UK Ecodesign rules for lighting products

At a glance

Revised text on legislation.gov.uk, 5 November 2026. ‘Sch’ is a Schedule. This table does not say that any product complies or is exempt.

What the Regulations cover

SI 2021/1095 is made under the Ecodesign for Energy-Related Products Regulations 2010. It regulates three things, and one bespoke fitting can be all three at once. The first drawing below is the path in one picture; the second names the parts on a cabinet.

• A light source is an electrically operated product that emits light and has the optical characteristics in regulation 2(2): chromaticity in a stated range, luminous flux between 60 and 82,000 lumen, less than 500 lumen per square millimetre of projected light-emitting area, and a colour rendering index above zero. LED chips and LED packages are not light sources. A light-emitting device made to be used directly in an LED luminaire is (regulation 2(6)).
• Separate control gear is a driver, transformer or ballast that prepares the mains for the form of supply a light source needs, is not physically integrated with a light source, and is placed on the market as a separate product or as part of a containing product. A dimmer, sensor or data part is a lighting control part and is not control gear (regulation 2(9)(b)).
• A containing product is a product containing light sources, separate control gear or both. The definition says it includes luminaires that can be taken apart so the light source can be verified separately, household appliances containing light sources, and ‘furniture containing light sources (for example display cabinets)’ (regulation 2(10)).

Chapter 2, the ecodesign requirements, applies to light sources and separate control gear placed on the market or put into service on or after 1 October 2021, including those placed on the market in a containing product (regulation 3(1)). The lamp or module inside a pendant therefore still has to meet Schedule 3. Chapter 3, the energy label, applies to light sources placed on the market; for a light source inside a containing product the supplier gives its energy class in the user manual (regulation 12(2); Schedule 8 paragraph 3). The Regulations extend to England, Wales and Scotland (regulation 1(4)). For Northern Ireland the OPSS list of energy-related products names different, EU, instruments. The government’s 2026 review found that online listings for LED strip and tape often lacked energy labels, so a strip bought as a product is worth checking for one.

Regulation 6 in plain English

Regulation 6 is the part that matters to a designer, because it is about how a fitting is built. It puts duties on the manufacturers, authorised representatives and importers of containing products. In plain English it asks for seven things, and each one is also a paper you can ask the supplier for.

Two points to carry into a specification. First, ‘commonly available tools’ is not defined in the text we read, and we found no government guidance that explains it: a screwdriver and a hatch are plainly commonly available, a heat-gun and a bonded panel are less clearly so, and the supplier should say which its fitting needs. Second, the same design choices that make a fitting replaceable make it maintainable: see lighting built into joinery for drivers, hatches and profiles, and O&M information for decorative lighting for where the replaceability statement belongs in the handover pack.

Who carries the duty, and what the text leaves open

The duties in regulation 6 sit with the manufacturer, authorised representative or importer. The 2010 Regulations define a manufacturer as a person who manufactures a product, or has a product designed or manufactured, and markets it under their own name or trade mark. An importer is a person established in the United Kingdom who places a product from outside it on the market. ‘Placing on the market’ is the first making available of a product on the market of Great Britain. OPSS guidance says the manufacturer, authorised representative or importer that first places a regulated product on the Great Britain or Northern Ireland market is responsible for compliance, must complete a declaration of conformity supported by technical documentation, and must keep that documentation available for at least 10 years from the date the product was last manufactured, and give it to OPSS within 10 working days of a request. Contravening regulations 3 to 5 of the 2010 Regulations is an offence (regulation 14).

That is the whole of what the text tells us about who carries the duty. It does not say who is the manufacturer of a bespoke fitting designed by one party, made by a second and sold under the name of a third, and it does not say whether site-built joinery with lighting is ‘placed on the market’ at all. The government’s own 2026 review of these Regulations records that manufacturers are unsure whether some light-containing products are in scope and lists clarifying the definition among changes that could be made in future; it recommends keeping the Regulations as they are for now.

So the page does not decide, and neither should a specification by assumption. Ask every party in the chain, the studio and its partners included, to state in writing which role it takes for these Regulations and for the 2010 Regulations, who holds the declaration of conformity and the technical documentation, and who will answer a question from the market surveillance authority. The same question arises for electrical safety: see luminaire conformity, EN 60598 and UKCA.

The product rules, and why ‘decorative’ is not an exemption

Two sets of rules sit beside regulation 6. The first is what the light source and the driver themselves must achieve. These are legal floors for a product placed on the market, measured at its factory default settings (the ‘reference control settings’), so tuneable-white and dim-to-warm sources are judged at those settings. They are not design targets: a designer who writes a colour rendering index of 90 or asks for a particular R9 value is asking for more than the Regulations do.

The second is the list of exemptions in Schedule 4. We read all of it. Each exemption is for a product that is specifically designed and marketed for a named use, and each asks for a statement of intended use. Decorative lighting is not a category.

The artist’s-work exemption points to regulation 4 of the Artist’s Resale Right Regulations 2006, which defines a ‘work’ as a work of graphic or plastic art such as a picture, sculpture, ceramic or item of glassware. A fitting made in a production run, or by a workshop to a designer’s drawing, is not obviously one. We do not suggest relying on it, and nothing here says any product qualifies. Part L is separate: the Approved Document L definition that includes chandeliers in ‘specialist process lighting’ is a Building Regulations term, and the 2021 Regulations contain no such category. See Part L and decorative lighting.

Status and dates

Dates matter here: the instrument was amended in 2025 and 2026 (for other products) and a statutory review has just reported. Each row says what we saw and when. We read the revised text served by legislation.gov.uk on 5 November 2026 and looked again on 6 November, when it was unchanged.

Two cautions. A ‘revised’ text on legislation.gov.uk can lag behind amendments, so a compliance adviser should check for later instruments before relying on any date here. And this sheet covers ecodesign and energy labelling only. Electrical safety, electromagnetic compatibility, restricted substances and waste each have their own rules, which are not read here: see luminaire conformity for the first of them.

For each luminaire and each lit joinery item the supplier is to state in writing, before shop drawing approval: (a) whether each light source and each separate control gear can be replaced with commonly available tools and without permanent damage to the product, and how (tools, access route, hatch size [ ] mm); (b) where it cannot, the technical justification related to the functionality of the product; (c) the removal and dismantling instructions. These are the matters in regulation 6 of SI 2021/1095 [where it applies]. The statement is to say whether the supplier acts as manufacturer, authorised representative or importer for that instrument and for SI 2010/2617.

The supplier is to provide, for each light source and each driver: model identifier; luminous flux; correlated colour temperature [ ] K; colour rendering index not less than [90] (the legal minimum for a light source is 80, with stated exceptions); beam angle where relevant; whether dimmable and the dimmer or protocol it is compatible with [ ]; and the energy efficiency class statement for the user manual (Schedule 8 paragraph 3 of SI 2021/1095).

The supplier is to provide the declaration of conformity for each luminaire, driver and light source, stating the marking used [UKCA / CE], and to confirm in writing that the technical documentation is held and for how long [10 years]. Documents are to be filed in part 03 of the lighting handover pack, by fitting tag, within [ ] days of practical completion.

Standards and sources

• SI 2021/1095, Ecodesign for Energy-Related Products and Energy Information (Lighting Products) Regulations 2021: revised text valid from 10 Apr 2026; read 5 and 6 Nov 2026.
• SI 2010/2617, Ecodesign for Energy-Related Products Regulations 2010: revised text valid from 27 Jul 2026; regs 2, 3, 4, 14, Sch 1.
• OPSS: Regulations, ecodesign of energy-consuming products: updated 8 Apr 2026; list of products and legislation, Jan 2026.
• DESNZ: Post Implementation Review for Energy-related Products: cover dated 2 Nov 2026; recommendation: keep.
• Artist's Resale Right Regulations 2006, regulation 4: definition of a work; read 5 Nov 2026.

Questions we are asked

Do the UK lighting ecodesign rules apply to bespoke chandeliers and pendants?

They apply to the light sources and drivers placed on the market, and through regulation 6 to a luminaire that contains them. We found no exemption for decorative, bespoke or one-off luminaires: Schedule 4 lists specific uses. Whether a particular fitting is a containing product placed on the market, and who is its manufacturer, is a legal question; ask the supplier to state its position in writing.

Can an LED module be sealed in so that it cannot be replaced?

Only with a technical justification, related to the functionality of the product, in the technical documentation (regulation 6(2)). Otherwise light sources and separate control gear must be replaceable with commonly available tools and without permanent damage. Ask for the replaceability statement and, where there is a justification, ask to see it.

Is lit furniture or joinery covered?

The definition of a containing product names ‘furniture containing light sources (for example display cabinets)’. What the text does not say is whether fitted, site-built joinery is placed on the market, or who the manufacturer is when joinery is designed by one party and made by another. The government’s 2026 review notes industry confusion over the definition. Design for replacement either way.

Does a decorative luminaire need an energy label?

The energy label is for a light source placed on the market as an independent product in packaging. For a light source inside a containing product the supplier states its energy class in the user manual (Schedule 8 paragraph 3). Check with the supplier what its product ships with.

How is this different from Part L of the Building Regulations?

Part L is about the energy use of a building’s fixed services and is guidance for building work in England. The ecodesign rules are product regulations that apply to what is placed on the market. Part L names chandeliers within ‘specialist process lighting’; the ecodesign Regulations have no such category, so being outside Part L does not put a chandelier outside these rules.

Are the rules the same in Northern Ireland?

No. SI 2021/1095 extends to England, Wales and Scotland. The OPSS list of energy-related products, updated January 2026, names Commission Regulation (EU) 2019/2020 and Delegated Regulation (EU) 2019/2015 for Northern Ireland. We did not read those instruments.

Does the studio say its lighting complies?

No. This sheet is guidance for specifiers and says nothing about any product. For any commission, ask each party for its declaration of conformity, its replaceability statement and its role under the Regulations, in writing.