The Environment Agency has recently (17/08/15) released a statement to clarify government guidance on non-household luminaries with integrated LEDs.
In this statement, the EA has confirmed:
It has come to our attention that there has been some confusion within Industry on which category non-household luminaires with integrated (non-removable) LEDs should be reported in.
We have sought clarification from BIS, and they have confirmed that non-household luminaires with integrated (non-removable) LEDs should be reported in category 5. The reasoning being that the LEDs become a component part of a finished product, and that this is consistent with the EU FAQs.
This decision supersedes the previous BIS Government guidance notes dated March 2014.
We now advise any members who are reporting non-household luminaries with integrated LEDs to contact us on 0845 680 9829 for advice on reporting.