The current Ecodesign Regulation (2019/2020/EU) distinguishes between light sources and surrounding products.
In addition to lamps and LED modules, light sources also include luminaires where the light source cannot be removed without causing
damage. In the latter case, the entire luminaire is considered a light source and must then fulfil all requirements for light sources. However,
luminaires from which the light source can be removed non-destructively for inspection are considered „surrounding products“.
Labelling with the energy efficiency label in accordance with Regulation 2019/2015/EU may only be used for light sources. Surrounding
products may not bear an energy efficiency label, but must include a reference to the energy efficiency class of the light source in the operating
instructions: „This luminaire contains a light source of energy efficiency class x“
Reasons why a light source cannot be removed from a luminaire and the luminaire thus becomes a light source itself, as described above, can
be, for example:
• if, due to IP protection requirements, the luminaire housing is bonded to provide effective protection against the ingress of water
and foreign bodies,
• if the design of the luminaire is such that light sources can be contaminated and/or damaged during replacement (ESD) and if the way
in which the light sources are attached has an influence on the thermal properties (heat dissipation).