Lighting is one of the most common products sellers import from China, and one of the most regulated. A simple LED bulb falls under at least five sets of EU rules at once: RoHS for hazardous substances, the Low Voltage Directive (LVD) for electrical safety, the EMC Directive for electromagnetic compatibility, the ecodesign rules for light sources and the energy label. The WEEE rules for electronic waste apply as well, from the moment you place it on the market (marking and registration). A smart bulb with WiFi or Bluetooth adds the Radio Equipment Directive.
Factories in China often send a "RoHS certificate" and a "CE certificate" with their quotation. This article explains why those papers do not cover you, which rules apply to which type of lighting, and what you can check before you place an order.
- Which rules apply to which product
- RoHS: hazardous substances
- Electrical safety and EMC
- Ecodesign: efficiency, flicker and packaging
- The energy label and the EU product database
- WEEE: the crossed-out bin and registration
- Why a factory certificate is not enough
- Who is responsible in the EU
- Checklist
Which rules apply to which product
| Product | RoHS | LVD | EMC | RED | Ecodesign | Energy label | WEEE |
|---|---|---|---|---|---|---|---|
| LED bulb, 230 V | Yes | Yes | Yes | No | Yes | Yes | Yes |
| Luminaire with replaceable bulb | Yes | Yes | Yes | No | Yes, for the bulb and the luminaire | On the bulb if sold separately; class in the manual if a bulb is included | Yes |
| Luminaire with built-in LEDs | Yes | Yes | Yes | No | Yes | Class in the user manual if the LEDs can be removed for verification; otherwise the luminaire itself needs the label | Yes |
| LED strip, 12 or 24 V | Yes | Only for the 230 V adapter | Yes | No | Yes | Yes, if sold as a light source | Yes |
| Smart bulb (WiFi, Bluetooth, Zigbee) | Yes | Covered by RED | Covered by RED | Yes | Yes | Yes | Yes |
The LVD only applies to electrical equipment between 50 and 1,000 V AC or 75 and 1,500 V DC (Article 1 of Directive 2014/35/EU). A 12 or 24 volt LED strip itself is therefore outside the LVD, but its mains adapter is not. For a smart bulb, the Radio Equipment Directive takes over the safety and EMC requirements, without a voltage limit (Article 3(1) of Directive 2014/53/EU).
RoHS: hazardous substances
All lighting falls under the RoHS Directive (category 5, lighting equipment, Annex I of Directive 2011/65/EU). Ten substances are restricted, measured in each homogeneous material, which means each material that cannot be separated mechanically, such as a solder joint, a plastic housing or a cable sheath (Article 3(20)):
| Substance | Maximum |
|---|---|
| Lead, mercury, hexavalent chromium | 0.1% each |
| Cadmium | 0.01% |
| PBB and PBDE (flame retardants) | 0.1% each |
| DEHP, BBP, DBP and DIBP (phthalates) | 0.1% each |
Two points matter for lighting in particular.
Fluorescent lamps are mostly gone. The mercury exemptions for compact fluorescent lamps for general lighting expired in 2023 (most on 24 February, the last on 24 August), and those for linear T5 and T8 tubes on 24 August 2023 (Annex III, points 1 and 2). For general lighting, LED is now the alternative.
There is no general exemption for LED. LED products often use component exemptions that apply to all electronics, for example lead in high-melting-temperature solder or lead in glass or ceramic in electronic components (Annex III, points 7(a) and 7(c)-I). These exemptions have end dates: 7(a) and 7(c)-I expire on 30 June 2027, the sub-entries of 7(a) on 31 December 2027. If your supplier relies on one, it should be named in the technical documentation.
Our article on RoHS for sellers outside the EU explains who does what under RoHS.
Electrical safety and EMC
Mains lighting has to be electrically safe under the LVD. The harmonised standards for luminaires are the EN 60598 series, starting with EN IEC 60598-1, with separate parts such as EN 60598-2-20 for lighting chains. LED drivers fall under EN 61347, and photobiological safety (UV, blue light and infrared) under EN 62471 (Implementing Decision (EU) 2023/2723).
The EMC Directive applies to every lamp or luminaire with electronics, so practically every LED product. A cheap LED driver is a common source of interference.
For a 12 or 24 volt LED strip, the LVD does not cover the strip itself, but the strip still has to be safe. The general safety requirement of the General Product Safety Regulation (GPSR) then covers the risks that no specific EU law covers, such as overheating (Article 2(1) of Regulation (EU) 2023/988).
Smart bulbs. Bulbs with WiFi, Bluetooth or Zigbee fall under the Radio Equipment Directive. Since 1 August 2025, radio equipment that can communicate over the internet, directly or via a hub or app, also has to meet cybersecurity requirements (Delegated Regulation (EU) 2022/30).
Not sure whether your supplier's reports cover the EU requirements? Our electronics testing checks RoHS, LVD, EMC and RED before you ship, and our test report review tells you whether the reports you already have are usable.
Ecodesign: efficiency, flicker and packaging
Since 1 September 2021, Regulation (EU) 2019/2020 sets the ecodesign requirements for light sources and separate control gears. It replaced the older rules from 2009 and 2012 (Article 10). It covers bulbs, LED modules and strips, and also light sources sold inside a luminaire (Article 1).
The main requirements for LED (Annex II):
- Maximum power for the amount of light: an LED light source may not use more power than the formula in the regulation allows.
- Standby: no more than 0.5 W, also for smart bulbs in networked standby.
- Colour rendering: CRI of at least 80, with exceptions for outdoor and industrial use that are stated on the packaging.
- Flicker and stroboscopic effect for mains LED lamps: Pst LM no more than 1.0, and since 1 September 2024 SVM no more than 0.4.
- Lifetime and colour consistency: requirements for lumen maintenance, survival and colour variation.
The packaging has to show, among other things, the useful luminous flux in lumens (in a font at least twice as large as the wattage), the colour temperature, the beam angle for directional lamps, the lifetime in hours, the power, the colour rendering and whether the lamp is dimmable (Annex II, point 3).
Luminaires. A luminaire with a light source must allow the light source and the driver to be replaced with common tools, unless the technical documentation justifies why not. The packaging must show, at least with a pictogram, whether the light source can be replaced (Article 4).
The energy label and the EU product database
Light sources sold on their own, such as bulbs and LED strips, need the A to G energy label on the packaging, with a QR code. The scale was reset on 1 September 2021 and is strict: class A starts at 210 lumens per watt, so a non-directional 230 V LED bulb that gives 100 lumens per watt lands in class F (Regulation (EU) 2019/2015, Annex II).
Before you place a new model on the EU market, the supplier has to register it in the EU product database for energy labels, known as EPREL (Article 4(1) of Regulation (EU) 2017/1369). For lighting made in China, the supplier is the importer in the EU or the authorised representative of the manufacturer. Online offers must show the energy class as well.
Luminaires no longer get their own energy label. If the built-in LEDs cannot be removed for verification, the whole luminaire counts as a light source and needs the label itself (Article 2(1) of Regulation (EU) 2019/2015). Otherwise, the user manual has to say: "This product contains a light source of energy efficiency class X" (Article 3(2)(a) and Annex V).
WEEE: the crossed-out bin and registration
Lighting is electronic equipment under the WEEE Directive. LED lamps are category 3 (lamps); luminaires are category 4 or 5, depending on whether they are larger or smaller than 50 cm (Annex III and IV of Directive 2012/19/EU).
- Every product needs the crossed-out wheeled bin symbol, preferably according to EN 50419 (Article 14(4) and Annex IX).
- The packaging of a light source must also warn that it may not be thrown away with household waste (Annex II of Regulation 2019/2020).
- The producer registers in every EU country where the products are sold, including for direct online sales to consumers (Article 16). Whether a seller from outside the EU needs a local authorised representative for this is decided per country.
We can arrange the registration for France with our WEEE registration for France.
Why a factory certificate is not enough
Under RoHS and the LVD, the manufacturer always assesses the product itself, through internal production control (Module A), and no notified body is involved (Decision 768/2008/EC, Annex II; recital 9 of Directive 2014/35/EU). Under the EMC Directive this is also the usual route; involving a notified body is optional (Article 14 of Directive 2014/30/EU). What counts legally is:
- the EU declaration of conformity, in which the manufacturer takes responsibility (Article 13 of Directive 2011/65/EU);
- the technical documentation, with the test reports, the design and the standards used.
A "RoHS certificate" or "CE certificate" from a lab is at best a test report. It may be useful evidence, but it does not replace the declaration of conformity, and it does not transfer any responsibility to the lab. Check that the report covers your exact model, that it is recent and that the lab tested against the right standards. A real certificate from a notified body only exists if the manufacturer chose EU-type examination, which is possible under the EMC Directive and the Radio Equipment Directive. For smart bulbs it is required when the manufacturer has not fully applied the harmonised standards for the radio or cybersecurity requirements (Article 17(4) of Directive 2014/53/EU).
A factory audit of a new supplier and a pre-shipment inspection help to check that what is shipped matches what was tested.
Who is responsible in the EU
Lighting that carries the CE marking may only be placed on the EU market if there is an economic operator in the EU who is responsible for it: the manufacturer, the importer, an authorised representative or, if none of these is in the EU, the fulfilment service provider (Article 4 of Regulation (EU) 2019/1020). That operator keeps the declaration of conformity and the technical documentation available, answers questions from authorities and puts its name and postal address on the product, the packaging or an accompanying document.
If you import the lighting yourself, you are the importer. You check that the manufacturer has done the conformity assessment, that the technical documentation exists and that the CE marking and documents are present, and you keep the declaration of conformity for 10 years (Article 9 of Directive 2011/65/EU).
Selling lighting in the EU from outside the EU? Our EU Authorised Representative service also covers CE-marked electronics. We keep your documentation available for the authorities and are their contact point in the EU.
Checklist
- Determine per product which rules apply: RoHS, LVD or GPSR, EMC or RED, ecodesign, energy label and WEEE.
- Ask the factory for the EU declaration of conformity and the full test reports for your exact model, not a certificate.
- Check RoHS for all ten substances and ask which exemptions the product relies on.
- Check flicker, the colour rendering and the power against the ecodesign limits.
- Check the packaging: lumens, colour temperature, lifetime, wattage, energy label with QR code, replaceability pictogram for luminaires and the crossed-out bin.
- Register light sources in EPREL before the first sale, and show the energy class online.
- For smart bulbs: check the radio and cybersecurity requirements.
- Register for WEEE in every country where you sell.
- Make sure there is a responsible economic operator in the EU, with name and postal address on the product or packaging.
Sources
- Directive 2011/65/EU on the restriction of hazardous substances (RoHS), consolidated version, Articles 3, 7, 9 and 13, Annexes I, II and III. EUR-Lex
- Directive 2014/35/EU (Low Voltage Directive), Article 1, Annex III, recital 9, and Implementing Decision (EU) 2023/2723 on harmonised standards. EUR-Lex
- Directive 2014/30/EU (EMC), Article 14, and Directive 2014/53/EU (Radio Equipment), Articles 3 and 17, and Delegated Regulation (EU) 2022/30. EUR-Lex
- Regulation (EU) 2019/2020 on ecodesign requirements for light sources and separate control gears, Articles 1, 4 and 10, Annex II. EUR-Lex
- Delegated Regulation (EU) 2019/2015 on energy labelling of light sources and Regulation (EU) 2017/1369, Article 4. EUR-Lex
- Directive 2012/19/EU on waste electrical and electronic equipment (WEEE), Articles 14 and 16, Annexes III, IV and IX. EUR-Lex
- Regulation (EU) 2019/1020 on market surveillance, Article 4, and Regulation (EU) 2023/988 (GPSR), Article 2. EUR-Lex
- Decision 768/2008/EC, Annex II (Module A). EUR-Lex
- Consulted November 2026.
