LED lighting products are regulated by an array of EU directives and safety standards. This guide covers what European importers and Amazon sellers must know about electrical safety standards, EMC, heavy metals, CE marking, certification, and lab testing.
- LED light bulbs
- LED light strips
- LED luminaires
- LED lamps
- Smart home products
- IoT products
RoHS regulates hazardous substances in electronics products to reduce the environmental effect and health impact in the European Union. RoHS sets limits to hazardous substances (mainly heavy metals), and the current restrictions are listed below:
- Lead(Pb) : 0.1%
- Cadmium(Cd): 0.01%
- Mercury: 0.1%
- Hexavalent chromium (Cr6+) : 0.1%
- Polybrominated biphenyls (PBB): 0.1 %;
- Polybrominated diphenyl ethers (PBDE): 0.1 %
- Bis(2-Ethylhexyl) phthalate (DEHP): 0.1%
- Benzyl butyl phthalate (BBP): 0.1%
- Dibutyl phthalate (DBP): 0.1%
- Diisobutyl phthalate (DIBP): 0.1%
It is easy to find those restricted substances in LED lighting products, especially in the part of the coating, solder, and circuit board. Therefore, importers need to comply with RoHS before placing their LED products on the EU market.
Suppliers shall only use RoHS components to manufacture LED lighting products. It is important to instruct your suppliers about RoHS compliance before mass production. The reason is that your LED lighting products won’t be considered as RoHS compliant if they contain any non-RoHS compliant component.
RoHS Lab Testing
Not every supplier can provide RoHS test reports. Hence, it is common that importers would book a third-party lab testing for their LED lighting products. RoHS test is relatively inexpensive as each component starts from $10. It can possibly increase to a few hundred depends on the complexity of LED lighting products.
Here are some RoHS testing companies:
- Bureau Veritas
RoHS covered products including LED lighting products must be CE marked.
RoHS marking is not an official compliance mark, and it has no legal meaning by itself. However, it is still commonly used to indicate the product is RoHS compliant.
Components used to manufacture LED lighting products are not exclusively RoHS compliant. In other words, non-RoHS components containing excessive amounts of restricted heavy metals can find their way into your products, unless you take prevented measures. Here are a few examples:
- Instruct your LED products manufacturer to only procure RoHS compliant parts
- Procure RoHS compliant parts directly from component suppliers
- Submit LED lighting product samples for RoHS testing before shipment
Low Voltage Directive (LVD)
Many LED lighting product has an input voltage in the range of 50 to 1000V AC or 120 to 1500V DC. In this case, importers need to comply with the Low Voltage Directive (LVD) before the products can enter the EU market.
LVD Test Reports
Importers must either obtain a verifiable and valid LVD test report from the suppliers or book third-party testing to verify if the LED product is LVD compliant.
Established testing companies such as Intertek, SGS, and CMA Testing, provide LVD compliance services for LED lighting products, including lab testing, certification, documentation, and other relevant services.
LVD Testing Costs
The LVD test for LED lighting products starts from around $700. We suggest that you should request a free quotation from testing companies to get an accurate quote.
LED lighting products, and other electronics covered by the scope of the Low Voltage Directive, must carry a CE mark to show that the product is compliant.
LED light bulbs and other LED lighting products manufactured in China, and other countries, are not exclusively designed to comply with the Low Voltage Directive. As mentioned, you must either limit your product selection to SKUs that are already lab-tested (i.e., test reports already exist) or submit the product for third-party lab testing. Non-compliant and unsafe LED bulb lights are common and can cause fires, injuries, and even death.
LED lighting products might cause interference with other electronic devices such as TV screens or computers. The EMC directive aims at ensuring that the products do not cause significant interference with other equipment.
Therefore, importers must verify that their LED lighting product is compliant with the EMC directive when placing on the EU market.
EMC Test Reports
It’s essential to obtain an EMC test report from the supplier, and instruct them about the EMC regulation at an early stage. In the case that they cannot provide EMC test report, importers should book a third-party lab testing via reputable testing companies such as SGS, TUV, and CMA Testing.
EMC Directive Testing Costs
In general, the EMC test cost ranges from a few hundred to a thousand dollars. It depends on the number of parts that emits radio interference, and other relevant product specifications.
Products fall under the scope of the EMC directive must carry a CE mark.
Radio Equipment Directive (RED)
Smart home products have become more common, which also includes WiFi and Bluetooth enabled LED lighting. The RED regulates all electronic products with Wi-Fi, RFID, and Bluetooth features, to ensure the efficient use of radio spectrum, electromagnetic compatibility, and safety requirements.
Hence, if you are planning to import smart LED lighting products, you shall ensure that the product is compliant with RED.
- Wi-Fi enabled light bulbs
- Bluetooth enabled ceiling lights
- 3G/4G/LTE enabled strip lights
RED Test Reports
Only a few LED lighting manufacturers can provide RED test reports, and third-party RED lab testing is the only possible way to ensure compliance when placing on the EU market. RED testing companies can provide comprehensive RED testing services including RED certification, risk assessment, and other technical documentation.
Click here to find more RED test companies for LED lighting products.
RED Testing Costs
RED lab testing cost starts from a few hundred dollars, and it can increase up to a thousand dollars depends on the complexity of the product.
RED is also a CE Directive which means smart LED lighting products must carry the CE mark.
For many LED lighting products placed in the EU market, you will find product information regarding energy efficiency and product life cycle. This is because this EU energy-related product directive set limits and requirements for LED lighting products sold in the EU.
Ecodesign requirements are mandatory for almost all LED lighting products imported and sold in the EU, except for those lighting products designed for specific uses such as the lighting used in theatres and museums.
Here is an overview of ecodesign requirements for LED lighting products:
1. The product shall be energy-efficient or recyclable
2. Importers shall provide information for minimizing its environmental impact
3. Importers shall provide a lifecycle analysis to identify alternative design options
4. Maximum energy consumption must not exceed the limit provided
5. Minimum quantities of recycled material shall meet the requirements
Importers can either obtain the test report from the supplier or other testing companies. Testing companies such as Intertek and TUV provide services including creating energy labels, product life cycle analysis, energy-saving test reports, and other relevant services.
Importing non-compliant LED lighting products is highly risky, as it could result in heavy fines and force recall on your product. Therefore, importers shall ensure the Ecodesign requirements before the importation.
The Ecodesign directive is also one of the ‘CE marking directives’, and thus products and packaging must carry the CE mark.
LED lighting products must carry the energy label as required by the ErP directive. The energy label must be visibly and permanently attached to the product and its packaging.
The information on the energy label shall include:
- The rank of energy consumption (From A++ to G)
- Ecodesign information
- Energy-saving instruction
- Reference number
As mentioned above, it is common that more than one CE directives (e.g LVD, RED, RoHS) apply to your LED lighting product, and you must carry the CE mark on the products and its package.
Meanwhile, CE compliance requires more than just a sticker, and importers must ensure other compliance requirements as well.
CE label file
Manufacturers are not responsible for compliance mark such as CE mark. Therefore, you must provide the CE label file preferably in .ai or .esp format, then submit to the manufactures before the production. The CE label file shall include:
- Print type
A traceability code is also required by the CE directives. The label must be permanently and visibly affix on the products and its packaging, also provide information such as:
- Manufacturing date
- Production facility
- Country code
Besides the CE label, CE compliance also requires a range of documents, including a Declaration of Conformity (DoC), user manual, technical file, and test report.
Declaration of Conformity (DoC)
The DoC can be issued by the manufacturers or the importers, which includes the information below:
- Produce identification/SKU (e.g. LED light bulb mode A)
- Product features
- Name and address of the manufacturer/importer
- List of EN standards or directives
- Responsible individual
The DoC is an essential document for CE compliance. It’s often requested by different parties such as retailers, consumers, and surveillance organization.
You shall also prepare the user manual for your LED lighting products. Here is an overview of the information included in the user manual:
1. Instructions on how to install the product
2. An overview of the relevant parts and part names of the product
3. Safety instructions
4. Instructions on how to use the product
5. Instructions on how to recharge and/or refill the product and
6. Instructions on how to dispose of the product in an environmentally friendly manner
Usually, importers or manufactures would include all compliance marks (e.g. CE mark) in the user manual as well.
The technical file is somehow similar to the product specification, to prove that the products were designed according to those compliance requirements. The technical file shall include information such as:
- Bill of materials
- Design drawings
- Label files
- Packaging files
- List of applied standards and directives (e.g. RoHS)
- Test reports
- QC reports
- Risk assessment
Note: The technical file shall include all relevant test reports to support the relevant statement.
WEEE (waste electrical and electronic equipment) symbol promotes recycling and minimizes waste of electrical products, and it also indicates that the product shall be collected separately.
The WEEE symbol must be permanently and legibly printed on the LED lighting product and its packaging.
WEEE label file
Similar to the CE marking, your suppliers are not responsible to provide WEEE labels for your LED lighting products. Therefore, you shall provide the label file and instruct them about the label’s size and placement.
REACH regulation is mandatory for all consumer products imported or sold in the EU market. When you are importing LED lighting products to the EU, you must also comply with it.
REACH sets limits to various hazardous substances such as heavy metals and chemicals which are commonly used in the LED semiconductor material.
Here are a few examples of regulated substances:
- Thulium arsenide
Substances of Very High Concern (SVHC)
The ECHA (European Chemicals Agency) provides a candidate list of SVHC to REACH regulated substances. Importers can access the list and determine whether their products are compliant with REACH.
Note: The list of SVHC is updated on an infrequent basis, and more restricted substances will be added to the list.
Click here to access the most updated list of SVHC.
Importers must either obtain the REACH test report from the LED lighting supplier or book a third-party lab testing before the importation.
Various recognized lab testing companies offer REACH compliance services such as SGS, QIMA, and Bureau Veritas. They offer a conformity assessment, lab testing, certification, and other documentation services.
Here are some companies offering REACH compliance testing:
- Bureau Veritas
You can find more REACH testing companies in this guide.
REACH testing for LED lighting product cost range from $200 to $500 on a per material basis. It could increase up to a thousand dollars when there are more materials in your LED lighting product.
Click here access the complete guide to REACH product lab testing.
Directive 94/62/EC: Packaging Regulations
Importers need to print all compliance mark or energy-saving information on the packaging. Meanwhile, the EU also regulates the packaging materials of many consumer products including LED lighting.
Heavy Metals Restrictions
The packaging material is regulated under the Directive 94/62/EC. It set limits to certain substances used in packaging such as heavy metal. For example, the packaging must not contain an excessive amount of Hg, Pb, Cr6+, and Cd.
Reputable test companies such as Intertek, SGS, and TUV, provide packaging compliance services for LED lighting products. We suggest you should book a third-party lab testing especially for the packing before importation.
Additional Packaging Information
1. Packaging design shall be beneficial for collection, reuse, and material recycling.
2. Labeling requirements (e.g. CE mark, WEEE symbol) shall be also included in the packaging.