Non-compliant Lighting Products are Just One Click Away

LightingEurope conducted a series of online mystery shopper exercises in 2020 and 2021, looking at 2 lighting products (an LED GLS replacement lamp and a desktop luminaire) on 4 platforms across 5 EU Member States - France, the Netherlands, Italy, Poland, and Spain. The exercise only focused on the product information required under EU and national legislation. The mystery shoppers entered the same search term and looked at the first 20 results that the algorithm of the online platform selected.

“The results are alarming. Only 8% of the first 20 products that the online platform algorithm proposed to our shoppers complied with the mandatory information requirements set out in EU law. Customers are being offered products that do not have a CE mark, that do not have an energy label or have the wrong label, or that do not pay towards the collection and recycling of the product at end of life,” stated Ourania Georgoutsakou, Secretary General of LightingEurope.

“Making non-compliant products available not only puts customers at risk. It also places those law-abiding companies who manufacture or sell compliant products at a competitive disadvantage,” she added.

“We must fix the EU legal framework to address product non-compliance online. The Digital Services Act must clearly allocate liability for all forms of non-compliance: not only when the product poses a safety risk, but also when it does not meet all labelling or information requirements, or when it does not contribute to waste recovery and recycling fees,” Ourania concluded.

The LightingEurope mystery shopping exercises also showed that:

• 30 products were purchased online and delivered to our mystery shoppers. Following inspection, 77% of the products received did not comply with EU laws. Some products did not have a CE mark, even though they were sold on websites clearly targeting the EU market.
• none of the desktop luminaires bought in France complied with WEEE obligations. None of the suppliers were registered with the French Extended Producer Responsibility scheme, which means that these products and their suppliers are not contributing to the cost of collecting and recycling the product at end of life.
• none of the lamps purchased in the Netherlands complied with the requirements on the energy efficiency label – they either did not display a label, or the label was not used correctly.

Further details on the LightingEurope mystery shopping exercises are available here.

LightingEurope has published recommendations for the Digital Service Act “Non-compliance of products on the EU market: How to address product compliance online?

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