marking is voided after re-lamping witha TLED where previously used components(e.g. control gear) are removed. The CE mark is anindicator (but not proof) of a product’s compliancewith EU legislation and enables the free movementof products within the EEA and Turkish market.
It is the visible marking resulting from a conformity
assessment when placing on the EU market until
it reaches the end user. Note that ‘placing on themarket’ is an important criteria here. Together
with the CE mark, the European Declaration ofConformity (DoC) indicates that the product iscompliant with the applicable directives. The EU
DoC of retrofit LED lamps is available on request.
Q: What do I need to consider when replacing a lamp
for one with a higher lumen output e.g. switchingaT5 HE for a T5 HO or T5 UO?
A: When replacing a lamp in an existing luminaire,several aspects must be checked, amongst them
quality of light. This is also the case when using
TLED retrofits. The amount of light and the light
distribution may differ, and you should therefore
verify that they are still in line with the originallight plan.

Q: Who is liable?
A: In case of re-lamping the liability is very clear:
the manufacturer of the light source is responsible
for the light source and the manufacturer of theluminaires remains responsible for the luminaire.
When replacing with an upgraded product, forexample when old products are no longer available,
the liability remains the same. It is still considered
to be a maintenance activity.
When re-lamping with modification, the liability ison the owner of the lighting system that instructs
the installer to do the re-lamping (unless liability
is agreed with the installer company). The liabilityfor the supplied parts is the responsibility ofthe supplier. There is no need to draw up a new
conformity assessment and to (re)place a new
CE marking since there is no transfer of the ‘new’
product to the owner.
If re-lamping a TLED with modification falls under
the responsibility of the installer, the product willchange ownership (after the job has been done).
If this is the case – following the reasoning of theBlue Guide – it could be that a new conformity
assessment is required, and a new CE mark should
be added.
For a quick reference guide, please see Table 1.
Q: Is a warranty applicable?
A: When retrofitting a luminaire, in most cases, thewarranty of the luminaire will expire. The warrantyof the light source will still be valid if the installer
has followed the installation instructions.
Q: How will an insurance company handle incidents(e.g. fire) after modification of the luminaire?
A: If there is an issue, an insurance company inspector
will carry out an investigation on the status of theluminaire. For example if maintenance has been
done regularly and in the correct way by qualified
personnel. In the case of modified luminaires, theinspector will check whether the modification has
led to new hazards. They will also verify whether
the company requesting the modification had
done the correct assessments and supplied
proper guidelines to avoid any introduction of
new hazards.

©2021 Signify Holding. All rights reserved. The information provided herein is subject to change, without notice.
Signify does not give any representation or warranty as to the accuracy or completeness of the information
included herein and shall not be liable for any action in reliance thereon. The information presented in this document
is not intended as any commercial offer and does not form part of any quotation or contract, unless otherwise
agreed by Signify. Philips and the Philips Shield Emblem are registered trademarks of Koninklijke Philips N.V.
All other trademarks are owned by Signify Holding or their respective owners.
Signify 2019 5