·Compliance of those products that were potentially excluded due to (i) loopholes or (ii) difficulty in verification.

·Safeguarding the competitiveness of the European lighting industry and the full value chain;

The main indicator for evaluating the impact of potential ecodesign and energy labelling regulations is the achievement of a market improvement towards lighting products with a smaller environmental impact. An analysis of the products on the market (sales figures, performance, etc.) will determine if the shift towards more resource efficient products has happened as estimated, in particular based on the following sub-indicators, which reflect the general and specific objectives:

The main monitoring element will be the tests carried out to verify compliance with the ecodesign and energy labelling requirements. This monitoring should be done by Member States’ market surveillance authorities to ensure that requirements are met.

Minimum estimated value. The decrease in total administrative burden also stems from freed resources for other activities (for both market surveillance authorities and SMEs) which cannot be easily monetised. See Sections 6.5 and 7.2.

Table 16 gives an overview of the increment in costs, revenue and administrative burden at 2030 as compared to the baseline.

The ECOEL2021 option will also reduce the total consumer expenditure as compared to the baseline. This consumer expenditure includes the acquisition cost and the energy cost. The acquisition cost will be higher, but the energy cost will decrease significantly as compared to the baseline. In addition, this option will improve industry’s revenues significantly.

The burden for MSAs to assess compliance is significantly reduced by the new proposals. It is, however, assumed that MSAs spend the freed-up time on other market surveillance activities, contributing to higher compliance rates: thereby there is no monetary saving from reduced administrative burden for MSAs.

Option 3 – ECOEL2021 will reduce the total administrative costs for industry, especially for SMEs manufacturing luminaires following the abolition of the energy label for luminaires. Lighting industry will in general benefit from a simplification of the tests. These measures overcome the one-off cost linked to the application of the new Energy Labelling Framework Regulation which is estimated in EUR 0.34 billion and will not have an impact anymore in 2030 (see Section 6.4).

This section will describe how the preferred option is expected to improve the efficiency of the existing measures.

·Extra savings on annual end-user expenditure of EUR 7.7 billion and extra business revenue of EUR 1.1 billion per year, which translates into around 23 000 jobs;

·Extra energy savings of 41.9 TWh/yr and GHG emission savings of 14.3 MtCO2eq./a, i.e. 2.88% of the Commission’s 2030 target for final energy consumption savings and 1.34 % of the Commission’s 2030 target for GHG-emissions savings;

By 2030, compared to Option 1 – BAU, Option 3 will result in the following:

Option 3 – Ecodesign and Energy label at 2021 ("ECOEL2021") fulfils the criteria in Article 15(5) of the Ecodesign Regulation and Article 16(2) of the Energy Labelling Regulation, see Section 3.1, and will achieve the objectives as set out in Section 4 in the best way, see Section 5.2.3.

Option 1 – BAU does not contribute to any of the objectives. The other options contribute to the general objectives. Option 2 – ECOELOnly only contributes fully to two out of three specific objectives: it is therefore not seen as the preferred policy option. Option 3 – ECOEL2021 and Option 4 – ECOEL2tiers positively contribute to all objectives in the same way, except for the contribution to the EU 2030 goals and the specific objective ‘Update the energy efficiency requirements and the energy label in line with international and technical developments’. Here Option 3 performs best thanks to the earlier time of application of the new measures. As a consequence Option 3 – ECOEL2021 is the preferred option. More information on the benefits of Option 3 is included in the next section.

*Innovation will enhance competitiveness of the EU manufacturers; the effect on innovation is therefore included in this objective.

3. Contribute towards a circular economy in the EU by including requirements for non-dismountable products containing light sources

2. Redefine the scope and the exemptions to reduce the administrative burden and close loopholes

1. Update the energy efficiency requirements and the energy label in line with international and technical developments;

4. Increase the security of energy supply in the Union through a reduction in energy consumption of lighting products.

3. Promote the energy efficiency of lighting products as contribution to the Commission's objective to reduce energy consumption by 30 % and domestic GHG emissions by 40 % by 2030;

2. Promote competitiveness of the lighting industry through the creation or expansion of the EU internal market for sustainable products;*

An assessment of the options, in view the objectives in Section 4, is shown in Table 15 , on the basis of

All options with the new energy label (Option 2 EL2021, Option 3 ECOEL2021 and Option 4 ECOEL2tiers) fulfil the criteria of Article 16(2).

§The proposed bands of the energy label will differentiate among LEDs, which are today all concentrated in the top classes;

§The product group has significant potential for saving energy (See Figure 5: at 2030 the savings are equivalent to the electricity consumption of Slovenia in 2015);

Pursuant to Article 16(2) of the Energy labelling Framework Regulation, future implementing measures should fulfil a number of criteria, see Section 3.1. The criteria are fulfilled, namely:

Pursuant to Article 15(5) of the Ecodesign Framework Directive, future implementing measures should fulfil a number of criteria, see Section 3.1. An assessment of the options in view of these criteria is shown in Table 14 .

7.3.Assessment in view of Article 15(5) of the Ecodesign Framework Directive and Article 16 (2) of the Energy Labelling Regulation

As for the new verification tests that the proposals introduce, MSAs either have their own facilities for testing or rely on expert laboratories. In both cases, the new tests do not put extra burden on MSAs as the existing testing appliances are set or can be easily set to run the new tests. Stakeholders have emphasised the importance of securing a sufficient level of market surveillance to ensure that only compliant products are placed on the market. In this respect, they call for increased enforcement by MSAs.

The burden for MSAs to assess compliance is significantly reduced by the new proposals, as explained in the previous chapters. However, this would not mean a monetary saving from reduced administrative burden for MSAs: MSAs would spend the freed-up time on other market surveillance activities instead, thereby contributing to higher compliance rates for the overall ecodesign and energy labelling policy.

All proposed policy options would be subject to Article 15(8) of the Ecodesign Framework Directive, as well as Article 8(1) and (3) of Energy Labelling Framework Regulation, which require that MSAs can verify the conformity of a product with all regulatory requirements.

2 The variations due to measures in general occur from 2021, but for the Ecodesign measures there are anticipatory effects starting from 2019

Option 4 – ECOEL2tiers option is similar to Option 3 – ECOEL2021 but with the phase out of the fluorescent T8 lamps delayed in time. Due to this delay, it leads to lower energy savings, lower reduction in emissions, and lower user expense savings. The option seems preferable for business revenues and jobs in 2025 and 2030, but this is due to the shift in time: cumulatively over the period up to 2030 Option 3 is more favourable.

Option 3 – ECOEL2021 option offers the highest electricity savings and the highest reduction of GHG-emissions. It requires higher acquisition costs especially in earlier years (user investment in high efficiency LED products), but this is more than compensated by lower energy costs in later years, so that this option leads to the highest savings on total user expenditure. In general this option also entails the highest business revenues and the best preservation of jobs, concentrated in earlier years.

Option 2 – ELOnly option has the lowest additional acquisition costs and maintains installer revenues at the same level as the baseline, but energy savings, emission reductions and user expenditure savings are much smaller than in the other two options.

The worldwide impact on employment is estimated from the variations in EU light source business revenue, using a sector-dependent turnover per employee. Consequently, projections for jobs closely follow the projections in business revenues that were explained in Section 6.2.1. Similarly, these revenues are closely related to the acquisition costs for users, see Figure 9 . For further details on employment see Annex 6.

The analysis takes into account only jobs in the supply chain: induced employment from spending of e.g. employees’ earnings or tax revenues, is not included. A large share (estimated 60-70%) of the industry jobs, especially those related to LED light sources, is outside the EU28. Jobs for wholesale, retail, installation and maintenance are assumed to be all inside the EU28.

Table 12 gives an overview of the employment impact worldwide due to EU light source business. Jobs related to the sale and installation of luminaires are not included.

In Option 4 – ECOEL2tiers the phase-out of T8 linear fluorescent lamps is postponed by two years, and consequently also the increase in LED sales and the associated increase in jobs shift forward in time. This leads to additional jobs especially in 2025-2030.

In Option 3 – EL2021 the increase in jobs is gradual and due only to an increase in LED efficacy that brings an increase in the production of LEDs of higher quality than in the baseline scenario. In addition to the label effects, the LED sales increase in early years, leading to more jobs especially in 2020-2025. This effect vanishes by 2030.

The other scenarios accelerate the shift to high-efficacy LED products, leading to an increase in jobs worldwide. This partly avoids the loss of jobs that occurs in the baseline. The positive effect on wholesale and retail is inside EU28. A large part of the increase in industry jobs is outside EU28: the production of basic LED components is mainly done in Asia. The additional jobs in EU industry regard e.g. machinery for the production of LED components, the integration of LED components (dies, packages, modules) into higher level products (lamps, light engines, luminaires), development of new applications (smart lighting, network connected lamps, colour-tuneable devices, human-centric lighting), research and development for increase of efficacy and quality, involving also new optical and thermal solutions.

In the baseline scenario, the global jobs related to the EU light source business are projected to decrease from 314 000 in 2015 to 243 000 (-23%) in 2030. This follows the decreasing trend in sales and in business revenues discussed in Section 6.2. The decrease in jobs is mainly in EU28 industry, due to lower production of incandescent-, halogen- and fluorescent-lamps. Jobs in retail and installation decrease due to lower sales volumes, while jobs in maintenance increase due to the increase in number of light source in use.

Stakeholders view – Many stakeholders, especially Member States, consumers and their associations, welcomed the idea of a requirement to tackle the flicker effect and asked to think of a requirement for stroboscopic effect. Some consumers are concerned that LEDs emit more UV-radiation or have other potential health risks from blue light.. Stakeholders from the theatre/stage/studio sector would like to keep a full exemption for lighting used in their sector: however many comments assumed that at the date of application of the new legislation, theatres and similar would need to replace all lamps and luminaires (which is not true, because ecodesign and energy labelling only apply to the placing on the market of new products and not to products in use or in stock).

Finally, it is considered to introduce an exemption for the purchase of incandescent lamps with medical prescription for people that are photosensitive to LEDs, to meet their health concerns (despite studies found no significant or safety hazard from using LEDs).

It is also considered to introduce mandatory information on the date of production of light sources and control gears, wherever they are contained. Manufacturers are required to indicate the expected lifetime of the product, also following a high favour from respondents to the online public consultation (72% - see Annex 2).

Some stakeholders have raised functionality concerns as regards e.g. colour tuneable lamps and some special purpose applications, including lighting in railways and studio, theatre and stage lighting. These comments have been taken into account for the formulation of exemptions in the ecodesign measures in Options 3 and 4.

LEDs are sometimes criticised to have flicker or stroboscopic problems, colour inconsistency or bad colour rendering. Especially the problem of flicker has been confirmed for many lamps during screening testing carried by the EU-funded project EEPLIANT which was finalised in 2017. Following comments at the Consultation Forum and from the online public consultation that ran until 7/5/2018, Option 3 – ECOEL2021 and Option 4 – ECOEL2tiers include functional requirements for flicker and stroboscopic effects for LEDs to improve the quality of LEDs on the market.

Stakeholders view – In relation to the phase-out of T8 linear fluorescent lamps, some stakeholders argued that for organisations managing large quantities of such lamps, the investment to make in LEDs would be too high to bear in such a short time. This is a misunderstanding of the intention of the regulation, i.e. there is no obligation to replace all installed LFL T8 by LED before the date set in the regulation: lamps can gradually be replaced when they fail, over a much longer period, thus spreading out the costs.

On the other hand, both options that would introduce new requirements for ecodesign (Option 3 – ECOEL2021 and Option 4 – ECOEL2tiers) do not change the requirements for LFL T5, HPS and MH that exist today: consequently, nothing changes for the users of these lamps. The reason for this choice is that many non-residential lighting users recently invested in luminaires for higher efficiency T5 linear fluorescent lamps (LFL T5), or for sodium or metal-halide lamps (HPS, MH), to replace lamp types that were phased-out by existing regulations. It would not be acceptable to force these users to change again before they have amortised their previous investments. In addition, LED replacement lamps (also known as “LED retrofit lamps”) for these classical lamp types are scarce so that users would often be forced to substitute entire luminaires.

This investment is payed back in later years in terms of lower electricity costs, leading to the total user expense savings reported in Section 6.3. On average, payback times are around 1 year or less for low-output residential lamps, and around 3-4 years for higher-output LED tubes replacing T8 linear fluorescent lamps.

To obtain the energy savings and reduction of GHG emissions, users have to invest in more, and more efficient, LED lighting products. Compared to the baseline, this leads to additional acquisition costs (see Section 6.3). For the EU as a whole, for the ELOnly option these are maximum 1.8 billion EUR/y in 2026 (EUR 3.6 per citizen; +17% vs baseline in that year). For the ECOEL2021 option the maximum is EUR 4.2 billion per year in 2022 (EUR 8.4/citizen; +31%), and for the ECOEL2tiers option EUR 3.7 billion per year in 2024 (EUR 7.4/citizen; +32%). See also the graphs at the end of Annex 4.

Conversely, the rescaling of the label of products on the market as required by the Energy Labelling Framework Regulation (EU) 2017/1369 would bring new costs in Options 2 – EL2021, 3 – ECOEL2021 and 4 – ECOEL2tiers. It is estimated that suppliers and dealers will encounter extra costs of respectively EUR 30 million and EUR 4 million. Suppliers will need to provide a second label for the products to rescale for each light source that will stay on the shelves of dealers after nine months (an estimated 10% of products), while dealers will need to relabel with stickers and 2.5 % of their products on display.

In addition, the simplification of tests in Options 3 and 4 will reduce the number of tests and eliminate tests that lost relevance by time. The impact on the industry from the new tests for LEDs is estimated to be negligible because the existing testing appliances are set or can be easily set to run the new tests. The same is valid for MSAs (see in Section 7.2).

The reduced burden will come not only from the abolition of the label but also from the abolition of the obligation to insert data in the products database EPREL introduced by the Energy Labelling Framework Regulation (EU) 2017/1369. Between 1 million and 3 million model luminaires are estimated to need a label today. Based on Eurostat data for year 2016, around 250 million luminaires are sold each year in EU28. With the revised energy labelling, only the fully integrated luminaires would be assimilated to light sources and thus added to the list of light sources that need to have an energy label. It is estimated that savings for SMEs will be at least EUR 35 million. Moreover, increased turnover should also be considered.

Indeed, Options 2 – EL2021, 3 – ECOEL2021 and 4 – ECOEL2tiers propose the abolition of the energy label applicable to luminaires. This measure will save costs and reduce burden for luminaires’ suppliers – 90% of which are SMEs. The burden will be reduced because of the fact that SMEs will not need to prepare the label and ensure its conformity, also in view of possible surveillance by market authorities.

The administrative burden for industry and MSAs is an area that could be improved in the current legislation, as explained in Section 2.2. With the new regulations proposed in Options 2 – EL2021, 3 – ECOEL2021 and 4 – ECOEL2tiers, the total administrative burden will decrease, especially for European SMEs.

Option 3 – ECOEL2021 requires the highest investment in LED products, concentrated in earlier years, cumulative EUR +30 billion (+20%) vs. Option 1 – BAU over the period up to 2030. However, the same option also leads to the highest energy cost savings, increasing in later years, cumulative EUR -52 billion (-7.8%) vs. Option 1 – BAU, and therefore has the highest user expense savings, cumulative EUR -21 billion (-2.4%).

Consumer expenditure consists of acquisition costs (purchase and installation), maintenance costs and electricity costs. Maintenance costs are assumed not to change between the options. The options different from the baseline promote a shift to LEDs and this causes additional acquisition costs in early years. This initial investment made by users is gradually paid back in later years through lower electricity costs. The acquisition cost, energy cost and overall consumer expenditure for the different scenarios are shown in Table 11 and Figure 8 . Table 11 shows that the overall effect in 2030 for consumers when considering acquisition costs and electricity costs is positive for all options. See Annex 4 for further details.

The technologies considered in all scenarios are commonly available to all major manufacturers.

The development of innovative energy-efficient technologies at competitive prices will enhance the competitiveness of European manufacturers. This is important because Asian manufacturers are rapidly expanding their global market share. For these manufacturers, product price, rather than quality, is one of the main selling points.

All LED technologies are today in the three top energy labelling classes. A new labelling scale based on the re-scaling required in the new energy labelling framework regulation will stimulate innovation to develop LEDs that will reach the new top classes.

The revision of the lighting energy labelling regulation is expected to support innovation and drive market transformation, as was observed in the past. It is in line with ongoing market trends towards higher energy efficiency, where a high energy label rating is a strong commercial driver (Review Study 2016).

Cumulatively over the period up to 2030, increases in revenues have the highest value for Option 3 – ECOEL2021: EUR 29 billion (+13%). The same explanation also applies to associated jobs, which are directly related to revenues (see Section 6.5.3).

In Option 4 – ECOEL2tiers, the phase-out of T8 linear fluorescent tubes is postponed from 2021 to 2023, and consequently also the associated increased sales of LEDs and the corresponding increase in business revenues shift forward by two years. Increases in business revenues in Option 4 are therefore much smaller than those in Option 3 in 2020, but higher in 2025 and 2030.

In Option 3 – ECOEL2021 this leads to higher total business revenues especially in early years, with, respect to Option 2 – ELOnly, a 5% increase in 2020, 9% increase in 2025, and a 2% decrease in 2030. Considering only industry revenues, the increase is 10% in 2020, 18% in 2025, and zero in 2030.

The same effect of improved labelling is also present in Option 3 – ECOEL2021 and Option 4 – ECOEL2tiers, but additionally the introduced Ecodesign measures increase the number of LED light sources being sold, by phasing-out from the market some traditional lamp types. This situation further increases business revenues due to an increase in sales quantities, with anticipatory effects from 2019. Different from the labelling effect, this increased-sales effect is temporary: instead of a gradual shift to LEDs in the base line, the Ecodesign measures accelerate the LED sales in earlier years, but then lead to lower sales of LEDs in later years.

The effect of Option 2 – ELOnly is an increase in the average efficacy of LED products being sold (pull-effect of labelling). Starting from 2021, compared with the baseline, this increases the average price per light source and thus increases total business revenues by 9-11% in 2025 and 2030 relative to the baseline scenario.

In the baseline option, business revenues show a decreasing trend due to the decrease in sales quantities. In ten years, from 2015 to 2025, total business revenues from light sources decrease from EUR 21.6 to 17.0 billion per year (-21%). In the same period, industry revenues decrease from EUR 9.7 to 6.3 billion per year (-35%). Towards 2030, revenues slightly increase again due to the general growth in the number of light sources (first point above).

The assumptions made in the analysis model regarding the development of the sales quantities and of the average unit prices are reported in detail in Annex 4. They lead to the business revenues shown in Table 10 . Figure 7 shows the projected industry revenue for the different policy options.

-However, the proposed regulation aims at increasing the average efficacy of LEDs being sold, and these high-efficient LEDs have a higher sales price.

-Due to the learning effect and the exponential increase in the quantities of LEDs being sold, their price is rapidly coming down and this trend is expected to continue in the BAU scenario (Option 1).

-Energy savings and GHG emission reductions for light sources are obtained by a shift from traditional lighting technologies to LEDs with higher energy efficiency. For the same light output, these LEDs have higher acquisition costs (but lower electricity costs) than the traditional lamps. So the shift to LEDs potentially implies a higher average sales price per lamp.

-However, at the same time the average lifetime of light sources is increasing. This implies a lower need to buy replacement lamps and thus a decrease in sales. At least for the next 10 years, this decrease is stronger than the increase deriving from the general growth of the previous point. Hence on the short-medium term, sales quantities of light sources are going down.

-There is a tendency for the number of installed light sources to increase with the years (more households, more light sources per household, increasing GDP). This potentially indicates an increase in sales quantities.

Business revenues mainly depend on the quantity of products being sold and on their average price. For light sources there is a complex interaction between factors that increase and decrease the revenues:

Currently the lighting equipment in scope of the WEEE Directive represents 5% of the total electrical and electronic equipment placed on the EU28 market annually and 2% of the total WEEE collected and recycled annually.

•for small luminaires (category 5): 75 % shall be recovered, and 55% shall be prepared for reuse and recycled.

•for large luminaires (category 4): 85 % shall be recovered, and 80% shall be prepared for reuse and recycled;

•75 % shall be recovered, and 55 % shall be prepared for reuse and recycled (for gas discharge lamps, 80 % shall be recycled);

The producers of the lighting equipment in scope of the WEEE Directive are in charge of meeting recycling and recovery targets that increase over time:

As for recyclability, this impact assessment does not explore measures for the recyclability of lighting products because lighting products are already in scope of Directive 2012/19/EU on waste of electric and electronic equipment (WEEE).The WEEE Directive introduced in August 2018 new recovery and recycling targets, including for lighting products. Until 14 August 2018 the lighting equipment in scope of the WEEE Directive includes all lamps, with the exception of filament bulbs, and all luminaires, with the exception of luminaires in households (Annex II of the WEEE Directive, Category 5). From 15 August 2018 the scope is enlarged to all luminaires, with specific requirements for large and small luminaires (Annex III of the WEEE Directive, Categories 4 and 5).Because of the close date of application of the new WEEE target for lighting products, it is deemed more relevant to look into requirements that would complement the WEEE directive in the next review of the ecodesign legislation.

Even though the Circular Economy dimension is not directly addressed, the proposed requirements for non-dismountable luminaires are in the spirit to promote circular economy because they will: (i) resolve the problem that market surveillance authorities have to test light sources when these are not accessible; (ii) resolve the issue of an unfair level playing field for industry when the same light source type is accessible; and (iii) support consumers in their conscious choice when buying integrated luminaires.

The proposed requirements address the problem of non-dismountable luminaires in an indirect way. In 2017 the Commission checked the possibility to have mandatory removability of light sources from luminaires, but there are technological drawbacks. Many luminaires are manufactured so that LED light sources are tightly mechanically integrated to optimise thermal management and for protection purposes. The side effect of this technology solution is that the unsealing and resealing of LED lights in the luminaire may hamper their energy efficiency. A way forward would be to include a review clause in the legislative proposal to investigate mandatory removability of light sources from luminaires, which will impact recyclability as well.

The aim of the proposed requirements is to stimulate manufacturers to find innovative solutions and design for dismountable luminaires using LEDs. Better design can make products more durable or easier to repair, upgrade or remanufacture. It can help recyclers to disassemble products in order to recover valuable materials and components. Overall, it saves resources. The current market signals appear insufficient to make this happen, in particular because the interests of producers, users and recyclers are not aligned. In addition, reparability can be important to consumers. It is therefore essential to provide incentives for improved product design, while preserving the single market and competition, and enabling innovation through ecodesign.

For material resources efficiency, all options, except the baseline option, introduce clear requirements to address the phenomenon of fully integrated luminaires as explained in Section 2.3 and Section 5.2.2. As for energy labelling, luminaires with non-dismountable light sources will be considered as light sources for the purposes of the energy labelling legislation and will be required to have an energy label. As for ecodesign, in the two options that have ecodesign measures (Options 3 ECOEL21 and 4 ECOEL2tiers), luminaires with non-dismountable light sources will be considered a light source for the purposes of the ecodesign legislation and will need to satisfy the ecodesign requirements.

The environmental life-cycle assessments in the Review Study 2015 show that the energy consumption and the related emissions are by far the dominant environmental impacts for this product category.

Similar to the energy savings, the largest reduction of emissions is obtained in the ECOEL2021 scenario: 14.3 MtCO2eq./a less than in the baseline in 2030 (-14%). Cumulative over the period up to 2030 the savings amount to 94 MtCO2eq. (-6.9%).

The emission reduction in the baseline relative to 2015 thus reflects the energy savings in the same scenario: 11 MtCO2eq./a (8 %) in 2020, 21 MtCO2eq./a (16 %) in 2025, and 31 MtCO2eq./a (23 %) in 2030. The GHG emission savings projected for the different scenarios are given in Table 15.

Figure 6 shows the EU GHG-emissions due to lighting for the different policy options. As these emissions are those occurring during electricity generation, the trends are similar to those for energy consumption presented above. The main difference is that for the energy scenarios, by convention, a primary energy factor of 2.5 (according the Annex V of the Energy Efficiency Directive (Directive 2012/27/EU) is used, whereas for the projections of the GHG-emissions changes in carbon-intensity of electric power generation are taken into account.

Cumulative over the period up to 2030, the highest energy savings are obtained in the ECOEL2021 option: 267 TWh or 7.1% less than in the baseline.

In the ELOnly option (labelling only) savings vs. the baseline in 2030 are 11.5 TWh/a (-3.8%). 11.5 TWh/y is almost equivalent to the total final electricity consumption of Slovenia in 2015. Adding the ecodesign measures, the savings increase to 41.9 TWh/a (-14.0%) for ECOEL2021 and to 40.1 TWh/a (-13.4%) for ECOEL2tiers. The difference between the two Ecodesign options is the effect of the two year postponement of the phase-out of T8 linear fluorescent lamps. The labelling measures represent 21% of the total energy savings in 2030 from energy label and ecodesign combined together (40-42 TWh/y depending on the Ecodesign option).

In the other options, compared to the baseline, additional energy savings are obtained, due to the increase in average LED efficacy (labelling), and due to the accelerated shift to LED products (ecodesign). The annual savings increase with the years, as the installed stock of light sources is gradually being replaced by more efficient models.

The baseline already shows decreasing energy use. This reflects the continuing effect of existing regulations and the general trend in the market, which anyway includes a gradual shift to higher efficient LED products. Relative to 2015 the reductions are 16 TWh/a (-4.8 %) in 2020, 24 TWh/a (-7.1 %) in 2025, and 37 TWh/a (-11 %) in 2030.

Figure 5 shows the EU final energy (i.e. electricity) consumption of light sources for the different policy options. This includes energy consumption by control gears. The projected savings for the different scenarios vs. the baseline are given in Table 8 .

The analytical methods used to determine the impacts are described in detail in Annex 4.

More generally, the MELISA model has been used not only in the study on lighting products, but also in the Ecodesign study on lighting systems and in the study on the impact of RoHS-measures on light sources. The industry organisation LightingEurope examined the model in detail and largely supports it. This shows that there is confidence in the robustness of the model data.

Third, as regards lighting in non-residential buildings, there is uncertainty about the average annual operating hours for lighting. The MELISA model could not be used because MELISA follows a conservative approach with relatively low operating hours, meaning that non-residential electricity consumption and savings might be underestimated. To overcome this problem, a separate estimate of the electricity consumption was made by using a completely different methodology. This used the building areas per type of space/activity derived from the Building Heat Demand report, lighting level requirements per type of space/activity from standards, and parameters and procedures from standard EN 15193. Following this method, using higher non-residential operating hours would not change the choice of the preferred option, but rather reinforce it.

A second factor is the uncertainty about the future development of electricity prices. MELISA uses the price projections from the MEErP (with a 4% annual escalation rate), while the PRIMES projection for electricity prices have a much lower escalation rate. However, a sensitivity analysis was performed using the PRIMES process for all options and the results are reassuring: the overall trend is confirmed and the classification of the options according to their monetary savings does not change when using PRIMES electricity rates instead of MEErP electricity rates (see Annex 4.9).

As regards the main limitations, risks and uncertainties of MELISA, the methodology itself (largely based on the MEErP) is sound, but as with any model, the results depend on the quality of the input data. The data was extensively checked during the review study and largely agreed with stakeholders to mitigate the risk from the quality of input data.

Greenhouse gas (GHG) emissions are directly related to electricity consumption by means of the Global Warming Potential (GWP) for electricity.

MELISA derives the installed stock of light sources in the EU28 from data on the annual sales and on the average useful lifetimes. These stock data are combined with average unit power values (W) and average annual operating hours per unit (h/a) to compute the total electricity consumption per base case (TWh/a). The contributions of the various base cases are summed up to arrive at the EU28 totals for all sectors. The shift in (light source) sales from the classical technology base cases to the LED base cases of the same group is one of the essential elements in the scenario projections in MELISA.

The scenario analysis for this impact assessment has been performed using the ‘Model for European Light Sources Analysis’ (MELISA). The input data for the model (e.g. annual sales volumes, average luminous flux, power and efficacy, light source prices, etc.) have been extensively checked against other data sources and discussed with stakeholders. In July 2016 this resulted in an updated MELISA version, incorporating new input data supplied by industry association LightingEurope , and implementing an enhanced method to compute the installed stock of light sources from the annual sales and (variable) lifetimes. A further update took place in October 2017 as regards the projections for the development of average LED efficacy and price. The projection curves were adapted to match the average LED efficacy derived from 2015-2017 catalogue data and taking into account recent projections from UNEP and US DoE . A separate projection curve was created for directional lamps. In addition, electricity rates were updated from Eurostat data.

To address the gaps in the methodological framework, the Commission mandated CEN/CENELEC to develop standards for material efficiency under ecodesign and a first set of horizontal standards is expected next year, in 2019. These will be integrated in the MEErP methodology as appropriate. A broader update of the MEErP is foreseen in 2019, in particular to see how circular economy aspects could be better integrated in preparatory and review studies, and the LLCC calculations.

Although a fully quantified impact assessment of such requirements has not been possible at this stage, a qualitative impact assessment was made, based on inputs taken from technical, scientific and policy-making literature, and nascent evidence from other similar product groups. This forms the basis of an assessment, which can be refined over time in due course, to be supplemented with actual quantitative data collected via the monitoring and the evaluations. These data will also serve at the time of the next revisions of the product regulations.

There is also a lack of methodologies to ‘quantify’ the costs and benefits of such criteria in the context of the ‘least life cycle cost’ (LLCC) calculations applied for energy efficiency in ecodesign, in particular as regards the assessment of trade-offs.

Therefore, the ‘circular economy’ requirements that are proposed are based in particular on stakeholder input, existing studies and evidence of product failure (e.g. on spare parts), and focus on measures that can be relatively easily implemented. As such, they can be considered a starting point that can subsequently be complemented or refined when the methodological tools are available.

With the adoption of the Ecodesign Working Plan 2016-2019 in November 2016, the Commission committed for the first time explicitly to systematically exploring resource efficiency requirements in ecodesign. As a result, the methodological basis for the inclusion of such requirements is not yet fully developed; there are no well-established and accepted methodologies in place to identify requirements in the context of mandatory legislation (contrary to green public procurement, ecolabels, etc.).

3. Last but not least, the EU legislator already decided on framework legislation governing this initiative. Lighting was identified as a priority group for the rescaling of the energy label by 2 November 2018 (Regulation (EU) 2017/1369). An "Ecodesign only" option would have to be discarded anyway to comply with framework Regulation.

2. Without an update label, consumers will not be able anymore to make an informed choice based on energy-efficiency performance. As shown in Section 2.1, today the top three energy efficiency classes of the energy label are overpopulated: they cover 66% of the models and all LEDs are in these three classes. By 2020 over 50% of LEDs will be A++. In conclusion, there is still significant difference in energy efficiency between the products remaining on the market to justify an energy label. Without an updated energy label, consumers will base their choice solely on price and the pull mechanism created by energy labelling will disappear.

1. Over 11 TWh of electricity savings at 2030 would be missed if the energy labelling measures were not updated (see Section 6.2.1 for details);

The Ecodesign only option would introduce new measures for ecodesign only and leave unchanged the current legislation for energy labelling of lighting products. This option was discarded for the following reasons:

Stakeholders view: Relevant stakeholders, including industry and some Member States normally known to support ambitious environmental policies, commented that September 2020 would be too early to implement the proposed requirements. See Annex 5 for the minutes of the Consultation Forum.

At first instance, the European Commission suggested at the Consultation Forum of December 2017 to apply Option 3 described in Section 5.2.3 as of September 2020, i.e. a year earlier than what is presented in this Impact Assessment. The main reason for discarding this option is to allow one more year for more good quality LEDs to come to the market that would replace the proposed-to-be phased out technologies, especially fluorescents. The phase-out of fluorescents would be as important as the ban of incandescents that happened from 2009. Fluorescent lamps well served the purpose to help with the phase-out of energy-inefficient incandescent lamps, but fluorescents have not been adopted as expected because of (real or perceived) sub-standard performance (e.g. colour rendering and temperature, ignition time, mercury hazards). Consumers bought less energy-efficient halogen lamps instead. As LEDs would play the role to replace fluorescents, like fluorescents played the role to replace incandescents, it is important not to ban fluorescents too early.

Stakeholders view: Almost all stakeholders, including some environmental NGOs, agreed that the timing to phase out from the market all non-LED lights was too demanding. Some among the most environment-friendly stakeholders proposed to add to the new legislation an only-LED set of requirements at a later stage (2023 or 2024).

However, there are several reasons why an only-LED choice at this point would not be feasible. First, despite LED-lamps enjoying considerable commercial success, there is the legacy of an existing park of light sources, control gears and luminaires. More importantly, there are still applications for which LEDs are not yet suitable. Second, for large investments in lighting, professionals may also encounter problems in obtaining loans, as lenders thoroughly scrutinise any investment that is higher than the bare minimum on payback and return-on-investment. Finally, many businesses were incentivised by government programmes to invest in efficient fluorescent lamps (especially the “T5”) only a few years ago and need time to recuperate their investments. The same goes for municipalities that invested in new city street lighting after the phase out of high pressure mercury lamps from April 2015.

The Ecodesign Framework Directive states that minimum efficiency requirements shall be set at the level of Least Life Cycle Costs (LLCC), relating to the economically most advantageous proposition for end-users. The 2015 Review study shows that for most household applications, LEDs already have the lowest life cycle costs. For professional applications, e.g. office lighting and street lighting, it depends on the application, but in many cases the classical technologies (fluorescent and high-intensity discharge lamps) still offer the lowest life cycle cost. This is expected to change by 2020, when payback times for an investment in LED for these applications will come down to two-three years. Hence, according to the LLCC-criterion, the minimum required efficiency for ecodesign could be set at a level that only LEDs would meet.

Stakeholders view: None of the stakeholders are in favour of voluntary agreements for the reasons set out above.

A voluntary agreement has to be given priority according to the Ecodesign Framework Directive, provided it meets the objectives in a quicker and more cost-effective manner. Today minimum mandatory requirements are already in force. Since no proposal has been put forward by industry, there is no voluntary agreement that meet the conditions of the Ecodesign Framework Directive. As a consequence, this option is discarded from further analysis. When substituting mandatory requirements by a voluntary agreement there would be a risk of free riders, in case not all actors present on the market would sign such an agreement and comply with it.

Stakeholders view on Option 4 – ECOEL2tiers: Part of the industry and a minority of Member States expressed preference for postponing the phase-out of T8 lamps to 2023, in particular to allow a smoother transition in some sectors. The majority of Member States supports an earlier phase-out together with targeted exemptions for problematic sectors. NGOs and consumers ‘associations oppose a late phase out of T8 lamps.

Option 4 is identical to Option 3, apart from the fact that it implements the requirements for T8 fluorescents two years later, i.e. in 2023 instead of 2021. The phase out of T8 lamps is the most relevant of the ecodesign measures: it would deliver 90% of the energy savings from lighting products in 2030. Postponing the phase out of T8 lamps would give the industry some extra time to prepare for the phase-out of T8 fluorescents, but it will come at a cost in terms of lower energy and emission savings, as explained in Section 6: it would mean missing 2-3 TWh of savings per year of postponement (for comparison: the electricity consumption of Malta in 2015). Many lighting companies are already commercialising LED replacements to T8. Lighting designers confirm that the vast majority of new installations use LEDs.

Stakeholders view on Option 3 – ECOEL2021: Stakeholders support the revision of both ecodesign and energy labelling regulations. At the online public consultation on the revision of lighting legislation that ran until 7/5/2018, a high majority of respondents (75%) supported to update ecodesign measures for lighting to take into account technological development (only 11% answered no, see Annex 2). For non-LED light source types, stakeholders generally support to keep on the market HID, LFL T5, CFLni and to phase out CFLi and almost all remaining halogens. Stakeholders also support the take up of good quality LEDs. The timing for the phase out of T8 fluorescents is the most sensitive point, as some stakeholders question the availability of LED replacements for all applications using T8, but the date of September 2021 and targeted exemptions tackle most concerns of stakeholders (see the discarded option that proposed measures at September 2020 in Section 5.3.3).

Energy labelling has in scope light sources. For fully integrated luminaires, the same as for ecodesign applies. Not all the products that are exempted in ecodesign would be exempted in energy labelling: this is to allow consumers to know the energy consumption of as many light sources as possible that are on the market.

Measure 7: Fully integrated luminaires to be treated as light sources – Luminaires (more generically ‘containing products’) are not in scope of the current ecodesign legislation, but the light sources and separate control gears used inside them have to comply with the current ecodesign legislation. To enable verification of these contained parts, and for reasons of material resource efficiency (circular economy), this measure would provide for fully integrated luminaires to be considered as light sources for the purposes of the ecodesign regulation when the luminaire cannot be dismounted without mechanical damage. Fully integrated luminaires would be considered as light sources also for the purposes of energy labelling.

Verification tolerances are made more specific, i.e. no longer a general 10% tolerance but a differentiation in the range of 2.5% to 10%, depending on the type of light source, parameter and possibly the power range. The number of test samples is reduced to 10, instead of 20. For expensive light sources the number of samples can be reduced to 3.

The procedure to be used by market surveillance authorities for compliance verification has been aligned with the common procedure for other Ecodesign products as introduced by Commission Regulation (EU) 2016/2282 .

Measure 5: Simplified tests – The tests to ensure the conformity of the products with the requirements are considerably modified, with the aim to reduce the burden on industry and help MSAs in their surveillance. The modifications to the tests are not lowering the ambition of the legislation. The main change is for the endurance testing: the proposed test will last half the time of the current one (3000 h vs. 6000 h) and will combine two tests which were developed in recent years (switching test and accelerated endurance test). The new endurance test will be for LEDs only. Other tests include the displacement power factor (limiting the disturbance of the electricity grid by LEDs), colour rendering index (ensuring good colour rendering for indoor light sources), colour consistency (limiting colour differences between LEDs of the same type), and flicker (ensuring absence of visible flicker for LED light sources). The proposal removes tests that have progressively lost their relevance (notably the start time test typical for fluorescents).

Measure 4: Redefined scope and exemptions – Under this measure it is proposed to drop the criterion of “intended use” to define "special purpose lamp" and to replace it with clearer specifications to define what is exempted and what is in scope of the legislation. Exemptions, including for ‘special purpose lamps’, would depend on measurable parameters (spectrum, light-emitting surface area, luminous flux <60 or >100 000 lm, etc.), exclusive use for certain applications or certification. As a specific example, in the case of stage/studio/theatre lighting the exemption for tungsten lamps would be based on the socket type: this would avoid installations of specific lights for stage/studio/theatre in residential apartments, as explained in Section 2.2.

Measure 3: Updated formula for ecodesign – The proposed solution for ecodesign requirements on light sources that are today spread over three regulations entails a single formula defining the maximum allowed input power as a function of the emitted luminous flux. The formula uses two constants (and L) whose values differ per light source type (see Table 7). In addition, there are three correction factors: F for use of flux in a cone instead of total flux (directional vs. non-directional light sources), R to reflect the influence of colour rendering characteristics (bonus for light sources with good colour rendering; penalty for bad colour rendering), and C as a correction factor (bonus) for special characteristics (see Annex 10).

Light sources that are no longer allowed on the market because they cannot meet minimum efficiency requirements of existing regulations will remain banned under the new regulation, i.e. there is no backsliding of requirements.

For control gears, the minimum efficiency requirements for halogen-, fluorescent- and HID-gear remain the same. The efficiency requirements for LED-gear are new.

Table 7 shows which light sources would stay on the market as an exception to the general minimum efficacy requirement and the values of constants  and L per type. For these light sources the minimum required efficacy is defined using the same maximum power formula, but with different values for the constants  and L. As a result, the required minimum efficacies are lower than the general requirement. As Table 7 shows, the constants  and L are in most cases tuned to closely match the existing requirements (where it reads "same level"). In practice nothing changes for these lamps compared to today. Where instead it reads "new", those lamps will still be allowed on the market, but with a higher minimum energy efficacy than today.

As exceptions to the general minimum efficacy requirement, T5 fluorescent light sources (mainly office use), high-intensity discharge light sources (mainly street lighting and industrial use), compact fluorescent lamps without integrated control gear (mainly tertiary sector) and linear halogen light sources (R7s cap) with less than 2700 lm light output (mainly household use) would continue to be allowed on the market. These light sources are not phased out because adequate higher efficiency LED light sources are not yet commonly available or not yet economically advantageous for the average user. Keeping lamps like T5 on the market avoids that users are requested too soon to switch again to another technology, following the application of the most recent ecodesign requirements.

All other light sources which are not listed in Table 7 (including LEDs) and which do not meet the general minimum efficacy requirement based on the maximum power formula

The energy efficiency requirements proposed in Measure 1 will no longer allow on the market linear fluorescent lamps T8 with a length of 2-, 4- or 5-feet, compact fluorescent lamps with integrated control gear (the old ‘energy saving lamps’ with slow start time), almost all remaining halogen light sources, and LED light sources with low efficiency. As of 2017, around 30% of the existing LED light sources would not meet the new proposed requirements. but with the rapid trend of new LEDs on the market this share is expected to decrease by September 2021. See Table 6.

Measure 1: Updated Ecodesign energy efficiency limits – As a general principle, it is proposed to have on the market only light sources that meet a certain minimum efficacy. The minimum efficacy is defined by means of a maximum power formula that uses =120 lm/W and L=1.5 as constants and that, reflecting the state of technological progress, will take into account in the calculation:

Option 3 would propose gathering all ecodesign requirements for light sources, for control gears and the correction factors in one single annex over three different tables. This will amount to a significant reduction of the dozens of pages contained in the relevant annexes in the current three Ecodesign regulations, making conformity assessment by industry and market surveillance by Member States easier.

Table 5 below shows the link between the different problems identified in Section 2 and the proposed measures under Option 3.

As regards energy labelling, Option 3 - ECOEL2021 puts forward similar measures as Option 2. In addition, and in response to the stakeholders view expressed on the energy-labelling only scenario in 5.2.2, Option 3 integrates revised ecodesign requirements with application from September 2021.

Stakeholders view on Option 2 - ELOnly: All stakeholders think that it is likely that an Energy Label alone will not reach important parts of the market, that there will be missed savings and loss of competitiveness through dumping. Regarding the discontinuity of the energy label for luminaires, industry, notably SMEs, and MSAs welcome this measure. This measure was part of the online public consultation on the revision of the lighting legislation, whose respondents were mostly private citizens and NGOs. Respondents did not show a clear preference for an option (30% would like to keep the label as it is, while 28% would favour its replacement by a label that concerns only the light source which is contained inside; 37% had no opinion), but only 5% favoured to discontinue the label for luminaires without an alternative. The solution that meets all needs is to keep the most relevant information that the energy label for luminaires gives and improve it (as explained in Measure 6) but to remove the requirement to supply the label for luminaires.

As for all other products containing a light source (e.g. shelves, mirrors, etc. as well as the dismountable luminaires), this measure introduces the concept of the “containing product”. Manufacturers of the containing products will be obliged to add to the information material of the containing product which light source type is inside, what is its energy class and if it is removable or not.

Measure 7: Fully integrated luminaires to be treated as light sources – Fully integrated luminaires will be considered a light source for the purposes of the energy labelling legislation and will be required to have an energy label. This measure will: (i) resolve the problem that MSAs have to test light sources when these are not accessible; (ii) resolve the issue of an unfair level playing field for industry when the same light source type is accessible; and (iii) support consumers in their conscious choice when buying integrated luminaires; In the longer run this measure will also stimulate innovation in LEDs, in particular towards thermal interfaces for LED modules that maintain their thermal dissipation characteristics when unmounted and remounted and, consequently, will reduce waste from old or damaged luminaires that cannot be refurbished or repaired.

In the interest of consumers, even if the label for luminaires is discontinued, relevant information from the current label, as well as additional information, should still be provided on the package, namely: (i) in case the luminaire is sold with a light source inside, the energy class of the contained light source; (iii) the compatible/contained light source type and technology; and (iii) if the light source can be removed.

As explained in Section 2.2, the energy label for luminaires is often considered a burden for SMEs and MSAs, and does not necessarily drive the consumer towards the most energy-efficient solution. Indeed, contrary to the lamp label, the luminaire label does not show the energy consumption of the luminaire, but rather inform consumers on the energy class of the compatible and/or contained light sources. In addition, the current label also informs consumers when the light source cannot be removed. However, other relevant information is missing on the luminaire label: the compatible/contained light source type and technology.

These are three ways of showing the energy label for luminaires today:

The introduction of the new metrics is not an additional burden on the manufacturers, importers and suppliers as they already have to compute them under the current regulations. In conclusion, the new metrics reflect technological progress and improve the transparency. A comparison of the proposed and old formulae is given in Annex 10.

Measure 3: Updated formula for energy label - A new formula for energy labelling is proposed that better reflects energy efficiency and is more intuitive in the calculation than the Energy Efficiency Index set out in the current energy labelling regulation. In the new metrics the limits for the energy efficiency classes have been defined directly in terms of light source efficiency, as a result of the total light output of a light source (in lumen, lm) divided by the mains (230V) power input (in Watt, W) and expressed as lm/W. This change implies that light sources with high light output do not need a higher efficiency to obtain a given energy efficiency class than light sources with low light output. This is reasonable considering that when the new energy labelling requirements start to apply, the label classes’ main purpose will be to differentiate between LEDs according to their respective efficiencies.

The energy label for lighting products is typically printed on the package of the product. Suppliers and dealers have shown concerns about how in practice to re-scale lighting products with the new energy label. The proposal to apply stickers on the products that at the date of application of the new label will be on shelves got much criticism at the Consultation Forum of December 2017 (see Annex 5) from almost all stakeholders. According to the new Framework Regulation (EU) 2017/1369 (art. 11(13)), specific rules can be provided for energy labels printed on the packaging, like in the case of lighting products. The proposed derogation for this measure is to put a deadline of nine months to dealers, after which the products can no longer be sold unless a rescaled label is attached on their package.

Following the outcome of the 2015 Review study, the measure aims in particular to increase the visibility of the label (e.g. arrow on front of package).

Remove products from the shelves if they do not have the new label

Table 4 gives an overview of the action that needs to be undertaken.

All light source models with efficacy below 85 lm/W will be class G. To obtain an A classification, a light source shall have an efficacy of at least 210 lm/W. Class widths are constant at 25 lm/W. As of October 2017 there are no light sources on the market that can meet the efficiency limits of classes A and B (but there are at laboratory level), so these classes would initially be empty as required by Regulation (EU) 2017/1369. The best LED light sources typically used by households today on the market would have new label class E; the best LED light sources for professional use today on the market would be class D and by 2021 some would be expected to be class C. In 2021, when the new classes will start to apply, class A is still expected to be empty while there might already be some class B light sources on the market.

Measure 2: Updated energy Label – Framework Regulation (EU) No 2017/1369 requires a rescaling of energy efficiency classes for light sources, from an A++ to G scale to an A-G scale by 2 November 2018. Class limits are to be set such that at the introduction of the rescaled label (2021) the A and B classes are empty, while the estimated time within which a majority of models falls into class A is at least 10 years later. The limits for the energy efficiency classes have been defined directly in terms of light source efficiency, as a result of the total light output of a light source (in lumen, lm) divided by the mains (230V) power input (in Watt, W) and expressed as lm/W.

Under Option 2, only the energy labelling legislation will be updated, while the ecodesign requirements would stay unchanged. Table 2 below depicts the link between the different problems identified in Section 2 and the proposed measures under Option 2.

Option 1 is the baseline for the impact assessment as described in Section 5.1. None of the measures in Figure 4 is implemented.

The requirement in the ETS to reduce emissions (from amongst other electricity production) will impact lighting products in a baseline scenario. Indeed, inefficient lighting products lead to more energy consumption. More electricity consumption increases the demand for ETS allowances. This either leads to higher ETS prices (which could in turn increase electricity prices) or to the need for additional emission reductions in ETS sectors (higher renewable energy targets or more reductions in industry).

The new Framework Regulation also prescribes the creation of a database (called EPREL) with information on all products in scope of delegated acts on energy labelling. The proposed act on lighting products specifies the information to be entered in this database.

In the baseline a shift towards LED lighting products will anyway happen, at a pace that is derived from current trends in sales, efficiency increase and price decrease. These trends are different for residential and non-residential applications.

In the baseline, the current Ecodesign and Energy Labelling Regulations and all other relevant EU-level policies and measures are assumed to continue without revision.

Similar to Option 3, except for the timing for phasing out the fluorescent T8 lamps which would occur in 09/2023

Both Ecodesign and energy labelling are reviewed, with application from 09/2021. Option 2 is encompassed in Option 3.

Only the Energy labelling regulation is reviewed with application from 09/2021; the ecodesign requirements remain unchanged

Subsequently, the policy options considered for this impact assessment are listed in Table 1 (detailed description in the next sections):

Some measures presented in this impact assessment were extensively discussed with stakeholders during two Consultation Forums (7 December 2015 and 7 December 2017) and represent the consensus achieved. They apply to all policy options and are further detailed under option 2 – ELOnly and Option 3 – ECOEL2021. The main element that needs to be further assessed is the timing for the phase out of linear fluorescent T8 lamps (see Options 3 and 4).

Figure 4 shows the link between the problems, the drivers, the specific objectives and the possible measures to tackle the problems. For every option, Section 5.2 describe the proposed measures.

The procedure for identifying policy options follows from the Better Regulation Toolbox . Specific measures in the policy options are the result of a combination of initiatives mentioned in the Review study 2015, the evaluation in Annex 9, the Inception Impact Assessment , and inspiration taken from the Ecodesign Framework Directive and the Energy Labelling framework Regulation. They aim to address the issues identified in Section 2 and achieving the objectives defined in Section 4.

·Contribute towards a circular economy in the EU by including requirements for non-dismountable products containing light sources.

·Redefine the scope and the exemptions to reduce the administrative burden and close loopholes, to better protect consumers and to make the obligations clear to manufacturers and MSAs;

·Update the energy efficiency requirements and the energy label in line with international and technological developments, and the revised Energy Labelling framework Regulation, to achieve further cost-efficient energy savings;

The specific objectives of the policy options considered in this impact assessment are to correct the problems identified in the problem definition (Section 2):

There are several synergies between these objectives. Reducing electricity consumption (by increasing the energy efficiency) leads to lower carbon, acidifying and other emissions to air. Tackling the problem at EU level enhances efficiency and effectiveness of the measure.

2.Increase energy security in the EU and reduce energy dependency through a decrease in energy consumption of lighting products.

1.Promote the energy efficiency of lighting products as a contribution to the Commission's objective to reduce energy consumption by at least 30% and domestic greenhouse gas (GHG) emissions by 40 % by 2030; implement the energy efficiency first principle established in the Commission Communication on Energy Union Framework Strategy; and

0.Promote competitiveness of the EU lighting products industry through the creation or expansion of the EU internal market for sustainable products;

Following the legal basis in the TFEU, the general objectives are to:

Without harmonised requirements at EU level, Member States would be incentivised to lay down national product-specific minimum energy efficiency requirements in the framework of their environmental and energy policies. This would undermine the free movement of products. Before the existing ecodesign and energy label measures were implemented, this was in fact the case for many products.

There is clear added value in requiring minimum energy efficiency levels and energy label class limits at EU-level.

Regulation (EU) 2017/1369 requires the Commission to update the current energy labelling regulation for lighting products, in particular as regards rescaling the label to remove the A+ and A++ classes.

Market surveillance is carried out by the MSAs appointed by MSs. In order to be effective, the market surveillance effort must be uniform across the EU to support the internal market and incentivise businesses to invest resources in designing, making and selling energy efficient products.

It is essential to ensure a level playing field for manufactures and dealers in terms of requirements to be met before placing an appliance on the market and in terms of the information supplied to customers for sale across the EU internal market. For this reason EU-wide legally binding rules are necessary.

Action at EU level gives end-users the guarantee that they buy an energy efficient product and provides end-users with harmonised information no matter in which MS they purchase their product. This is becoming all the more relevant as the online trade increases. With ecodesign and energy labelling at EU level, energy efficient products are promoted in all MSs, creating a larger market and hence greater incentives for the industry to develop them.

During the review process (Review study 2015), it was established that lighting products fulfil the above eligibility criteria.

·The introduction of energy labelling requirements for a product group should not have a significant negative impact on the functionality of the product during use.

·There should be no significant negative impact as regards the affordability and the life cycle cost of the product group;

·Models with equivalent functionality should differ significantly in the relevant performance levels within the product group;

·The product group should have significant potential for saving energy and where relevant, other resources;

The procedure for preparing such measures is described in Article 15(3). In addition, the criteria of Article 15(5) should be met:

o an absence of other relevant Community legislation or failure of market forces to address the issue properly,

The Ecodesign Framework Directive and Energy Labelling Framework Regulation include a built-in proportionality and significance test. For the Ecodesign Framework Directive, Articles 15(1) and 15(2) state that a product should be covered by an ecodesign or a self-regulating measure if the following conditions are met:

The legal basis for acting at EU level through the Ecodesign framework Directive and the Energy Labelling framework Regulation is Article 114 and Article 194 of the Treaty on European Union and the Treaty on the Functioning of the European Union (TFEU) respectively. Article 114 relates to the "the establishment and functioning of the internal market", while Article 194 gives, amongst others, the EU the objective "in the context of the establishment and functioning of the internal market and with regard for the need to preserve and improve the environment" to "ensure security of energy supply in the Union" and "promote energy efficiency and energy saving and the development of new and renewable forms of energy".

For society as a whole, ambitious policies in the area of energy efficiency are important tools to mitigate climate change. Effective and efficient energy labelling and ecodesign regulations contribute to achieving goals set in the Paris Agreement and they help achieve the 2030 EU climate and energy goals.

The increasing number of fully integrated luminaires from which the light source is not removable, could mean more costs for consumers.

The new features that are increasingly included in LED lamps (e.g. dimming, change of colour or white-tone by remote control, etc.) allow consumers to create their desired functionality and ‘atmosphere’; but as the energy consumption or quality characteristics of such features are not considered in the current legislation, consumers do not get the full picture from the existing information and energy scale.

For consumers, the energy label offers a unique opportunity to make an informed choice as to which products offer the best energy performance allowing them to save money in the long run. Ecodesign requirements safeguard consumers from the worst performing products.

Manufacturers of luminaires are mostly SMEs. The EU luminaire market is very fragmented: the ten largest European manufacturers cover 45% of the total market . Manufacturers of luminaires say they find it burdensome to implement the current energy labelling regulation.

With the ongoing rapid shift to LED lighting, manufacturers of lighting-related electronics are required to adjust from electronic control gears for classical lighting technologies to drivers for LEDs. Less efficient electro-magnetic control gears are being phased out from the market since 2017 and have been replaced by more efficient, high-frequency electronic ones. These manufactures have a dynamic business also due to the increasing trend to have ‘smart lights" with new features.

Asian manufacturers are rapidly expanding their global market share, using price as their main selling point. The energy label and ecodesign requirements play a crucial role for EU industry, to distinguish itself based on quality and innovation.

The largest part of the production chain for LEDs is in Asia, while European companies tend to specialise in high quality LEDs with new features (e.g. "smart lights"). Some European companies have sold their general lighting business in the last years, especially to Asian companies.

As for manufacturers of light sources, the EU28 employment in the light sources industry is 60 000 jobs (1/3 direct manufacturing, 1/3 OEM and 1/3 services: worldwide the total is 194 000). The major suppliers of light sources in EU28 are Philips Lighting, Ledvance/Osram, General Electric (GE) Lighting and Feilo-Sylvania. Together, they make EUR 3 billion of estimated revenue from the sale of light sources for general lighting, directly employ 15 000 people in direct manufacturing and generate employment for further 30 000 people (in OEM and services).

Manufacturers of lighting products include manufacturers of light sources, manufacturers of lighting-related electronics and manufacturers of luminaires. More information on employment and the size of the lighting products market can be found in Annex 6.

Price reflection – The price of the products does not reflect the real environmental costs to society in terms of circular economy. Hence, without setting requirements that will improve circular economy aspects of the product, the different actors in the life cycle of the appliance will not be incentivised to improve the circular economy aspects of the appliance.

Split incentives – Without up to date energy efficiency requirements, the guarantee that the products will be cost-effective over their life-time is lost. This is especially important for a certain group of consumers, in particular those in a landlord-tenant situations, where the landlord buys the appliance and the tenant pays the energy bill.

Myopic behaviour - Without up to date energy efficiency requirements and energy labels, economic actors (both business and private) will not choose the product that is the most cost-effective over the product's life-time. This is because economic actors are limited by the information they have, their knowledge about products, and the finite amount of time they have to make a decision.

In addition to the product specific problem drivers described in Sections 2.1, 2.2 and 2.3, some general market failures have been identified:

With the growing trend of fully integrated luminaires on the market, the situation will become worse if no action is taken.

Driver 2: Thermal characteristics of LEDs. Many luminaires are manufactured so that LED light sources are tightly mechanically integrated to optimise thermal management and for protection purposes. The side effect of this technology solution is that the unsealing and resealing of LED lights in the luminaire may hamper their energy efficiency.

Driver 1: Increase on the market of fully integrated luminaires. According to a survey by EU consumer association ANEC/BEUC on LED luminaires, in 2016 removability of light sources was not possible in 40% of the cases, compared to 30% in 2015.

Addressing the issue of non-dismountable luminaires, and other products containing light sources, would help the development of products that are dismountable, and thus reparable, better recyclable and with the option to replace the contained light source. This will contribute to a Circular Economy.

The current regulations impose ecodesign requirements on light sources wherever they are contained. But in practice MSAs may not be able to test them because they cannot access them. In practice, those light sources cannot always be monitored, and this creates an unfair level playing field compared to the same light source type which is accessible (e.g. because it is sold separately).

The problem is even bigger when considering all the non-dismountable furniture products containing a light source (e.g. shelves, mirrors, etc.).

The Energy label for luminaires provides information to consumers about the possibility of removing the contained light source, but this is not enough to avoid unwanted waste because non-dismountable products hamper replacement and recycling.

This trend is taking place because an integrated design offers advantages for energy efficiency and safety, and because LED light sources have longer lifetimes than classical technology light sources. Because these lifetimes are closer to the useful lifetime of the luminaire, it is often superfluous to make the light source replaceable. But integrated LED luminaires may still fail or be damaged. Representatives of lighting designers reported on various occasions during the review process that practical problems have arisen where large quantities of integrated luminaires were bought for an office or a shop: some luminaires failed prematurely (for various reasons), but the same luminaire model was not available anymore, requiring the user to replace it by another type or even to replace all luminaires when the lighting effect could not be the same.

Sales of luminaires with separate, replaceable light sources are shifting towards non-dismountable LED luminaires (also known as fully integrated luminaires). With these devices, when the contained light source fails, the entire luminaire has to be replaced.

Electricity savings due to the existing regulations were expected to be 110 TWh in 2020, but according to the last estimation they will be limited to 70 TWh. Ambiguities in the legislation on special purpose lamps and hampered capacity of MSAs to check compliance are relevant causes, especially because many lamps exempted for special purposes are energy inefficient incandescents and as exempted products they are therefore not subject to minimum energy efficiency requirements.

Driver 3: Long and expensive testing. The number of parameters for compliance testing and the length of the test procedures make conformity assessment expensive and time-consuming. This is particularly true for the 6000 hours testing for the lamp survival factor and lumen maintenance. By way of illustration, LED lamp models have often sold out by the time the testing by MSAs is completed.

Driver 2: Unclear scope. The way that some exemptions are formulated makes the inclusion of certain products in the scope uncertain. In particular, "special purpose lamps" are exempted only on the basis of their "intended" use, which is a subjective test. It is not unusual to have special purpose lamps marketed for general lighting applications, thereby circumventing the minimum requirements that should apply to them. One example are the ‘special purpose lamps’ intended for ovens, which are incandescent lightbulbs because they have to withstand high temperatures. Nevertheless, they are also sold for general lighting purposes because they are compatible with some normal luminaires, thereby circumventing the ban on incandescent lightbulbs for general lighting. Another example comes from the special purpose lamps for stage/studio/theatre lighting, especially the tungsten halogen lamps. The estimate for the energy consumption of special purpose lighting for movie/TV or photo studio/theatre/event applications is a small part of the total energy consumption for lighting products (0.075 TWh/y for special purpose lamps in theatres, compared to the total 336 TWh/y for all lamps as shown in Figure 3). Nevertheless, certain exemptions in the current Regulation, including the one on stage/studio/theatre lighting, have been used as loopholes. It is not uncommon to find installations of stage/studio/theatre lighting in residential apartments. Stakeholders, including the lighting industry, are keen for the revised legislation to close such loopholes.

Driver 1: Complex legislation. Ecodesign requirements for lighting products are laid down in three different regulations: Commission Ecodesign Regulations (EC) No 244/2009, (EC) No 245/2009 and (EU) No 1194/2012. This creates uncertainty as to the applicable regulation to specific products. Furthermore, each regulation has its own formulae to calculate energy efficiency.

In addition, industry (mostly SMEs) find the Energy Label for luminaires a burden with limited added value. Many MSAs also find the verification of this label not worth the effort and consider that their enforcement efforts should rather focus on other aspects which would achieve more energy savings.

Practice shows that compliance with current Ecodesign legislation for lighting products can be difficult. Stakeholders have complained that (i) the norms are scattered between legislative texts, (ii) the scope and exemptions are not always clear and (iii) conformity assessment is demanding. Industry reported having problems in implementing this legislation and Market Surveillance Authorities (MSAs) encounter difficulties evaluating if products are in scope and in performing proper surveillance.

Finally, light sources used in the EU could become less energy efficient than in other economies such as US and Australia . As a result, the EU could become a dumping ground for less efficient products that can no longer be sold in other parts of the world.

Without requirements adapted to technological progress, light sources used in the EU are expected to be less energy efficient than they could be, and EU consumers will lose out from buying slightly cheaper but more energy consuming products, because the lifecycle costs which include energy consumption will be higher. Without improved legislation, the potential to save energy would not be reached in time to contribute to achieving the EU’s energy and greenhouse gas emissions reductions goals for 2030.

Ecodesign is a key driver for innovation in product energy efficiency and supports the EU’s technological and environmental leadership. The EU lighting regulations are generally in line with worldwide regulation and in some cases cover a wider scope of light sources or set more stringent requirements.

Driver 3: Current focus on household lighting. 2/3 of the energy savings achieved by the current legislation come from the residential sector, because of the existing ecodesign requirements for incandescent and halogen lamps, which are typically used for household lighting. However, 80% of lighting electricity is now consumed in the non-residential sector, 60% of this by linear fluorescent lamps (including the typical T8 fluorescent tube lights in offices). Without an update of the requirements, the energy savings potential of non-residential lighting will not be realised at the required pace to contribute to the EU 2030 energy and greenhouse gas emissions reductions goals.

Driver 2: Additional use functions. New features to make lights more "human centred" and "smart" have been added to lighting products since the adoption of the Ecodesign and Energy Labelling Regulations. The new functionalities have an impact on the energy efficiency of the lighting products but are not reflected in the existing energy efficiency calculations.

As a result of this technological progress the top three energy efficiency classes of the energy label are overpopulated: they cover 66% of the models and all LEDs are in these three classes. By 2020 over 50% of LEDs will be A++. This makes it more difficult to distinguish between models. Moreover, the "A+", "A++" and "A+++" classes introduced by the Energy Labelling Framework Directive (Directive 2010/30/EU) have been shown to be less effective in persuading consumers to buy more efficient products than the A to G scale, with consumers wrongly believing that there is not much difference between A and A+++ .

Driver 1: Technological progress. Technology for light sources keeps evolving, thereby improving energy efficiency. LED technology, which is for almost all applications the most energy efficient lighting technology that exists, has had a rapid uptake on the EU market: from 0% of sold lamps in 2008 to 22% in 2015 with models on the market often being replaced by updated versions every six months to one year. In addition the average energy efficiency of LEDs quadrupled between 2009 and 2015, and prices dropped significantly: compared to 2010, in 2017 a typical LED lamp for household use was 75% cheaper and a typical LED lamp for offices 60% cheaper.

Moreover, the energy label for luminaires does not necessarily drive the consumer towards the most energy-efficient option: this label is different from a normal energy label, because it informs customers on the compatible light sources and on the possibility to remove the light source but not on the energy consumption of the luminaire.

Nevertheless, lighting remains the second largest electricity consumer in the EU ecodesign programme (around 12% of all gross electricity production in the EU28).

In 2008, prior to the entry into force of the current Ecodesign and Energy Labelling Regulations in 2009 and 2012 respectively, there were 9.2 billion light sources operating in EU28, consuming 330 TWh/a of electricity. Without the current Regulations, in 2015 the electricity consumption of light sources in scope would have been 41 TWh higher (377 TWh instead of 336 TWh – see ‘BAU2008’ in Figure 3 ), equivalent to the total final electricity consumption of Denmark and Lithuania together. Savings happened despite the fact that the number of light sources had increased to 11.4 billion (+23.7% compared to 2008; +3.1% per year). Ecodesign and energy labelling measures have also reversed the growth trend of electricity consumption for light sources faster than under business-as-usual conditions.

The current ecodesign requirements for lighting products no longer capture cost-effective energy savings and the current energy label no longer allows consumers to differentiate sufficiently between the products on the market.

The options presented in Section 5 were built on the outcome of the review to address the above listed concerns.

Moreover, incandescent lamps, which the ecodesign legislation phased-out from 2009, were expected to be mainly replaced by compact fluorescent lamps. However, many consumers preferred the less energy-efficient halogen lamps. Fluorescent lamps have not been adopted as expected because of (real or perceived) sub-standard performance (e.g. colour rendering and temperature, ignition time, mercury hazards).

·Recent appearance on the market of ‘fully-integrated luminaires’ from which the light source cannot be removed for compliance verification.

·Tolerances intended for use by market surveillance during verification that have been used also by manufacturers in the declaration of lamp characteristics, with the result to bring on the market products with an efficacy that is lower than the minimum required one;

·Unclear definitions for exempted lamp types ("special purpose lamps", as defined in the current legislation), using a description of intended use rather than measurable parameters;

·Too many parameters to verify by market surveillance, and too expensive/long verification testing required (e.g. 6000h test for lumen maintenance);

The main finding from the evaluation of the impact of the current legislation is that electricity savings due to the existing requirements were expected to be 110 TWh in 2020, but according to the latest estimation they will be limited to 70 TWh. The evaluation showed that the gap in energy savings is the result of:

The review process for lighting products ran for longer than usual for a product group in scope of ecodesign and energy labelling and had two Ecodesign Consultation Forums (in December 2015 and in December 2017, see Annex 2 and Annex 5), while usually only one is needed. This happened to take properly into account all relevant aspects and shape the problem definition.

The review of the ecodesign and energy labelling for lighting products started in 2015 and several studies were conducted for this purpose, as described in Annex 1. These studies evaluated the impact of the current legislation, as reported in Annex 9; they also looked at the technological and economic evolution of the sector and at stakeholders' views. Results from the studies have been used directly as input to the problem definition analysis model (see Annex 4).

More generally, the filling up of the top classes means that the label is no longer effective. If there is still a significant difference in energy efficiency of products remaining on the market, a label will still bring added value in terms of guiding consumers to more efficient products.

The new Energy Labelling framework Regulation requires the Commission to rescale the existing labels for five priority product groups, including lighting, by 2 November 2018 at the latest, to remove the A+ to A+++ classes.

Several other policies and political priorities require the revisions to look beyond the technical revisions mentioned in the review article of the existing regulations, e.g.:

Manufacturers and consumers stand to benefit from the fact that there are still cost effective energy savings to be achieved in the lighting sector. By way of illustration, electricity savings due to the existing requirements on lighting products were expected to be 110 TWh in 2020, but according to the last estimation will be limited to 70 TWh.

The need to act is driven by the following main considerations:

Several new policy initiatives indicate that ecodesign and energy labelling policies are relevant in a broader political context. The main ones are the Energy Union Framework Strategy, which calls for a sustainable, low-carbon and climate-friendly economy, the Paris Agreement, which calls for a renewed effort in carbon emission abatement, the Gothenburg Protocol, which aims at controlling air pollution, the Circular Economy Initiative , which amongst others stresses the need to include reparability, recyclability and durability in ecodesign, the Emissions Trading Scheme (ETS), aiming at cost-effective greenhouse gas (GHG) emissions reductions and indirectly affected by the energy consumption of the electricity-using products in the scope of ecodesign and energy labelling policies, and the Energy Security Strategy, which sets out a strategy to ensure a stable and abundant supply of energy.

Finally, in August 2017, the new Energy Labelling framework Regulation (EU) 2017/1369 entered into force, repealing Directive 2010/30/EU . Under the repealed Directive, energy labels were allowed to include A+ to A+++ classes to address the overpopulation of the top classes. Over time, due to technological development, also the A+ to A+++ class became overpopulated, thereby reducing the effectiveness of the labels significantly. To resolve this, the new framework regulation requires a rescaling of existing energy labels, back to the original A to G scale. Article 11 of the Energy Labelling framework Regulation lists 5 priority product groups for which new delegated acts with rescaled energy labels must be adopted at the latest on 2 November 2018. Lighting products are one of the priority product groups.

The Ecodesign working plan 2016-2019 mentions the review of the four lighting regulations as one of the major energy savings opportunities, with anticipated primary energy savings of 125 TWh per year in 2030. The working plan also requires examining how aspects relevant to the circular economy can be assessed and taken on board, in line with the Circular Economy Initiative .

The Ecodesign and Energy Labelling Regulations for lighting products require all the regulations to be reviewed in the light of technological progress no later than five years (three years for the 2012 acts) after their entry into force. The review of the energy labelling act should in particular assess the verification tolerances.

An overview of existing policies, legislation and standards affecting lighting products in the EU and outside is given in Annex 8.

Under this framework, as listed in Section 1, lighting products are regulated by Commission Ecodesign Regulations (EC) No 244/2009, (EC) No 245/2009 and (EU) No 1194/2012 and Commission Delegated Energy Labelling Regulation (EU) No 874/2012.

For more details about the legal framework, including a full list of ecodesign and energy labelling measures, see Annex 7.

As an alternative to the mandatory ecodesign requirements, voluntary agreements or other self-regulation measures can be presented by the industry, see also Article 17 of the Ecodesign Framework Directive. If certain criteria are met the Commission formally recognises these voluntary agreements. The benefits are a quicker and more cost-effective implementation, which can be more flexible and easier to adapt to technological developments and market sensitivities

The Ecodesign framework Directive and the Energy Labelling framework Regulation are implemented through product-specific implementing and delegated regulations. To be covered, the energy-related products must (i) represent a significant volume of sales (more than 200000 units a year), (ii) have a significant environmental impact within the EU and (iii) represent a significant energy improvement potential without increasing the cost excessively, see also Article 15.2 of the Ecodesign Framework Directive.

For those consumers that do not use the energy label to select a product and for consumers in a tenant-landlord situation (where the landlord set the lighting equipment and the tenant pays the bill), ecodesign requirements are important, as it safeguards consumers from the worst performing products.

The legislative framework builds upon the combined effect of the two aforementioned pieces of legislation. See Figure 2 for a visualisation of this effect.

The energy label is recognised and used by 85% of Europeans.

The BAT is determined following the MEErP methodology, and is based on purely technical grounds, i.e. the product on the market with the lowest environmental impact, while ensuring that other functional requirements (e.g. performance, quality, durability) are equivalent to the base case.

In general, the boundaries of the label scale are defined by the performance of products on the market incorporating ‘Best Available Technology’ (BAT) and the minimum requirement under ecodesign for those products. Subsequently, the bandwidth of the classes is determined so as to keep the same effort to move from one class to the next one. For specific product groups this may however be different to take into account appropriate product differentiation.

·Moreover, the A to G steps of the classification shall correspond to significant energy and cost savings and appropriate product differentiation from the customer’s perspective.

·Where technology is expected to develop more rapidly, classes A and B shall be empty when introducing the label;

·Class A shall be empty at the moment of introduction of the label, and the estimated time within which a majority of the models falls into that class is at least 10 years;

The Energy Labelling Framework Regulation complements the Ecodesign Framework Directive by enabling end-consumers to identify the better-performing energy-related products, via an A-G/green-to-red scale. The Regulation sets out the general rules for rescaling the existing A+ to A+++ labels:

In the EU, the Ecodesign Framework Directive sets a framework requiring manufacturers of energy-related products to improve the environmental performance of their products by meeting minimum energy efficiency requirements, as well as other environmental criteria such as water consumption, emission levels or minimum durability of certain components before they can place their products on the market.

In the EU, lighting products have been subject to Ecodesign requirements since 2009 and Energy labelling since 2012. Electricity consumption in the EU in 2015 would have been 41 TWh higher without the existing legislation. Light sources in particular are one of the largest electricity consumers worldwide and are subject to minimum energy efficiency and labelling requirements around the globe.

This legislative framework benefits from broad support from European industries, consumers, environmental non-governmental organisations (NGOs) and Member States (MSs), because of its positive effects on innovation, increased information for consumers and lower costs, as well as environmental benefits.

The average household will invest in more expensive and efficient products, but in return saves about EUR 500 annually on its energy bills by 2020. Although the cost for industry, service and wholesale and retail sectors will increase, it will result in EUR 55 billion per year of extra revenue by 2020.

It is estimated that by 2020, ecodesign and energy labelling regulations will deliver around 175 Mtoe (i.e. about 2035 TWh) of energy savings per year in primary energy in comparison to if there were no measures in place. This is roughly equivalent to Italy's energy consumption in 2010, close to half the EU 20 % energy efficiency target by 2020 and about 11 % of the expected EU primary energy consumption in 2020.

Ecodesign and energy labelling are recognised globally as one of the most effective policy tools in the area of energy efficiency. They are central to making Europe more energy efficient, contributing in particular to the ‘Energy Union Framework Strategy’, and to the priority of a ‘Deeper and fairer internal market with a strengthened industrial base’. Firstly, this legislative framework pushes industry to improve the energy efficiency of products and removes the worst-performing ones from the market. Secondly, it helps consumers and companies to reduce their energy bills. In the industrial and services sectors, this results in support to competitiveness and innovation. Thirdly, it ensures that manufacturers and importers responsible for placing products on the European Union (EU) market only have to comply with a single EU-wide set of rules.

Figure 1: Lighting technologies (above) and example of a control gear for linear fluorescent lamps (below)

For the purposes of this impact assessment, "lighting products" are thus light sources, control gears and luminaires. When the control gear is integrated in the light source, the combined product is a light source.

−‘luminaires’: equipment which distributes, filters or transforms the light transmitted from one or more light sources and which includes all the parts necessary for supporting, fixing and protecting the light sources and, where necessary, circuit auxiliaries together with means for connecting them to the electric supply. Luminaires include wall-mounted, ceiling, table or standing luminaires.

®Commission Regulation (EU) No 1194/2012 on ecodesign requirements for lighting products applicable to directional lamps, Light Emitting Diode (LED) lamps and related equipment , and

®Commission Regulation (EC) No 245/2009 on ecodesign requirements for lighting products applicable to fluorescent lamps without integrated ballast, high intensity discharge lamps and ballasts and luminaires able to operate such lamps,

This report commits only the Commission’s services involved in its preparation and does not prejudge the final form of any decision to be taken by the Commission.

7.3.Assessment in view of Article 15(5) of the Ecodesign Framework Directive and Article 16 (2) of the Energy Labelling Regulation45

For all scenarios, the total expense savings with respect to the BAU-scenario are smaller