Do LED lamps need CE marking?
Updated
Yes, and CE is only part of it.
A mains LED lamp is electrical equipment in the 50 to 1,000 V AC range, so it falls under the Low Voltage Directive 2014/35/EU, the EMC Directive 2014/30/EU and RoHS 2011/65/EU. The manufacturer draws up technical documentation and an EU declaration of conformity and affixes the CE marking. LED light sources also have to meet the ecodesign rules in Regulation (EU) 2019/2020, carry an energy label under Regulation (EU) 2019/2015, and be registered in the EPREL product database before they are placed on the market.
What changes the answer
- Low-voltage lamps. A 12 V LED lamp is below the LVD range. It still needs EMC and RoHS, and the driver or transformer it plugs into is under the LVD.
- Smart bulbs. A bulb with Wi-Fi, Bluetooth or Zigbee is radio equipment under the Radio Equipment Directive 2014/53/EU, which covers safety and EMC through its own essential requirements. Internet-connected bulbs also fall under the RED cybersecurity requirements in Delegated Regulation (EU) 2022/30.
- Lamps built into luminaires. A luminaire that contains a light source is a "containing product" under 2019/2020. The light source inside must comply, and the luminaire maker must say whether it can be replaced.
- EU contact. Because these directives are listed in Article 4 of Regulation (EU) 2019/1020, the lamp can only be placed on the market if an economic operator established in the EU, such as an importer or authorised representative, holds the declaration and documentation.
- Take-back. Lamps are electrical equipment under the WEEE rules, so producers register and finance take-back in each member state where they sell.
What to do
- Test to the harmonised standards for each directive, typically for lamp safety, EMC emissions and immunity, photobiological safety, and RoHS material content.
- Measure the ecodesign parameters in 2019/2020, such as efficacy, power factor, flicker and stroboscopic effect, and register the model in EPREL with its product information sheet.
- Print the energy label with the QR code linking to EPREL, and show the energy class in online listings.
- Sign the EU declaration of conformity, affix CE marking, and keep the technical file for 10 years.
- Mark the lamp or packaging with the manufacturer's and, for imports, the importer's name and postal address, plus the EU responsible person.
- 8539.52.00.91
8539: Electrical filament or discharge lamps, including sealed beam lamp units and ultraviolet or infrared lamps; arc lamps; light-emitting diode (LED) light sources; parts thereof
Light-emitting diode (LED) light sources / Light-emitting diode (LED) lamps / Other
LED lamps, other. Statistical note 8 to chapter 85 sets the earlier suffixes by lamp type.
General rate2%Free or reduced under 17 programs - 8539.51.00.00
8539: Electrical filament or discharge lamps, including sealed beam lamp units and ultraviolet or infrared lamps; arc lamps; light-emitting diode (LED) light sources; parts thereof
Light-emitting diode (LED) light sources / Light-emitting diode (LED) modules
LED modules.
General rateFree
Next steps
Frequently asked questions
- Can I use a CE certificate from my supplier?
- CE marking is a self-declaration by the manufacturer, not a certificate issued by a lab. A supplier's test report helps, but the declaration of conformity must name the manufacturer, and an EU economic operator must be able to produce it.
- Do I need a notified body for LED lamps?
- Usually no. The LVD and EMC Directive allow internal production control. Radio equipment under the RED can need a notified body when harmonised standards are not fully applied.
- Is EPREL registration needed for sales through Amazon EU?
- Yes. Suppliers must enter the model in the product database before placing it on the market, whatever the sales channel.
Sources
This is general information drawn from the official sources linked above. It is not legal advice. Rules change and often turn on the facts of your product, so confirm your test plan with an accredited lab and your obligations with qualified counsel before you import or sell.