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Reusing and Upgrading to LED – What You Need to Know

06 Apr

For luminaire manufacturers, installers, and facility owners

Introduction

With the EU’s phase-out of mercury-containing fluorescent tubes (RoHS Directive), upgrading to LED is becoming the new standard. But switching from fluorescent to LED is not just a technical upgrade – it comes with new responsibilities around CE marking, safety standards, and documentation.

This guide summarizes what you need to know before starting a reuse or upgrade project.

Key Points to Consider

Point What It Means Comment
1. Conversion = New product Modifying a luminaire (e.g. installing LED modules) invalidates the original CE marking. The party performing the upgrade becomes legally responsible.
2. New CE marking may be required A new CE declaration is required if the product is sold or changes ownership. Not necessary if the luminaire remains in use by the original owner.
3. Chemical regulations still apply Converted products for resale must comply with current RoHS and REACH regulations. This can be difficult to ensure for luminaires made before the 2000s.
4. Conversion kit must be complete Includes drivers, cabling, sockets, and clear installation instructions in the local language. We supply full documentation with our modules.
5. Installation by certified professionals only Required by national electrical safety authorities. Converted luminaires must be labeled. Applies even if only the module is replaced.
6. EMC and electrical safety still apply Still required after modification, especially in systems with DALI, alarms, or building automation. A common compliance risk.
7. CE marking not always needed again No new CE marking is needed if the luminaire is not placed back on the market. See the EU’s “Blue Guide” for clarification.
8. Liability during retrofit LED module manufacturers are responsible for the module; retrofitters are responsible for the complete fixture. We recommend clearly documenting all roles.

Real-World Examples

Case Is new CE marking required?
Electrician upgrades luminaires with LED modules that remain in the same facility ❌ No
Company sells modified luminaires to a new customer ✅ Yes
Church replaces fluorescent tubes in 1800s chandeliers (internal use only) ❌ No

Tips When Reusing Luminaires

• Assess the condition of old components – aging wires or materials may be heat-sensitive or brittle.

• Always document the installation.

• Use components with proper technical documentation.

• Discuss responsibilities clearly – especially if building ownership changes.

Want to see how a smart, low-impact upgrade can be done right?
Check out our project at The Swedish School of Textiles.

Reuse and Smart Technology at The Swedish School of Textiles

Where Innovation Meets Sustainability At The Swedish School of Textiles, the future is about combining creativity with responsibility—not just in

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