EU Regulation 2019/2020, implementing the Ecodesign Directive (2009/125/EC) for light sources, is commonly referred to as "ErP Lot 21" in the lighting industry. It entered into force on September 1, 2021, and represents the most comprehensive overhaul of EU lighting regulations since the incandescent phase-out began in 2009.

For buyers sourcing decorative LED lamps for the European market — importers, distributors, lighting specifiers, and procurement managers — Lot 21 compliance is not optional. Non-compliant products cannot legally be placed on the EU market. Customs authorities in major EU ports (Rotterdam, Hamburg, Antwerp) have been conducting increased inspections of lighting product shipments since 2022, and non-compliant products are subject to seizure and destruction at the importer's cost.

This guide explains what Lot 21 requires, which products are affected, what the minimum performance thresholds are, what documentation is required, and how to verify that a supplier's products are genuinely compliant.

Scope: Which Products Are Covered by Lot 21?

Lot 21 covers "light sources" — a broad category that includes almost all electrically powered light sources placed on the EU market. The regulation specifically covers:

Included product categories:

• LED lamps (all types, including decorative filament lamps)
• Fluorescent lamps (T5, T8, compact fluorescent)
• High-intensity discharge lamps (metal halide, high-pressure sodium)
• Incandescent lamps (subject to separate phase-out regulations)
• Light sources integrated into luminaires (where the light source is separately replaceable)

Excluded product categories:

• Light sources with a rated power ≤ 2W (exempt from efficacy requirements but subject to other requirements)
• Light sources specifically designed for non-general lighting applications (e.g., medical, automotive, theatrical, photographic)
• Light sources with a color rendering index < 60 (exempt from efficacy requirements)
• Light sources with a correlated color temperature outside the range 1,000K–20,000K

Decorative LED filament lamps: Standard decorative LED filament lamps (ST64, G95, G125, A60, T45, C35, etc.) with rated power > 2W and CRI ≥ 60 are fully covered by Lot 21. There is no exemption for "decorative" or "vintage" styling.

The Minimum Efficacy Requirements

The core energy efficiency requirement of Lot 21 is a minimum luminous efficacy — the ratio of light output (lumens) to electrical power input (watts), expressed in lm/W.

Efficacy Thresholds by Product Category

For LED lamps (including decorative filament lamps), the minimum efficacy thresholds are:

Non-directional LED lamps (which includes all decorative filament lamps):

Color Temperature	Minimum Efficacy (lm/W)
2,700K	85 lm/W
3,000K	85 lm/W
4,000K	90 lm/W
6,500K	95 lm/W

Important note for decorative filament lamps: The 85 lm/W threshold at 2,700K is the minimum. Many decorative LED filament lamps on the market — particularly those with amber glass envelopes, which absorb a significant portion of the lamp's light output — fail to meet this threshold.

The Amber Glass Problem

Amber glass envelopes are the most common compliance challenge for decorative LED filament lamps. An amber glass envelope absorbs 15–30% of the lamp's light output, reducing the measured lumen output and therefore the measured efficacy.

Example: A decorative LED filament lamp with a clear glass envelope produces 450 lm at 4W = 112.5 lm/W (compliant). The same lamp with an amber glass envelope that absorbs 25% of the light output produces 338 lm at 4W = 84.5 lm/W (non-compliant — below the 85 lm/W threshold).

To produce an amber glass decorative LED filament lamp that meets the 85 lm/W threshold, the manufacturer must either:

1. Use a higher-efficacy LED chip and driver to compensate for the glass absorption, or
2. Use a lighter amber tint that absorbs less light (typically ≤ 15% absorption), or
3. Increase the lamp's rated power (which increases lumen output but also increases energy consumption)

Luminaries Factory's amber glass decorative LED filament lamps are designed to meet the 85 lm/W threshold despite the glass absorption, using high-efficacy LED chips and optimized driver design. Our compliance test reports are available on request.

Energy Labelling Requirements

In addition to the minimum efficacy requirements, Lot 21 requires that all covered light sources carry an EU energy label. The energy label uses a scale from A (most efficient) to G (least efficient).

Energy Label Classes for LED Lamps

The energy label class is determined by the lamp's efficacy relative to a reference efficacy:

Energy Label Class	Efficacy Relative to Reference
A	≥ 210% of reference
B	185–210% of reference
C	160–185% of reference
D	135–160% of reference
E	110–135% of reference
F	85–110% of reference
G	< 85% of reference

The reference efficacy is calculated from the lamp's rated lumen output using a formula specified in the regulation. For a 450 lm lamp at 2,700K, the reference efficacy is approximately 75 lm/W. A lamp producing 450 lm at 4W (112.5 lm/W) achieves 150% of the reference efficacy, placing it in energy label class D.

Practical implication: Most decorative LED filament lamps on the EU market fall into energy label classes D, E, or F. Class A and B are reserved for the most efficient LED lamps (typically non-decorative, high-efficacy products). Class G products cannot be placed on the EU market (they fail the minimum efficacy requirement).

Label Display Requirements

The energy label must be displayed:

• On the product packaging (printed or affixed)
• In online product listings (as a digital label image)
• At the point of sale (for physical retail)

The label must include: the energy class (A–G), the rated power consumption (W), the rated lumen output (lm), the color temperature (K), and the rated lifetime (hours).

Declaration of Conformity (DoC) Requirements

Lot 21 requires that manufacturers or importers placing covered light sources on the EU market prepare and maintain a Declaration of Conformity (DoC). The DoC is a legal document in which the manufacturer or importer declares that the product meets all applicable EU regulations.

DoC Content Requirements

The DoC must include:

• Product identification (model name, model number, description)
• Name and address of the manufacturer or importer
• Reference to the applicable EU regulations (Regulation 2019/2020, Regulation 2021/341 for energy labelling)
• Reference to the harmonized standards used to demonstrate compliance (EN 62560 for LED lamps, EN 55015 for electromagnetic compatibility)
• Test report references (from an accredited laboratory)
• Date and place of issue
• Signature of the authorized representative

Technical Documentation

In addition to the DoC, manufacturers must maintain technical documentation that supports the compliance declaration. This documentation must be available to EU market surveillance authorities on request and must be retained for 10 years after the last product is placed on the market.

Technical documentation includes:

• Product design drawings and specifications
• Bill of materials
• Test reports from accredited laboratories (photometric performance, electrical safety, electromagnetic compatibility)
• Quality management system documentation
• Risk assessment

Importer responsibility: If you are importing decorative LED lamps from a non-EU manufacturer (e.g., a Chinese manufacturer), you are the "importer" under EU product liability law and are responsible for ensuring that the products meet all applicable EU regulations. You cannot rely solely on the manufacturer's DoC — you should verify compliance through independent testing and maintain your own technical documentation.

Verifying Supplier Compliance

Step 1: Request the DoC

Ask the supplier for a copy of the Declaration of Conformity for each product you are sourcing. The DoC should be in English (or another EU language) and should reference Regulation 2019/2020 specifically.

Red flags: A DoC that references only the CE Marking Directive (2014/30/EU) without referencing Regulation 2019/2020 is incomplete. A DoC that does not include test report references is unverifiable.

Step 2: Request Test Reports

Ask the supplier for test reports from an accredited laboratory demonstrating compliance with the minimum efficacy requirements. The test reports should be from a laboratory accredited by a national accreditation body (UKAS in the UK, DAkkS in Germany, COFRAC in France, or equivalent) and should reference the applicable test standards (EN 62560 for photometric performance).

Key data to verify in the test report:

• Measured lumen output (must be ≥ the rated lumen output on the energy label)
• Measured power consumption (must be ≤ the rated power on the energy label)
• Calculated efficacy (must be ≥ 85 lm/W for 2,700K–3,000K products)
• Color temperature (must be within ±10% of the rated CCT)
• CRI (must be ≥ 60 for the product to be covered by Lot 21; must be ≥ the rated CRI)

Step 3: Independent Verification

For high-volume purchases or new supplier relationships, commission independent testing of product samples through an accredited laboratory. The cost of independent testing (typically $200–$500 per product) is negligible compared to the cost of a customs seizure or a market surveillance enforcement action.

Luminaries Factory's full product range is tested by Intertek (an accredited laboratory) and all test reports are available to buyers on request. Our DoC for each product is available in English, German, French, and Dutch. Contact our compliance team to request documentation for specific products.