Clarity on CE marking when replacing luminaires to LED

In a helpful white paper , the Central Association of the Electrical and Electronic Industry (ZVEI-Germany) clarifies in which cases the existing CE marking can continue to apply and a new CE declaration of conformity is not required when traditional luminaires are upgraded to LED technology. For installers, this means greater planning certainty when using LED tubes.

When is a new declaration of conformity required when converting an existing luminaire with old lighting technology to LED technology - and when not? Until now, different positions have been taken in response to this question, leading to uncertainty in the market. ZVEI is now providing clarity with its recently published white paper.

The basis is the European Union Blue Guide (2022) and its definition of "significant changes to products," according to which a product's CE mark remains valid if no significant or risky changes have been made to its performance, application or construction. This means that an installer does not necessarily become a manufacturer when fitting luminaires with LED tubes, including rewiring, and does not have to issue a new CE declaration.

This gives installers four options for upgrading traditional fluorescent fixtures to efficient, long-lasting LED lighting:

LED lamps for retrofit 1.

LED bulbs for conversion

3. LED upgrade kits

New LED fixtures 4.

The choice of one of these solutions depends on several factors, such as the suitability of the existing lighting and the risk assessment. In particular, retrofitting or converting to LED tubes proves cost-effective and environmentally friendly because existing luminaires can be reused and additional electrical waste is avoided.

Waste and maintenance costs

The longer lifetime of LED light sources compared to conventional bulbs also reduces waste and maintenance costs. In addition, the lower energy consumption of LED light sources leads to a reduction in CO2 emissions, helping to combat climate change.

LEDVANCE strongly supports ZVEI's position and offers a variety of safe, efficient and EU-compliant LED solutions for switching from conventional luminaires to LED technology. For example, the most energy-efficient
LED tubes with 210 lm/W (EEL-A) that save up to 72% energy compared to conventional fluorescent lamps. Or the LED TUBE EXTERNAL system consisting of an LED tube and a separate external driver, which is perfect for DALI-2 controlled applications or in combination with emergency lighting.