Lighting products are already subject to comprehensive EU ecodesign requirements under Commission Regulation (EU) 2019/2020, which banned incandescent and halogen lamps and set minimum efficiency requirements for LED and fluorescent sources. The ESPR delegated act will add a Digital Product Passport requirement with mercury content disclosure, recycled material content, and carbon footprint per lumen.
Existing Ecodesign Requirements for Lighting Products
Light Source Type
Status
Minimum Efficacy
In Force Since
Incandescent lamps
Banned
N/A
1 September 2021
Halogen lamps (mains voltage)
Banned
N/A
1 September 2021
Compact fluorescent lamps (CFL)
Banned
N/A
1 September 2023
T8 fluorescent tubes
Banned
N/A
1 September 2023
T5 fluorescent tubes (professional)
Temporarily permitted
105 lm/W
Phase-out expected 2025–2027
LED lamps (non-directional)
Permitted
85 lm/W
1 September 2021
LED lamps (directional)
Permitted
85 lm/W
1 September 2021
LED modules
Permitted
85 lm/W
1 September 2021
Truth Anchor: Commission Regulation (EU) 2019/2020 remains in force under ESPR Article 74. Incandescent and halogen lamps are banned from the EU market. — EUR-Lex CELEX:32024R1781
Expected DPP Data Fields for Lighting Products
Data Field
Annex III Category
Status
Luminous efficacy (lm/W)
Energy performance
Already required
Luminous flux (lm)
Energy performance
Already required
Colour temperature (K)
Energy performance
Already required
Colour rendering index (CRI)
Energy performance
Already required
Rated lifetime (hours)
Durability and reliability
Already required
Mercury content (mg)
Substances of concern
New under ESPR delegated act (for remaining fluorescent)
Recycled aluminium content
Recycled content
New under ESPR delegated act
Recycled glass content
Recycled content
New under ESPR delegated act
Carbon footprint per klm
Carbon footprint
New under ESPR delegated act
End-of-life recycling instructions
End-of-life information
New under ESPR delegated act
LED Lighting: The ESPR Opportunity
LED lighting manufacturers are well-positioned for ESPR compliance. LED lamps are already the only permitted technology for most applications, and LED manufacturing is more amenable to recycled content than fluorescent manufacturing. The DPP requirement primarily adds data collection and registration obligations — not new product design requirements — for manufacturers already producing compliant LED products.
The carbon footprint per kilolumen-hour (klm·h) is expected to be a key DPP metric for lighting products. LED lamps have significantly lower carbon footprints than the banned incandescent and halogen lamps. Manufacturers who can demonstrate low carbon footprints will have a marketing advantage in public procurement, where ESPR carbon footprint data will be used in green procurement criteria.
What Lighting Manufacturers Must Do Now
Verify compliance with existing Regulation (EU) 2019/2020: Confirm all light sources meet minimum efficacy requirements and that banned technologies are not being placed on the EU market.
Audit mercury content: For any remaining fluorescent products, document mercury content in milligrams per lamp. This will be required in the DPP.
Conduct lifecycle carbon footprint assessment: Calculate the carbon footprint per kilolumen-hour for LED products. Focus on manufacturing phase (LED chip production is energy-intensive) and use phase.
Prepare DPP data templates: Create DPP data templates for all light source models. LED manufacturers with large product ranges should prioritise automation of DPP data collection.
Lighting Products Under ESPR: Post-LED Transition
The EU's lighting ecodesign regulations have been instrumental in driving the transition from incandescent bulbs to LED lighting. The current Ecodesign Regulation for light sources (Regulation (EU) 2019/2020) sets minimum energy efficiency requirements that effectively prohibit the sale of incandescent and halogen bulbs in the EU. The ESPR lighting delegated act will build on this foundation and add new requirements for recycled content, substances of concern (particularly mercury in fluorescent lamps), and the Digital Product Passport.
Lighting DPP: Expected Data Fields
Data Category
Expected Data Fields
Status
Energy performance
Energy efficiency class (A-G), luminous efficacy (lm/W), power (W)
Existing (EU 2019/2020)
Light output
Luminous flux (lm), colour temperature (K), colour rendering index (CRI)
Mercury in Fluorescent Lamps: A Substances of Concern Priority
Fluorescent lamps (including compact fluorescent lamps) contain mercury — a substance of very high concern under REACH. The ESPR lighting DPP will require manufacturers to declare the mercury content of fluorescent lamps and provide instructions for safe disposal and mercury recovery. The EU is phasing out mercury-containing lamps under the RoHS Directive, but existing stocks of fluorescent lamps will remain in use for years. The DPP will help ensure that these lamps are disposed of correctly at end of life.
Lighting Products Already Subject to Ecodesign — What Changes Under ESPR?
Lighting products have been subject to EU Ecodesign requirements since 2009, when the phaseout of incandescent lamps began under Regulation (EC) 244/2009. The current Ecodesign regulation for light sources (EU 2019/2020) and the Energy Labelling regulation for light sources (EU 2019/2015) set performance requirements for lamps and luminaires. The ESPR delegated act for lighting will extend these requirements to include Digital Product Passport obligations and enhanced lifecycle data requirements. The key additions under ESPR compared to the existing Ecodesign regulation are: mandatory DPP data carrier on the product, lifecycle carbon footprint declaration, recycled content disclosure, and repairability/replaceability information for luminaires.
LED Lighting and ESPR Compliance
LED lighting now dominates the EU market for lamps and luminaires. LED lamps must comply with the minimum energy efficiency requirements in EU 2019/2020 — the minimum luminous efficacy for LED lamps is 85 lm/W (Class E on the Energy Label). The ESPR delegated act for lighting is expected to raise the minimum efficacy threshold over time, potentially to 100 lm/W or higher, to drive continued efficiency improvements. For luminaires, the ESPR DPP will require disclosure of the luminaire efficacy (lm/W at the luminaire level, not just the lamp level), the light source replaceability (whether the LED module can be replaced without replacing the entire luminaire), and the expected lifetime in hours at L70 (the point at which luminous flux has declined to 70% of initial value).
Hazardous Substances in Lighting Products
Fluorescent lamps contain mercury — a hazardous substance regulated under the EU RoHS Directive (2011/65/EU) and the Minamata Convention. The EU has been progressively tightening the exemptions that allow mercury in fluorescent lamps, with the goal of phasing out mercury-containing lamps entirely. The ESPR delegated act for lighting will require manufacturers to declare the mercury content of any lamps containing mercury, referenced to the RoHS exemption under which the mercury is permitted. LED lamps do not contain mercury, which is one of the key environmental advantages of LED technology. However, LED lamps do contain other substances of concern — including lead in solder (covered by RoHS exemptions), arsenic in semiconductor substrates, and rare earth elements in phosphors — that must be disclosed in the ESPR DPP.
Yes. Commission Regulation (EU) 2019/2020 sets minimum energy efficiency requirements for light sources. These requirements entered into force on 1 September 2021 and remain in force under ESPR Article 74. Incandescent and halogen lamps are banned from the EU market.
The ESPR delegated act for lighting products is expected in 2027-2029. From the compliance date, every light source placed on the EU market must have a valid DPP.
Fluorescent lamps (T8, T5, compact fluorescent) are being phased out. Commission Regulation (EU) 2019/2020 banned most fluorescent lamps from 1 September 2023. Only T5 fluorescent lamps for professional applications remain temporarily permitted.
The DPP is expected to require disclosure of mercury content for any light source containing mercury (primarily remaining fluorescent lamps). The mercury content must be disclosed in milligrams per lamp.
The delegated act is expected to require disclosure of recycled aluminium content (heat sinks), recycled glass content (lamp envelopes), and recycled plastic content (lamp bases and housings).
Register Your Digital Product Passport
The EU DPP Registry goes live on 19 July 2026. EU customs will verify DPP compliance automatically from that date. Products without a valid DPP can be refused entry. Register now at Africa’s first ESPR-compliant DPP registry.
Current Ecodesign Requirements for Lighting Products
Lighting products are currently subject to ecodesign requirements under EU Regulation 2019/2020 (light sources) and EU Regulation 2019/2015 (energy labelling), which took effect on 1 September 2021. These regulations set minimum energy efficiency requirements for light sources (expressed as the luminous efficacy in lm/W) and require manufacturers to provide product information including the rated luminous flux, colour rendering index (CRI), colour temperature, and rated lifetime. The ESPR delegated act for lighting products will build on these requirements and add DPP data disclosure and recyclability requirements.
The lighting market has undergone a fundamental transformation over the past decade, with LED technology replacing incandescent, halogen, and compact fluorescent lamps. LED lighting is significantly more energy-efficient than previous technologies, but it introduces new environmental challenges: LED lamps contain electronic components (drivers, control circuits) that are difficult to recycle, and they often use rare earth elements (europium, terbium, yttrium) in the phosphor coating that are difficult to recover at end-of-life. The ESPR delegated act is expected to address these challenges by requiring manufacturers to design LED lamps for easier disassembly and to disclose the content of rare earth elements in the DPP.
Frequently Asked Questions
The ESPR delegated act for lighting products is expected to be adopted in 2025–2026, superseding EU Regulation 2019/2020. Manufacturers should plan for compliance by 2027–2028. The existing regulation remains in force until the ESPR delegated act takes effect.
The current ecodesign regulation covers light sources (lamps) but not luminaires (fixtures). The ESPR delegated act may extend coverage to luminaires, particularly those with integrated non-replaceable light sources. The preparatory study will determine the scope of the delegated act.
The DPP for LED lamps is expected to include: luminous efficacy (lm/W), rated lifetime (hours), colour rendering index (CRI), colour temperature (K), carbon footprint, recycled content percentage, rare earth element content, and end-of-life disassembly instructions. This data must be accessible via a QR code or other data carrier affixed to the product or its packaging.
Smart lighting products (connected LED lamps and luminaires) face additional ESPR requirements related to software update commitments and cybersecurity. The DPP for smart lighting products is expected to include the software update commitment period and information on the product's connectivity standards.
For small LED lamps where space is limited, the QR code may be required only on the packaging rather than the lamp itself. The delegated act will specify the exact placement requirements. For luminaires, the QR code is expected to be required on the product itself in a durable, accessible location.