I. Introduction
EU energy labels are mandatory. Products that have not completed EPREL registration and label affixing will face risks such as customs detention and e‑commerce platform delisting. As a lighting product with an independent LED driver power supply, the triangular cold light lamp involves a dual consideration of "light source + control gear" in its compliance registration, requiring particular attention from sellers.
II. Product Characterisation: Defining the Identity of Triangular Cold Light Lamps in Regulations
2.1 Distinction Between Light Sources and Independent Control Gear
Citing the definitions in Article 2 of (EU) 2019/2015: a light source is "a product that is electrically driven and used for, or adjustable for, emitting light"; a control gear (LED driver power supply) is "a device used to convert mains power into the electrical format required by the light source."
If the triangular cold light lamp is an integrated structure in which the light source and driver power supply cannot be separated, it is registered as a whole light source; if the driver power supply can be sold independently or is detachable, the light source and power supply must separately meet compliance requirements.
2.2 Applicable and Exempt Boundaries
Mandatory scope: Products that are mains‑powered, used for general lighting, with luminous flux ≥30 lm.
Exempt circumstances: Pure battery‑powered, solar‑powered, or non‑general lighting uses such as medical/agricultural/stage lighting. If the triangular cold light lamp is used in such special scenarios, an exemption declaration may be issued to exempt it from registration.
III. Key Parameters of ErP Energy Efficiency Testing
3.1 Regulatory Basis
Testing is based on the supporting requirements of (EU) 2019/2020 (Ecodesign) and (EU) 2019/2015 (Energy Labelling).
3.2 Core Test Items
Optical parameters: Luminous flux, luminous efficacy (lm/W), colour temperature consistency, Colour Rendering Index (CRI – general lighting requires >80).
Electrical parameters: Actual power consumption, power factor, standby power consumption.
Flicker indicators: Must cover both SVM and Pst LM – measuring only one is a common reason for rejection.
Lifespan parameters: 6,000‑hour luminous flux maintenance rate (failure rate ≤10%, maintenance rate ≥80%).
3.3 Laboratory Qualifications and Timeline
It is recommended to choose a laboratory with CNAS/ISO 17025 accreditation to issue EN standard reports.
The standard testing cycle is 5‑7 working days. Models with different power ratings and colour temperatures must be tested separately.
IV. Registration in Practice: The Complete EPREL Database Registration Process
4.1 Prerequisite for an EU Authorised Representative
Non‑EU companies cannot register in EPREL independently; they must appoint an EU Authorised Representative as the compliance responsible party.
4.2 Six‑Step Registration Method
Step 1: Create an EU Login company account and link the EU Representative information.
Step 2: Select the product category (light source/control gear) and enter the brand, model, and technical parameters.
Step 3: Upload the energy efficiency test report and Declaration of Conformity (DoC).
Step 4: The system generates a unique registration number and traceability QR code.
Step 5: Download the official energy label PDF file automatically generated by the system.
Step 6: Upload the label and product information sheet to the backend of sales platforms such as Amazon.
4.3 Timing and Cost Notes
Registration review typically takes 1‑2 weeks, and the complete EU Representative contracting plus registration process takes approximately 2‑4 weeks. Registration is valid long‑term after a single registration; no annual renewal fee is required.
V. Affixing Requirements for the New A‑G Class Labels
5.1 Six Mandatory Elements of the New Label
Supplier name/trademark
Product model
Energy class letter (A‑G)
Energy consumption data under standard conditions
EPREL traceability QR code
Corresponding regulation number
5.2 Size and Affixing Rules
Standard size not less than 36 mm × 72 mm; a simplified version of 20 mm × 54 mm may be used for small packaging.
The label should preferably be affixed to the outer packaging, printed in colour, with the QR code size ≥1 cm × 1 cm and clear contrast.
Since September 2021, the old A+++ label has been abolished; continued use will result in the product being deemed non‑compliant.
VI. Common Compliance Pitfalls and Responses
Pitfall 1: Only completing ErP testing without completing EPREL registration. Meeting energy consumption standards ≠ label compliance – the two are independent obligations.
Pitfall 2: Omission of registration for the light source and driver power supply. Detachable drivers must be registered separately from the light source.
Pitfall 3: Incomplete flicker testing. Having only SVM data without Pst LM will result in direct rejection during review.
Shenzhen Zhongwei Inspection is a professional third‑party export energy efficiency testing and certification body, operating a professional energy efficiency laboratory in China. It provides EU ERP energy efficiency certification, US DOE and California CEC energy efficiency certification, and UK energy efficiency certification services. The company‘s engineering team is proficient in European and American energy efficiency regulations and has long provided export energy efficiency testing and label registration services to domestic and international customers, with complete qualifications, professional reliability, and high praise.
Welcome to contact us for EU energy label registration services.
