Regulatory framework

The lighting sector has become flooded with LED replacement gear trays. It is vital that the regulatory framework is factored into your buying decision.

What you need to consider

We believe that it is important for our customers to fully understand which retrofit solution is best suited to fit our products and how to choose them. As well as ensuring full and reliable compatibility, it is vital that the regulatory framework, and your legal obligations, are met.

Is your product CE marked?

The CE mark demonstrates regulatory compliance with the LVD, EMC, ErP and RoHS Directives.

CE marking recertification

Retrofitting into an existing fluorescent luminaire constitutes a fundamental alteration. When a retrofit LED gear tray replaces an existing fluorescent light source, the luminaire in its entirety will need to be tested, certified and CE marked. A technical construction file will need to be prepared. It is not acceptable to simply supply a CE marked gear tray and assume that the product in its entirety will comply.

Remember the golden rule CE + CE doesn’t equal CE. Re-certification and CE marking as a new product is mandatory.

Compliance with the Consumer Protection Act (CPA)

Under the CPA a retrofit gear tray supplier must take on the legal responsibility for the entire product.

Ingress protection of the modified luminaire

The retrofit supplier is responsible for ensuring the IP rating is maintained. Any new gaskets or components must be to the original manufacturer’s specification and installed using the same application method. Otherwise, testing and recertification will be required.

Building regulations – Part L assessment

To enable assessment against part L of the building regulations, the photometric performance of the modified luminaire must be known. Testing is required – photometric data cannot be estimated.

Lighting performance, comfort and quality

Using a genuine Designplan gear tray will help control glare and maximise efficiency, and we will provide confirmation of the CCT and CRI. When upgrading to LED the task lighting levels must be recalculated to ensure the application lux level is still maintained. This is very important in an integral emergency light fitting, as the light distribution in the new luminaire may differ from the original fluorescent.

LED compatibility

The retrofit gear trays we supply are tested to help prevent the effect, over time, of Volatile Organic Compounds (VOC’s) generated by new and existing parts, components and finishes.

Operational life of your retrofit solution

Designplan tests our retrofit gear trays for heat generation. This safeguards against the possibility of excessive heat inside the luminaire and protects the operational life of LEDs.


The warranty of Designplan supplied gear trays extends to all parts of the modified luminaire, including existing parts, and only applies when we retrofit a Designplan luminaire.

Construction design and management (CDM)

Using genuine Designplan gear trays ensures our customers have engaged a supplier who has the capability to carry out modification works and who can provide supporting evidence as required by the CDM regulations.

Waste Electric and Electronic Equipment (WEEE)

Designplan are proud to be a supplier who can demonstrate our process to recycle a lighting product at the end of its useful life, under the scope of the WEEE Directive.

CIBSE accredited CPD

We have a CIBSE accredited CPD presentation available on this subject. For more information about this 1 hour seminar CLICK HERE