Why "we have CE" is not a complete answer
Ask ten suppliers whether their LED panel can be sold in Germany and most will answer "yes, we have CE". CE is not a certificate issued by a laboratory for general lighting products. It is a declaration signed by the manufacturer (or the importer acting as manufacturer), and for a luminaire it typically means conformity with several pieces of EU legislation at once:
- Low Voltage Directive 2014/35/EU (electrical safety, usually shown through EN 60598-1)
- EMC Directive 2014/30/EU (emissions and immunity)
- RoHS Directive 2011/65/EU (restricted substances)
- Ecodesign framework Directive 2009/125/EC, with the product-specific rules in Regulation (EU) 2019/2020
- Energy labelling: Regulation (EU) 2017/1369 and Delegated Regulation (EU) 2019/2015
- Additional obligations such as REACH and WEEE at member-state level
The safety part is usually well covered. The part that gets projects into trouble is the performance part: ecodesign and energy labelling. A fixture can be electrically safe and still be illegal to place on the EU market because it draws too much power for its light output, or because nobody has registered it in EPREL.
The one question that changes everything: is it a light source or a containing product?
Regulation (EU) 2019/2020 does not regulate luminaires as such. It regulates light sources and separate control gears, including when they are inside a containing product. The definition then splits the market in two:
- If the LED module or lamp can be removed for verification without permanent damage, the luminaire is a containing product. No light source energy label may be used on it. Instead, from 1 March 2022 the instructions must carry the sentence "This product contains a light source of energy efficiency class X".
- If the light source cannot be removed for verification, the whole luminaire is treated as the light source. It must carry an A–G label, its data must be registered in EPREL, and it must meet every ecodesign requirement in its own right.
That is why integrated sealed fixtures carry more compliance weight than fixtures with replaceable LED boards. Importers often discover this when a marketplace or market surveillance authority asks for the product information sheet and finds no record.
There are category exclusions in Annex III (specialised applications such as certain equipment covered by other rules), so never assume a product is out of scope: check the exclusion list for that specific use.
The power limit: why "120 lm/W minimum" is a myth
The headline requirement for a light source is a maximum allowed power:
Pon,max = C x (L + Phiuse / (F x eta)) x R
For LED sources not listed separately in Table 1 of the Regulation: eta = 120 lm/W and L = 1.5 W (L = 2.0 W for a connected light source). C depends on the type: 1.08 for a non-directional mains source, 1.23 for a directional mains source, 1.00 and 1.15 for the respective non-mains versions. F is 1.00 for non-directional and 0.85 for directional. R rewards colour quality: R = (CRI + 80) / 160 for CRI above 25, and 0.65 for CRI below that.
Note the wording in the Regulation itself: 120 lm/W is a threshold efficacy used in the calculation, not the minimum required efficacy. The actual minimum is what you get by dividing the declared lumens by the computed maximum power, so it moves with output level and CRI.
A 36 W panel that fails
Take a non-directional mains LED panel, CRI 80, declared 3,200 lm, 36 W:
- 3,200 / 120 = 26.67 W
- + 1.5 W end loss = 28.17 W
- x 1.08 = 30.4 W allowance
The product draws 36 W against a 30.4 W ceiling. It fails ecodesign, even though it would still be legal to label. Push efficiency to 3,600 lm at 32 W and the allowance becomes 1.08 x (1.5 + 30) = 34.0 W, so it passes. Raise CRI to 90 and the allowance grows to about 32.3 W for the 3,200 lm version, because R becomes 1.0625.
This is the single most useful check a buyer can run before comparing prices. Two fixtures with identical lumens can differ by 20 percent in input power, and only one of them can legally be shipped to the EU.
The functional requirements suppliers forget
From 1 September 2021, the following apply to LED and OLED light sources:
| Requirement | Limit | Note |
|---|---|---|
| Colour rendering | CRI >= 80 | Exemptions exist for HID above 4,000 lm and for sources intended for outdoor or industrial use where standards allow CRI below 80 |
| Displacement factor cos phi1 | >= 0.5 from 5-10 W, >= 0.7 from 10-25 W, >= 0.9 above 25 W | No limit at or below 5 W |
| Colour consistency | Within a 6-step MacAdam ellipse | Measured against the declared ellipse centre, tolerance 0.005 |
| Flicker PstLM | <= 1.0 at full load | Same exemptions as CRI |
| Stroboscopic effect SVM | <= 0.4 at full load | Same exemptions as CRI |
| Standby and networked standby | <= 0.5 W each | The two allowances are not added together |
| Separate control gear efficiency | >= Pcg^0.81 / (1.09 x Pcg^0.81 + 2.10) | Applies at full load; no-load and standby <= 0.5 W |
Two of these trip up commercial projects regularly. The first is colour consistency: a six-step MacAdam limit is looser than the three-step many specifiers assume, so ask for the declared SDCM value and read the tolerance. The second is SVM. A driver that looks fine in the office can produce visible stroboscopic effect in motion-heavy environments such as warehouses, gyms or workshops.
If flicker is part of your specification, read our separate verification guide: Flicker-Free and Low Blue Light LED: How to Verify "Healthy Lighting" Claims.
The endurance test is not a Lifetime claim
Lumen maintenance under EU law is verified by an endurance test, not by an LM-80 extrapolation. Annex V uses ten units, 1,200 switching cycles of 150 minutes on and 30 minutes off, giving 3,000 hours of operation inside a 3,600-hour total test. The measured XLMF must be at least:
XLMF,MIN % = 100 x e ^ (3000 x ln(0.7) / L70)
with a cap of 96.0 percent, and at least nine of the ten samples must still operate afterwards.
So a long L70 declaration is checked against roughly 3,000 hours of switched operation, and the maths is unforgiving: claim too long a life and the required remaining flux gets easier, claim a short one and the bar rises. LM-80 and TM-21 data remain valuable for design confidence, but they do not replace this test. Ask for a report that names Annex V and the number of cycles.
The label: how the A-G class is actually calculated
The energy class comes from the total mains efficacy:
etaTM = (Phiuse / Pon) x FTM
FTM is 1.000 for a non-directional mains source, 0.926 for a non-directional non-mains source, 1.176 for a directional mains source and 1.089 for a directional non-mains source. Classes on the 1 September 2021 rescaled label:
| Class | Total mains efficacy etaTM (lm/W) |
|---|---|
| A | 210 or above |
| B | 185 to 210 |
| C | 160 to 185 |
| D | 135 to 160 |
| E | 110 to 135 |
| F | 85 to 110 |
| G | below 85 |
Realistically, most commercial LED products sit in classes D to F today, so a supplier promising class A deserves a close look at the test data. The old A++ to E scale and the old luminaire label under Regulation 874/2012 are gone; the label now carries a QR code that resolves to the EPREL record, which is the fastest way to check that a registration exists.
Always cross-check the label against measurable quantities. If a label claims class D, the ratio between declared lumens and declared watts must fall in the 135-160 lm/W band; a mismatch of 20 percent usually means the print run came from catalogue numbers rather than from a report.
What market surveillance will test, and how much headroom to leave
Annex IV sets the verification tolerances that authorities apply to a sample of ten units:
- Useful luminous flux: measured average must not be less than declared minus 10 percent
- CRI: not less than declared minus 2 points
- Power: not more than declared plus 5 percent (2.5 percent above 100 W, 0.20 W below 2 W)
- PstLM and SVM: not more than declared plus 10 percent
- Colour consistency: measured steps must not exceed the declared steps
- CCT: within 10 percent, beam angle within 25 percent
Declaring exactly at the limit is risky. If your project needs 4,000 lm on paper, production variance can push a batch below tolerance, so leave around 5 percent headroom on flux.
Documents to request in your RFQ
- EU Declaration of Conformity listing every applicable directive or regulation, signed by the manufacturer or importer placed on the EU market
- Test report covering Regulation (EU) 2019/2020: useful lumens, on-mode power and Pon,max calculation, CRI, R9, DF, six-step colour consistency, PstLM and SVM, with values in line with the declared data
- Photometric file and integrating-sphere or goniophotometer data, ideally LM-79 based - see how to read an IES or LDT photometric file
- LM-80 and TM-21 evidence plus a Tc point declaration for the lifetime claim
- EPREL record link (or product information sheet) together with the label artwork containing the QR code
- The name and EU address of the responsible economic operator; since 16 July 2021 Regulation (EU) 2019/1020 requires an EU-established operator for the harmonised products it covers, and without one the goods should not be placed on the market
- Safety and EMC reports against EN 60598-1, EN 62471 photobiological safety, and the relevant EMC and harmonic standards
Red flags worth ten minutes of checking
- A "CE certificate" issued by a test house. For general lighting this is a self-declaration; third-party involvement is normal for testing, not for a CE entitlement.
- A CE logo whose letters are closer together than usual, which often indicates a China Export mark rather than conformity.
- Label artwork without a QR code, or a QR code that does not resolve to an EPREL record.
- Class A or B claims unsupported by the underlying lm/W arithmetic.
- "We tested to LM-80" supplied as the answer to an ecodesign lifetime question.
- Packaged sources missing the mandatory printing of lumens and CCT on the product itself where space allows.
How Solarix Lighting handles European projects
At Solarix Lighting we build our commercial ranges - backlit and edge-lit LED panels, downlights, tri-proof fixtures, high bays and roadway luminaires - around measured data rather than catalogue numbers, because those same figures end up in EU declarations, EPREL records and project submittals. We hold CE conformity documentation under the Low Voltage and EMC directives, can supply photometric reports in IES and LDT formats, and provide the flicker, colour consistency and driver data that an ecodesign file requires.
If you are importing into the EU, the cheapest moment to find a compliance gap is before production, not at customs. Send us your specification - target lumens, CRI, beam angle, dimming protocol and installation environment - and we will return a data pack you can hand straight to your notified lab or consulting engineer. Start with our downlight specification guide if you are unsure which fixture type fits the ceiling, or contact us for the complete test file of the model you are considering.