LED mirrors do not need to be registered in the EPREL database, because the law classifies them as contained products. This means they are not considered standalone light sources. This status results from their design and the definitions set out in EU regulations.
Definition of a contained product
An LED mirror contains a light source or control gear. However, it is not considered a lighting product that requires its own energy label. Regulation 2012/341 defines a contained product as an item that includes at least one light source or one separate control gear. This definition also covers luminaires and furniture. Furniture includes shelves, mirrors, and display cabinets. As a result, LED mirrors are treated as contained products rather than independent light sources.
Requirement for light source removal
A manufacturer or importer must allow the removal of the light source from a contained product. This requirement supports inspections carried out by market surveillance authorities. The removal must make it possible to assess the light source without damaging it. It does not concern user convenience. The principle is that a laboratory must be able to remove the component even if doing so requires destroying the mirror itself. The key requirement is that the light source or control gear remains intact.
Information required in instructions
The instructions for a contained product must describe the removal process. The user must be informed that the light source in the mirror is not intended to be replaced by the consumer. There may also be a note stating that the entire product should be disposed of at the end of its service life. Such information is compliant with the law. It follows from the product's construction and the rules governing laboratory verification.
Information obligations for manufacturers
A manufacturer or importer must also provide information on the energy efficiency class of the light source. This applies to documentation and user instructions. It must be clearly stated whether the light source can be replaced. In LED mirrors such replacement is typically not possible. Information about the impossibility of replacement must appear on both the packaging and in the instructions.
Labelling of LED mirrors
An energy label for a light source must not be placed on an LED mirror. Doing so could mislead the consumer. Energy labels apply only to standalone light sources. Market surveillance authorities may consider such labelling to be a violation of the regulations. Manufacturers must therefore ensure correct marking and full compliance with the applicable legislation.
Why LED mirrors do not enter EPREL?
LED mirrors remain outside the EPREL registration requirement because the system applies only to actual light sources. Contained products such as LED mirrors are not added to the database. However, manufacturers must still provide clear information to the consumer and ensure full compliance with technical requirements.
Use RCC support
Meeting the requirements for LED mirrors demands accurate documentation and clear marking, making it worth working with full awareness of the regulations. To minimise the risk of errors when placing a product on the market, it is advisable to consult experts who will guide you through the entire process. Contact RCC to request a conformity analysis and comprehensive support with documentation.