The basis is the EU Blue Guide (2022) and its definition of “significant changes of products”. If no significant changes are made to the performance, application or construction when converting an existing luminaire with old lighting technology to LED technology, no new product will be created. The electrician making the conversion will therefore not become a manufacturer and a new CE declaration of conformity will not be required. Along with the 1:1 retrofit solution, this makes it very easy to convert existing luminaires to efficient LED lamps cost-effectively.