Direct answer: The 0.5 W ceiling on your smart luminaire’s standby and networked standby power comes from Regulation (EU) 2019/2020, not from Regulation (EU) 2023/826. Regulation 2023/826, which applies from 9 May 2025 and replaced (EC) No 1275/2008, sets off, standby and networked standby limits for the household and office equipment groups listed in its Annex II — and lighting equipment is not one of them. When a supplier defends a 0.9 W connected fixture by quoting the “2 W networked standby allowance”, they are quoting the wrong regulation. Your luminaire is measured against 0.5 W, and for a connected light source the standby and networked standby allowances do not even add up.
This is one of the most common compliance mix-ups we see in smart lighting tenders, and it is expensive in both directions: buyers accept non-compliant fixtures because they believe a lenient limit applies, and suppliers burn engineering budget chasing a 2 W target that was never theirs. Here is how the two regulations divide the territory.
What Regulation 2023/826 actually covers
Regulation (EU) 2023/826 was published in the Official Journal on 18 April 2023 and applies from 9 May 2025, replacing Regulations (EC) No 1275/2008 and (EC) No 107/2009. It is a horizontal ecodesign regulation: it governs power consumption in off mode, standby mode and networked standby for the electrical and electronic household and office equipment listed in its Annex II. That list covers appliances designed for household use, information technology equipment intended primarily for the domestic environment, consumer equipment such as radios and streaming devices, toys and leisure equipment, adjustable furniture, and motor-operated building elements such as shutters and blinds. Lighting equipment is not among the listed product groups.
The limits themselves live in Annex III, with a second, tighter stage two years after the regulation’s application date:
| Mode | Limit from 9 May 2025 | Limit from 9 May 2027 |
|---|---|---|
| Off mode | 0.50 W | 0.30 W |
| Standby, reactivation function only | 0.50 W | 0.50 W |
| Standby with information or status display | 0.80 W | 0.80 W |
| Networked standby, HiNA equipment | 8.00 W | 7.00 W |
| Networked standby, other equipment | 2.00 W | 2.00 W |
HiNA — high network availability — equipment means the devices whose job is to keep the network up: broadband modems, routers, access points and the like. Everything else networked gets 2.00 W. The regulation also imposes functional duties: networked equipment must switch itself into networked standby within 20 minutes when no main function is running, unless another product depends on it, and users must be able to deactivate wireless network ports unless wireless is essential.
Those 2 W and 8 W figures are real and widely quoted. The mistake is applying them to a luminaire.
The regulation that actually sets your luminaire’s power limit
For light sources and separate control gears, the product-specific ecodesign regulation is (EU) 2019/2020, often called the single lighting regulation or SLR. It has applied since 1 September 2021, and it carries the binding low-power limits that market surveillance authorities actually check on lighting products:
- The standby power of a light source must not exceed 0.5 W.
- The networked standby power of a connected light source must not exceed 0.5 W.
- The allowable values for standby and networked standby must not be added together.
- A separate control gear has the same 0.5 W ceilings for standby and for networked standby, and its no-load power must not exceed 0.5 W.
The regulation also requires this data to be published: standby power and, where applicable, networked standby power belong on the packaging and on the manufacturer’s free-access website for separate control gears. So the number is not supposed to be a secret buried in a test report — if a supplier cannot produce a Psb and Pnet figure for a connected product, that is already a red flag. The same transparency duty applies to product registration in the EU database; see our guide to EPREL rules for LED luminaires. For more on how 2019/2020 reshapes luminaire construction, see our guide to replaceable light source rules.
The definition that decides which limit you get
Everything hinges on whether your product is a connected light source (CLS) or a connected separate control gear (CSCG). The regulation defines these as a light source or control gear that includes data-connection parts physically or functionally inseparable from the light-emitting or control parts — parts that transmit or receive wired or wireless data signals, or sense and process signals, to control light emission or to maintain the reference control settings.
Read that carefully, because it is a configuration test, not a technology test. A WiFi ceiling fixture whose radio is soldered into the driver housing and needed to keep the light’s settings is a connected light source: 0.5 W applies. A plain driver plus a plug-in wireless node shipped separately keeps the two identities apart — the node is not part of the light source, and the luminaire keeps its simpler compliance profile. The same logic decides whether your driver is a connected separate control gear.
| Configuration | Classification under 2019/2020 | Low-power limit |
|---|---|---|
| Driver with integrated, inseparable radio or sensor needed for its settings | Connected light source / connected separate control gear | Standby 0.5 W and networked standby 0.5 W, non-additive |
| Plain driver plus separately supplied wireless node | Light source / control gear; node is a separate product | 0.5 W on the driver; node assessed on its own merits |
| Driver with a hard-wired switch to fully deactivate wireless | Depends on whether data-connection parts remain functionally inseparable | Confirm with the test lab before claiming a limit |
| Luminaire whose radio only serves an optional app function | Frequently argued either way | Treat as connected until documented otherwise |
The last two rows are the honest ones. Configuration edge cases are settled by measurement and documentation, not by datasheet wording, and this is exactly the kind of question you want answered before a shipment rather than during one. The verification route for low-power modes of lighting equipment is standardized — IEC 63103 covers power measurement in non-active modes for lighting products — so a competent lab can give you a defensible number.
Where 2023/826 still reaches into a lighting project
Concluding that a luminaire is outside 2023/826 is not the end of the analysis. The regulation still shapes connected lighting projects in three ways.
First, the network side. The router, switch or access point your lighting gateway depends on is HiNA equipment with an 8 W networked standby allowance, tightening to 7 W from 9 May 2027. Any other networked box in the installation — a media player, a smart display, a household appliance — gets 2 W. If your lighting solution ships as part of a wider kit of networked devices, those devices carry their own limits, and their power management duties shape how aggressively they can be put to sleep.
Second, documentation discipline. 2023/826 tightened the information duties on networked equipment, requiring manuals and free-access websites to state power consumption per mode and how long the product takes to reach its low-power condition. EU buyers now increasingly expect the same discipline from lighting suppliers, and many tender templates simply copy the requirement across. Answering it well is a commercial advantage, not paperwork.
Third, the direction of travel. The Commission prefers product-specific ecodesign measures where they exist, which is why lighting sits under 2019/2020 today. Policy pressure on always-on electronics keeps rising, and any future revision of the lighting regulation will be written against the backdrop of these stricter horizontal limits. Designing a connected luminaire that sips well under 0.5 W today is cheap insurance against a tighter number later.
How suppliers get this wrong on spec sheets
Four patterns show up again and again in connected lighting quotations:
- Quoting the wrong limit. “Networked standby 2 W is allowed” belongs to 2023/826’s non-HiNA equipment. For a connected light source the ceiling is 0.5 W.
- Adding the allowances. The regulation explicitly forbids adding standby and networked standby values together. A fixture at 0.4 W standby plus 0.4 W networked standby is not compliant “because each is under 0.5 W in its mode” — the limits do not stack.
- Testing with the radio disabled. The standby limit for networked equipment is measured with wired ports disconnected and wireless ports deactivated, but the networked standby limit is not. A figure measured only with the radio off says nothing about compliance.
- Silence on Psb and Pnet. For separate control gears these values are mandatory packaging and website information. A datasheet that omits them is telling you something.
What to demand from your supplier
- Declared standby power and networked standby power for the light source and for the separate control gear, in watts, with the test method stated.
- A written statement of whether the product is classified as a connected light source or connected separate control gear, and why the data-connection parts are inseparable.
- Whether the networked standby figure was measured with the radio active, and at which network state.
- For drivers: the no-load power figure, which must also stay at or below 0.5 W.
- If the wireless function can be disabled by the end user, the measured power in that condition and instructions for disabling it.
Ask for these five items with the quotation, not after the purchase order. Suppliers who test properly can produce them within a day; suppliers who cannot usually discover, mid-project, that their number was never measured.
Frequently asked questions
Does EU Regulation 2023/826 apply to LED luminaires?
Lighting equipment is not one of the product groups listed in Annex II of 2023/826, so the luminaire itself falls outside its scope. The binding standby and networked standby limits for light sources and separate control gears come from the product-specific regulation (EU) 2019/2020. Networked devices installed alongside the lighting — routers, media devices, appliances — are covered by 2023/826 in their own right.
What is the standby power limit for a connected light source?
Under Regulation (EU) 2019/2020, standby power must not exceed 0.5 W and the networked standby power of a connected light source must not exceed 0.5 W. The two values must not be added together. The same ceilings apply to separate control gears, along with a 0.5 W no-load limit.
Why do people keep quoting a 2 W allowance?
Because 2.00 W is the networked standby limit in Regulation 2023/826 for networked equipment that is not HiNA, such as smart TVs and other connected consumer devices. It is the correct number for those products and the wrong one for lighting, which is governed by its own product-specific measure.
Can we avoid the 0.5 W limit by shipping the radio separately?
Often, yes, and that is a legitimate design strategy: a light source and separately supplied data-connection parts are not automatically one product. But classification depends on how the parts are placed on the market and whether they are needed to maintain the reference control settings. Document the split properly and confirm it with the test lab before relying on it.
Which number should go in the tender response?
The declared Psb and Pnet from the light source or control gear test report, with the test method named. If your product is a separate control gear, the same values plus the no-load power. Numbers quoted from the horizontal 2023/826 table will not survive a market surveillance check on a lighting product.
This article is a procurement guide, not legal advice. Confirm requirements for your specific product and market with a qualified compliance provider.
