URG 19 downlight spots are > URG 19 when used

I'm working on a project where I want to use downlight spots 60 degr with UGR <19.

I used all the well known brands. Zumtobel, Gewiss, Fagerhult, Philips and more. all say in the specs that the URG is below 19. But when I use them at mounting hight 2,7m and 1,2-1,6m offset UGR all are more than 19. What do I do wrong? Somebody a Idea.

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