Government clarify how the WEEE regulations affect lighting equipment – particularly LED modules.
The EA have today published updated scope guidance for the WEEE regulations. The guidance is pragmatic, but some lighting producers will need to change the way they report the products they sell, where they supply luminaires incorporating user replaceable LED modules.
1. All business luminaires (conventional and LED integrated) are to be reported in category 5.
2. All lamps (gas discharge and LED) are to be reported in category 13. This also includes LED modules intended for use by an end-user.
3. Where LED luminaires contain a user replaceable LED light source (eg Zhaga module), then the LED module must be reported separately in category 13. The luminaire itself (minus the weight of the module) should be reported in category 5. This approach makes sense, and applies to LED luminaires the same logic used where luminaires are supplied containing fluorescent lamps (the weight of the fluorescent lamps and luminaire are reported separately).
4. All household luminaires remain out of scope (although there are likely to be changes when “dual use” guidance is available in early 2015. “Dual use” products are those that are likely to be used by householders and businesses.)
5. All LED subassemblies supplied to OEMs for incorporation into finished products are components and remain out of scope of the regulations.
6. Products that incorporate LED light sources (eg cooker hoods) or LED indicator lights continue to be reported in their own categories (eg large domestic appliances). The key change in this guidance therefore is the way in which user replaceable LED modules (and luminaires that contain such modules) are reported under the regulations.
Recolight and the LIA have supported the Government in the development of this guidance. Producer members of the Recolight compliance scheme will receive an update on any reporting changes that may be required.
