What efficiency regulations govern smart switches in the EU?

last updated: Mar 24, 2025

After measuring the standby power consumption of various Zigbee and Z-Wave devices, I became curious about what efficiency regulations governed them. The EU has typically been at the forefront of energy use regulations, famously introducing the idea of a common charger back in 2009 before later mandating it, and issuing ecodesign requirements for transformers as early as 2009 (EC No 278/2009). Infact their first energy labelling directives were issued way back in in 1979.

So which regulations cover smart switch power use?

It’s a good question and one that wasn’t straightforward to find a a concrete answer to. If you have some expertise in this space, please let me know your thoughts. Below is a layman’s interpretation of the current rules:

Key smart switch adjacent regulations

  • (EC) 1275/2008 (amended by (EU) No 801/2013 / (EU) 2019/2021, and repealed by (EU) 2023/826)
    • Scope listed in Annex 1 - smart switches don’t fit any category.
    • (EU) No 801/2013 adds various network equipment and networked standby mode, but nothing covering smart switches.
    • (EU) 2019/2021 added electronic displays and tightened efficiency requirements.
    • (EU) 2023/826 repealed the original regulation and expanded the products, but doesn’t cover lighting or smart switches.
  • (EC) No 278/2009
    • Adds external power supplies, which were missed by 1275/2008.
    • And adds no-load (i.e. disconnected) efficiency requirements.
  • (EU) 1194/2012
    • Specifically covers “directional lamps, light emitting diode lamps and related equipment”.
    • Unfortunately control devices are not included in the efficiency requirements under the reg.
  • (EU) 2019/1782
    • Expands in-scope products in Annex 1, but still nothing that a smart switch would qualify for.
    • Expands power supply coverage to multi-voltage supplies.
  • (EU) 2019/2020
    • Finally we have something that covers smart switches explicitly.
    • Smart switches would seem to qualify as connected separate control gear and smart bulbs as a connected light source.
    • Amended by (EU) 2021/341, but no relevant changes.
    • Consumption requirements are 0.5W under no-load, standby, and networked standby.

So the answer as of 2025 appears to be: 0.5W under no-load, standby, and networked standby.

[Connected] separate control gear

All modes are 0.5W:

  • No-load (0.5W)
  • Standby (0.5W)
  • Networked standby (0.5W)

I also found “guidance” for manufacturers of Zigbee/Z-Wave etc. USB sticks and hubs in the EU Code of Conduct on Energy Consumption of Broadband Equipment (latest V9.0, 2024).

This is a code of conduct, not a regulation, and as such is voluntary:

Hubs and USB-dongles

Zigbee/Z-wave USB dongles

  • Ready-state (0.1W):
    Inactive, but ready to detect activity or pass user traffic.
  • On-state (0.1W):
    Active, with traffic: 10 kbit/s

Hubs (CPE central functions - Home Gateways - Throughput < 1Gbps)

  • Ready state (1.2W)
  • One state (1.4W)

A bit more detail

(EC) No 1275 /2008​ / (EU) No 801/2013 / (EU) 2019/2021

Implementing Directive 2005/32/EC of the European Parliament and of the Council with regard to ecodesign requirements for standby and off mode electric power consumption of electrical and electronic household and office equipment,

This directive was amended by (EU) No 801/2013 and (EU) 2019/2021.

Despite possibly qualifying as “networked equipment with high network availability functionality" under the (EU) No 801/2013 amendment, smart switches are not included in any category listed in the original Annex I listed and are specifically excluded in the below, verbosely titled, November 2014 document:

Lighting and lamp control gear and devices are not covered. Therefore, smart lamps and devices installed between the mains and the lamp, which can be controlled by e.g. a smart phone over a network connection, are not covered. These are covered by the regulation (EU) 1194/2012.

Guidelines accompanying Commission Regulation (EU) No 801/2013 of 22 August 2013 amending Regulation (EC) No 1275/2008 with regard to ecodesign requirements for standby, off mode electric power consumption of electrical and electronic household and office equipment, and amending Regulation (EC) No 642/2009 with regard to ecodesign requirements for televisions

So smart switches are out of scope and covered by the regulation (EU) 1194/2012. Right?

(EU) 1194/2012 specifically excluded smart switches from its efficiency requirements

The scope of the regulation is listed as covering (emphasis mine):

(a) directional lamps;
(b) light-emitting diode (LED) lamps;
(c) equipment designed for installation between the mains and the lamps, including lamp control gear, control devices and luminaires (other than ballasts and luminaires for fluorescent and high-intensity discharge lamps);

including when they are integrated into other products.

(EU) 1194/2012

Section (c) would seem to cover smart switches, but then we have the following definitions:

‘control device’ means an electronic or mechanical device controlling or monitoring the luminous flux of the lamp by other means than power conversion, such as timer switches, occupancy sensors, light sensors and daylight regulation devices. In addition, phase cut dimmers shall also be considered as control devices;

’lamp control gear’…The term does not include:…control devices

(EU) 1194/2012

So to summarise:

  • Smart switches appear to be control devices, but
  • control devices are specifically excluded from the lamp control gear category.
  • lamp control gear and directional lamps are the only items with efficiency requirements in this regulation (under section 1) - control devices are not covered.
So smart switches are in scope under 1194/2012, but there are no efficiency requirements for them.

In 2019 we finally have something that addresses modern switching devices

Commission Regulation (EU) 2019/2020 of 1 October 2019 laying down ecodesign requirements for light sources and separate control gears

https://eur-lex.europa.eu/eli/reg/2019/2020/oj/eng

This regulation restricts smart switches to 0.5W power consumption when not on. The relevant definitions are:

(5) ‘connected light source’ (CLS) means a light source including data-connection parts that are physically or functionally inseparable from the light emitting parts to maintain the ‘reference control settings’. The light source can have physically integrated data-connection parts in a single inseparable housing, or the light source can be combined with physically separate data-connection parts placed on the market together with the light source as a single product;

(6) ‘connected separate control gear’ (CSCG) means a separate control gear including data-connection parts that are physically or functionally inseparable from the actual control gear parts to maintain the ‘reference control settings’. The separate control gear can have physically integrated data-connection parts in a single inseparable housing, or the separate control gear can be combined with physically separate data-connection parts placed on the market together with the control gear as a single product;

(7) ‘data-connection parts’ means parts that perform any one of the following functions:

  • (a) reception or transmission of wired or wireless data signals and the processing thereof (used to control the light emission function and possibly otherwise);

  • (b) sensing and processing of the sensed signals (used to control the light emission function and possibly otherwise);

  • (c) a combination of these;

(17) ‘full-load’ means:

  • the condition of a light source, within the declared operating conditions, in which it emits the maximum (undimmed) luminous flux; or
  • the operating conditions and loads of the control gear under efficiency measurement as specified in the relevant standards;

(18) ‘no-load mode’ means the condition of a separate control gear in which its input is connected to the mains power source and its output is intentionally disconnected from light sources, and, if applicable, from lighting control parts and non-lighting parts. If these parts cannot be disconnected, they shall be switched off and their power consumption shall be minimised following the manufacturer’s instructions. No-load mode only applies to a separate control gear for which the manufacturer or importer has declared in the technical documentation that it has been designed for this mode;

(19) ‘standby mode’ means the condition of a light source or of a separate control gear, where it is connected to the power supply but the light source is intentionally not emitting light, and the light source or control gear is awaiting a control signal to return to a state with light emission. Lighting control parts enabling the standby function shall be in their control mode. Non-lighting parts shall be disconnected or switched off or their power consumption shall be minimised following manufacturer’s instructions;

(20) ‘networked standby mode’ means the condition of a CLS or a CSCG where it is connected to the power supply but the light source is intentionally not emitting light or the control gear does not supply the electric power that enables light source(s) to emit light, and is awaiting a remotely initiated trigger to return to a state with light emission. Lighting control parts shall be in their control mode. Non-lighting parts shall be disconnected or switched off or their power consumption shall be minimised following manufacturer’s instructions;

(21) ‘control mode’ means the condition of lighting control parts where they are connected to the light source and/or to the separate control gear and performing their functions in such a way that a control signal can be internally generated or a remotely initiated trigger can be received, by wire or wireless, and processed to lead to a change in the light emission of the light source or to a corresponding desired change in the power supply by the separate control gear;

(22) ‘remotely initiated trigger’ means a signal that comes from outside the light source or separate control gear via a network;

  1. Energy efficiency requirements:

From 1 September 2021:

The no-load power Pno of a separate control gear shall not exceed 0,5 W. This applies only to separate control gear for which the manufacturer or importer has declared in the technical documentation that it has been designed for no-load mode.

The standby power Psb of a separate control gear shall not exceed 0,5 W.

The networked standby power Pnet of a connected separate control gear shall not exceed 0,5 W.

The allowable values for Psb and Pnet shall not be added together.

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