CROSS-STANDARD public interest · LED luminaire

China-to-EU LED Luminaire Compliance Gap Matrix

AI-compiled from official public sources — cross-checked by multiple AI models, not human-verified. Informational only; see disclaimer. Public-interest, source-linked comparison of common China LED luminaire documentation against EU CE marking (LVD, EMC, RoHS), Ecodesign Regulation (EU) 2019/2020, energy labelling (EU) 2019/2015, and photobiological safety requirements versus Chinese GB standards and CCC certification.

Dataset 2026-06-11 Last verified 2026-06-12 11 rows

GAP MATRIX

Compliance Gap Matrix

Gap matrix
Compliance item Common China baseline European Union (CE / ErP) Gap / action Source + verification date
Ecodesign Minimum Efficacy and Performance (Reg EU 2019/2020) China's equivalent is GB 30255-2019 (Energy efficiency requirements for LED room luminaires). It defines three energy efficiency grades: Grade 1 (highest): ≥90 lm/W; Grade 2: ≥80 lm/W; Grade 3: ≥70 lm/W. Grade 3 is the minimum required for market entry in China. The China Energy Label (CEL) registration is mandatory for GB 30255-covered products; labels are administered by SAMR. GB 30255 does not comprehensively cover power factor, CRI minimums, or lifetime requirements in the same binding way as the EU Ecodesign Regulation.GB 30255-2019 — Energy efficiency requirements for LED room luminaires (SAC/SAMR) Commission Regulation (EU) 2019/2020 sets mandatory minimum performance requirements for light sources placed on the EU market. Applicable from September 2021: minimum luminous efficacy for most non-directional LED lamps is ~approx. 85 lm/W; directional LED lamps also ~approx. 85 lm/W (exact thresholds vary by product sub-category — verify current Annex II for the specific product type). Additional mandatory requirements include: minimum colour rendering index (CRI/Ra ≥80 for general lighting products); minimum rated lifetime (≥6,000 hours for most LED lamps); power factor (≥0.9 for luminous flux ≥25W); survival factor; colour consistency. Products not meeting the minimum requirements cannot be placed on the EU market.Commission Regulation (EU) 2019/2020 — Ecodesign requirements for light sources and separate control gears (Annex II: minimum performance requirements) EU minimum efficacy (~approx. 85 lm/W) broadly aligns with CN Grade 2 (≥80 lm/W) but Chinese Grade 3 (70 lm/W) products would fail EU Ecodesign minimum. Beyond efficacy, EU additionally mandates: minimum CRI ≥80 (CN does not have an equivalent mandatory minimum across all product types); minimum lifetime ≥6,000 h (CN does not mandate equivalent); minimum power factor ≥0.9 for luminous flux ≥25W (CN GB 30255 does not have an equivalent mandatory minimum). Manufacturers achieving only CN Grade 3 must upgrade product performance before EU market entry. Note: exact lm/W thresholds vary by product sub-category (e.g., directional vs. non-directional, integrated vs. non-integrated); always verify against current Reg (EU) 2019/2020 Annex II for the specific product sub-category.[INFORMATIONAL] Commission Regulation (EU) 2019/2020 sets mandatory minimum efficacy, CRI, lifetime, and power factor requirements for LED light sources placed on the EU market. Chinese Grade 3 products (≥70 lm/W) may not meet EU minimums. Additionally, EU mandates CRI ≥80, lifetime ≥6,000 h, and power factor ≥0.9 (≥25W) — requirements not fully mirrored in GB 30255. Verify exact thresholds for the specific product sub-category in the current Annex II before market entry. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
EU Energy Label A-G (Rescaled) + EPREL Registration (Reg EU 2019/2015) China's China Energy Label (CEL) under GB 30255-2019 is mandatory for LED room luminaires. Products must be registered with the CQC (China Quality Certification Centre) or CECP (China Energy Conservation Programme) before affixing the CEL. The CEL shows Grade 1–3 based on absolute lm/W thresholds. There is no mutual recognition between the EU EPREL registry and the CN CEL registration scheme.GB 30255-2019 — Energy efficiency requirements for LED room luminaires (SAC/SAMR)
China Energy Label (CEL) scheme — administered by SAMR/CQC/CECP		 Commission Delegated Regulation (EU) 2019/2015 mandates a rescaled A-G energy label and EPREL registration for regulated light sources, effective September 2021. The energy class is calculated from the Energy Efficiency Index (EEI) derived from the product's luminous efficacy relative to a reference value. Scope note: the energy labelling obligation under Reg (EU) 2019/2015 applies to the light source (and separate control gear), not automatically to a whole luminaire as such. A luminaire containing a non-replaceable integrated LED source falls in scope as a light source itself; where the LED source is replaceable, the obligation attaches to the contained light source. Verify your product configuration to confirm who bears the EPREL registration and labelling obligation. Mandatory steps for in-scope products before EU market entry: (1) calculate the EEI and determine the A-G class; (2) register the product in the EU EPREL (European Product Registry for Energy Labelling) database at eprel.ec.europa.eu — registration is free but must be completed before placing the product on the market; (3) display the EU energy label on product packaging, physical product (where required), and EU online product listings.Commission Delegated Regulation (EU) 2019/2015 — Energy labelling of light sources (rescaled A-G label, EPREL registration) The EU EPREL database registration is a mandatory pre-market step with no CN equivalent. The EU A-G label class is calculated from the EEI (a relative metric), while the CN CEL grade uses absolute lm/W thresholds — they are not directly comparable and a product's CN grade does not determine its EU label class. Both schemes are mandatory but non-mutual: a product must be registered separately in EPREL for EU and with CQC/CECP for CN. Additionally, the EU label must also include the blue light hazard class (see ledeu-photobio-02). Online retailers selling into the EU must display the EU energy label on product listing pages — a requirement that CN-market product pages do not carry.[INFORMATIONAL] The EU rescaled A-G energy label and EPREL database registration are mandatory for in-scope light sources under Delegated Reg (EU) 2019/2015. Scope clarification: the obligation applies to the light source (and separate control gear) — not automatically to the whole luminaire. A luminaire with a non-replaceable integrated LED source falls in scope as a light source; where the LED source is replaceable, the labelling and EPREL obligation attaches to the contained source. Verify your product configuration before assuming the luminaire as a whole must be EPREL-registered. Chinese CEL registration does not substitute for EPREL. The EEI-based EU class and lm/W-based CN grade are calculated differently and cannot be directly cross-mapped. Register in EPREL early — it is free but must precede first market placement. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
EMC Emissions — EN 55015 Conducted and Radiated (EMC Directive 2014/30/EU) China's equivalent is GB 17743-2017 (Limits and methods of measurement of radio disturbance characteristics of electrical lighting and similar equipment), which is technically aligned with CISPR 15. For luminaires sold in China, GB 17743 compliance is required as part of CCC certification (which covers both safety and EMC for relevant product categories). Testing must be conducted at CNAS/CMA-accredited laboratories in China. Chinese CCC EMC test reports are not accepted under the EU EMC Directive conformity assessment pathway.GB 17743-2017 — Limits and methods of measurement of radio disturbance characteristics of electrical lighting and similar equipment (SAC/SAMR, aligned with CISPR 15) LED luminaires placed on the EU market must comply with the EMC Directive 2014/30/EU. EN 55015:2019+A11:2020 (Limits and methods of measurement of radio disturbance characteristics of electrical lighting and similar equipment) is a voluntary harmonised standard route that may confer a presumption of conformity for lighting-equipment emissions when correctly applied. It covers conducted emissions on the mains supply terminals (150 kHz–30 MHz) and radiated emissions (30 MHz–300 MHz). CE marking requires an EMC Declaration of Conformity referencing Directive 2014/30/EU. Luminaires with integrated wireless functionality (e.g., Bluetooth dimming, Wi-Fi smart lighting) also fall under the Radio Equipment Directive (RED) 2014/53/EU.Directive 2014/30/EU (EMC Directive)
EN 55015:2019+A11:2020 — Limits and methods of measurement of radio disturbance characteristics of electrical lighting and similar equipment		 EN 55015 and GB 17743 are both derived from CISPR 15 and emission limits are largely harmonized. Key gaps: (1) EU requires a separate EMC DoC in addition to LVD DoC (both are referenced in the overall CE marking DoC); (2) EU EMC testing should be conducted at an ILAC MRA-member accredited laboratory (UKAS, DAkkS, COFRAC, etc.) for EU DoC purposes — Chinese CNAS-accredited labs are generally ILAC members and may issue reports accepted for EU compliance, but confirm the lab's EU market scope; (3) if the luminaire incorporates wireless functionality, the Radio Equipment Directive (RED) 2014/53/EU applies and the EMC DoC must also reference RED; (4) the DoC must cite the specific EN 55015 amendment version in force.[INFORMATIONAL] CE marking for LED luminaires in the EU requires EMC compliance under Directive 2014/30/EU. EN 55015:2019+A11:2020 is a voluntary harmonised route that may confer presumption of conformity for emissions; alternatives are allowed if the manufacturer demonstrates conformity with the Directive. Emission limits are broadly harmonized with CN GB 17743 (both CISPR 15-derived), but a separate EU EMC DoC is required and testing must be at an ILAC MRA-recognised laboratory. Smart luminaires with wireless functions additionally require compliance with RED 2014/53/EU. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
EMC Immunity — EN 61547 (Lighting Equipment Immunity Requirements) China's equivalent is GB/T 18595-2014 (General requirements for the electromagnetic immunity of lighting equipment), which is technically equivalent to IEC 61547:2009. GB/T 18595 is a recommended standard (T = tuijian, recommended) and is less strictly enforced than the CN emissions standard GB 17743. CCC certification for CN luminaires generally focuses more on safety and emissions than immunity. Passing EN 61547 immunity testing typically demonstrates performance beyond the requirements typically enforced in the CN market.GB/T 18595-2014 — General requirements for the electromagnetic immunity of lighting equipment (SAC/SAMR — recommended standard, aligned with IEC 61547:2009) LED luminaires placed on the EU market must meet the essential requirements of the EMC Directive 2014/30/EU, including adequate immunity in their intended electromagnetic environment. EN 61547:2009 (Equipment for general lighting purposes — EMC immunity requirements) is a voluntary harmonised standard route for demonstrating lighting-equipment immunity. Tests include electrostatic discharge (ESD, IEC 61000-4-2), electrical fast transient/burst (IEC 61000-4-4), surge (IEC 61000-4-5), conducted RF disturbances (IEC 61000-4-6), power frequency magnetic field (IEC 61000-4-8), and voltage dips/interruptions (IEC 61000-4-11).Directive 2014/30/EU (EMC Directive)
EN 61547:2009 — Equipment for general lighting purposes — EMC immunity requirements		 The EU mandates conformity with the EMC Directive 2014/30/EU essential requirements; EN 61547 is a voluntary harmonised route for documenting lighting-equipment immunity and may confer presumption of conformity when correctly applied. CN immunity testing under GB/T 18595 is a recommended standard and not universally enforced for all luminaire categories. Products tested and complying with EN 61547 immunity levels will generally meet or exceed CN GB/T 18595 requirements due to the shared IEC 61547 technical base. The practical gap is primarily a documentation gap: EU DoC must cover EMC immunity evidence; CN CCC documentation may not include equivalent immunity test reports. Manufacturers using the harmonised route should include EN 61547 immunity test reports from an ILAC-recognised laboratory in the technical file.[INFORMATIONAL] LED luminaires must satisfy the EMC Directive 2014/30/EU essential requirements, including immunity. EN 61547:2009 is a voluntary harmonised route for demonstrating immunity and may confer presumption of conformity; it is not the mandatory legal obligation itself. Chinese GB/T 18595 is a recommended standard and does not substitute for EU immunity compliance documentation. The technical content is largely harmonized with IEC 61547, so products already tested to GB/T 18595 may have a reduced re-testing burden, but the EU DoC and technical file must contain adequate EMC immunity evidence. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
Photobiological Safety — Blue Light Hazard (EN 62471 Risk Groups) China has adopted GB/T 20145-2006 (Photobiological safety of lamps and lamp systems), which is technically equivalent to IEC 62471:2006 (the predecessor to the 2008 edition used in EU). GB/T 20145 is a recommended standard (T = tuijian, recommended) and is not universally mandatory for all LED luminaires in the Chinese market. Enforcement and testing obligations are less prescriptive for residential luminaires compared to the EU Ecodesign framework.GB/T 20145-2006 — Photobiological safety of lamps and lamp systems (SAC/SAMR — recommended standard) Commission Regulation (EU) 2019/2020 (Ecodesign for light sources, Annex II) makes photobiological risk classification and technical documentation a legal obligation for regulated LED light sources and relevant luminaires. EN 62471:2008 (Photobiological safety of lamps and lamp systems) is the referenced technical method commonly used to derive the risk group; the mandatory obligation is the Regulation, not the EN standard as a standalone legal rule. Risk groups range from RG0 (Exempt — no hazard) to RG3 (High risk). Blue light weighted radiance and irradiance limits define the group. RG2 and RG3 products carry usage restrictions and must be declared in the technical file.Commission Regulation (EU) 2019/2020 — Ecodesign requirements for light sources (Annex II: photobiological safety)
EN 62471:2008 — Photobiological safety of lamps and lamp systems (harmonised standard for risk group classification)		 EU Ecodesign Reg 2019/2020 Annex II requires photobiological risk group classification and declaration for regulated light sources — this is not optional. EN 62471:2008 is the referenced technical method commonly used to determine the risk group, but the legal obligation is the Regulation. CN GB/T 20145 is recommended-only and not routinely enforced for residential LED luminaires. Manufacturers producing for the EU market should document a defensible risk-group assessment, commonly by testing to EN 62471:2008; RG2 luminaires must include warnings and usage instructions; RG3 products face significant market restrictions (typically limited to professional/industrial use with specialist training). Most general-purpose LED luminaires targeting RG0 or RG1 have no usage restrictions, but the classification must be formally documented in the technical file.[INFORMATIONAL] Photobiological risk group classification is required for regulated LED products under Commission Regulation (EU) 2019/2020. EN 62471:2008 is the referenced technical method commonly used to derive the classification; it should not be described as the standalone mandatory legal obligation. Chinese GB/T 20145-2006 testing may be useful as a reference, but EU technical documentation should show a classification aligned with the EU Ecodesign framework. Manufacturers should formally document the risk group in the technical file; RG2/RG3 products require additional labelling and usage warnings. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
Blue Light Hazard Class on EU Product Label (Delegated Reg 2019/2015) China's Energy Label (China Energy Label, CEL) mandatory under GB 30255 (LED room luminaires energy efficiency) does not include a blue light hazard class. The Chinese labelling regime focuses on energy efficiency grades (Grade 1–3) and lumen output. There is no CN regulatory requirement to display photobiological risk group information on luminaire packaging equivalent to EU Delegated Reg 2019/2015.GB 30255-2019 — Energy efficiency requirements for LED room luminaires (SAC/SAMR — no blue light class requirement) Commission Delegated Regulation (EU) 2019/2015 (Energy labelling of light sources, Annex VI) requires blue light hazard class information on labels for in-scope products since September 2021. The class is derived from the photobiological risk assessment, commonly using EN 62471 risk groups as the technical basis. The label uses plain-language classes: RG0 = 'No risk', RG1 = 'Low risk', RG2 = 'Moderate risk'. Products in the RG2 or above category must display this class prominently. This labelling obligation applies to light sources and to luminaires containing regulated light sources placed on the EU market.Commission Delegated Regulation (EU) 2019/2015 — Energy labelling of light sources (Annex VI: blue light hazard class labelling) The EU blue light hazard class label has no direct CN counterpart — Chinese manufacturers producing to CN specifications will not have this label on their standard CN-market packaging. For EU export, the blue light hazard class required by Delegated Reg 2019/2015 must be added to product labels and packaging. This requires: (1) documenting a photobiological risk assessment, commonly using EN 62471 risk group testing; (2) updating label artwork to include the blue light class in the EU label layout per Annex VI of Delegated Reg 2019/2015; (3) ensuring the class is visible on any online product listings in the EU (required by the energy labelling framework). This is an additional labelling compliance step beyond the core energy label A-G class.[INFORMATIONAL] The EU blue light hazard class label is required by Delegated Reg 2019/2015 Annex VI since September 2021 and has no Chinese regulatory equivalent. Chinese manufacturers should document the photobiological risk group, commonly using EN 62471 as the technical method, and add the plain-language blue light class to EU-market product labels and online listings. The mandatory obligation is the EU Regulation; EN 62471 is the technical route for deriving the class. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
RoHS — 10 Restricted Substances (RoHS 2011/65/EU + (EU) 2015/863) China's equivalent is GB/T 26572-2011 (Requirements for concentration limits for certain restricted substances in electrical and electronic products), covering the original 6 RoHS substances (Pb, Hg, Cd, Cr(VI), PBB, PBDE) with the same concentration thresholds as EU RoHS. China RoHS 2 (Management Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products, SJ/T 11364-2014) requires a hazardous substance disclosure label (orange for contains substances above threshold / green for below threshold) on EEE products sold in China. As of 2026, the 4 phthalates (DEHP, BBP, DBP, DIBP) added by EU Directive 2015/863 are not yet in the CN mandatory restricted list under GB/T 26572.GB/T 26572-2011 — Requirements for concentration limits for certain restricted substances in EEE (SAC/SAMR — covers original 6 substances)
SJ/T 11364-2014 — Marking for the restricted use of hazardous substances in electronic and electrical products (China RoHS 2 disclosure label)		 Directive 2011/65/EU (RoHS 2), as amended by Directive (EU) 2015/863, restricts 10 substances in homogeneous materials in electrical and electronic equipment (EEE) placed on the EU market. The 10 restricted substances and maximum concentration values (MCV) are: Lead (Pb) ≤0.1%, Mercury (Hg) ≤0.1%, Cadmium (Cd) ≤0.01%, Hexavalent chromium (Cr(VI)) ≤0.1%, Polybrominated biphenyls (PBB) ≤0.1%, Polybrominated diphenyl ethers (PBDE) ≤0.1%, Di(2-ethylhexyl) phthalate (DEHP) ≤0.1%, Benzyl butyl phthalate (BBP) ≤0.1%, Dibutyl phthalate (DBP) ≤0.1%, Diisobutyl phthalate (DIBP) ≤0.1%. A RoHS Declaration of Conformity is required; CE marking for EEE in the EU includes RoHS compliance. Exemptions exist for specific applications — check current Annex III and IV for any applicable exemptions.Directive 2011/65/EU (RoHS 2 — Restriction of Hazardous Substances in EEE)
Commission Delegated Directive (EU) 2015/863 — amending Annex II to Directive 2011/65/EU (adding 4 phthalates, effective 22 July 2019)		 The most significant gap is the 4 phthalates (DEHP, BBP, DBP, DIBP) added by EU Directive (EU) 2015/863, effective 22 July 2019. These are not in CN GB/T 26572 — CN-compliant products have not been tested for phthalates under CN RoHS. For EU market entry, manufacturers must test all homogeneous materials (especially plastics, cables, insulation, gaskets) for the 4 phthalates. Additionally, EU RoHS requires a RoHS DoC and the CE marking to reflect RoHS compliance; CN RoHS 2 focuses on disclosure labelling rather than restricting market access. Check current RoHS Annex III/IV for any exemptions that may apply to specific LED luminaire components.[INFORMATIONAL] EU RoHS 2011/65/EU as amended by (EU) 2015/863 applies to LED luminaires placed on the EU market and restricts 10 substances including 4 phthalates not covered by CN GB/T 26572. Manufacturers must test for the 4 phthalates (DEHP, BBP, DBP, DIBP) — CN RoHS compliance alone is insufficient. A RoHS DoC is required in addition to the LVD and EMC DoC. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
REACH SVHC Article 33 Supply Chain Notification vs CN Chemical Regulations China does not have a direct equivalent to the REACH SVHC Article 33 supply chain notification obligation. The closest CN instruments are: MEP (Ministry of Ecology and Environment) Order No. 12 (2010, revised) on new chemical substance registration; GB 30981-2020 (Rules for the classification and labelling of chemicals) for hazardous chemicals labelling; and the Measures for the Environmental Management of New Chemical Substances (MEE Order 12, 2020). None of these create an equivalent obligation to proactively notify B2B customers when an SVHC is present in an article above 0.1% w/w.MEE Order No. 12 (2020) — Measures for the Environmental Management of New Chemical Substances (China)
GB 30981-2020 — Rules for the classification and labelling of chemicals (China)		 REACH Regulation (EC) 1907/2006 Article 33 requires that if any article contains a Substance of Very High Concern (SVHC) from the ECHA Candidate List at a concentration above 0.1% w/w, the supplier must proactively inform business customers (B2B) within 45 days of a request, and must also provide the same information to consumers upon request. The ECHA Candidate List is updated biannually by the European Chemicals Agency (ECHA) and contained 240+ substances as of 2026. The importer or EU-based manufacturer (whoever places the article on the EU market) is responsible for maintaining compliance with each Candidate List update. SVHC compliance is an ongoing obligation, not a one-time test.Regulation (EC) No 1907/2006 (REACH) — Article 33: Duty to communicate information on substances in articles
ECHA Candidate List of Substances of Very High Concern — updated biannually (240+ substances as of 2026)		 REACH SVHC Article 33 notification is an ongoing compliance obligation with no CN equivalent. Chinese LED luminaire manufacturers entering the EU market must: (1) establish a process to screen their supply chain against the ECHA Candidate List for each update (biannual); (2) be prepared to respond to B2B customer requests within 45 days if SVHC >0.1% w/w; (3) be prepared to respond to consumer requests on SVHC presence. This requires a supply chain management process and a live connection to the ECHA Candidate List — not a one-time factory test. ECHA's SCIP (Substances of Concern In Products) database registration may also be required for articles containing SVHCs above 0.1% w/w placed on the EU market.[INFORMATIONAL] REACH Article 33 SVHC supply chain notification is a mandatory ongoing obligation for LED luminaire importers or EU-established manufacturers. There is no CN equivalent. Chinese manufacturers must establish a process to track ECHA Candidate List updates biannually and screen their supply chain. SCIP database registration may additionally be required for articles containing SVHCs above 0.1% w/w. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
CE Marking Overall Process and Technical File vs CCC / CQC In China, the primary mandatory certification for luminaires sold in the residential market is CCC (China Compulsory Certification), administered by CNCA (Certification and Accreditation Administration of China). CCC requires mandatory third-party certification by a CNCA-authorized certification body (e.g., CQC — China Quality Certification Centre). CQC voluntary certification is also available for products not covered by mandatory CCC. For wireless-enabled luminaires (e.g., smart LED with Wi-Fi/Bluetooth), SRRC (State Radio Regulation Commission) type approval is additionally required in China. CCC certification bodies are not recognised for EU CE marking purposes.CNCA-C10-01 — CCC certification rules for luminaires (CNCA/CQC)
SRRC type approval — required for wireless-enabled luminaires in China		 CE marking for LED luminaires in the EU requires: (1) Compile a technical file (design drawings, component specifications, test reports for LVD, EMC, RoHS, Ecodesign, photobiological safety); (2) Prepare an EU Declaration of Conformity (DoC) listing all applicable directives (LVD 2014/35/EU, EMC 2014/30/EU, RoHS 2011/65/EU) and the ErP/Ecodesign Regulation (EU) 2019/2020; (3) Apply the CE mark on the product (minimum 5 mm in height); (4) Appoint an EU Authorised Representative if the manufacturer has no EU establishment; (5) Retain the technical file for 10 years from the last date of manufacture; (6) For standard luminaires, a Notified Body is not required — self-declaration is the standard route when harmonised standards are fully applied. Market surveillance authorities may request the technical file at any time.Directive 2014/35/EU (LVD — CE marking framework for luminaires)
Directive 2014/30/EU (EMC Directive)
Directive 2011/65/EU (RoHS 2)
Commission Regulation (EU) 2019/2020 (Ecodesign for light sources)
Commission Delegated Regulation (EU) 2019/2015 (Energy labelling for light sources)		 EU self-declaration route (no mandatory Notified Body for standard luminaires applying harmonised standards) vs CN mandatory third-party CCC. The CE and CCC processes run in parallel with no mutual recognition — a product requires separate technical files, test reports, and certification processes for each market. Key EU-specific requirements with no CN equivalent: (1) EU Authorised Representative mandatory for non-EU manufacturers (legal representative in EU, must be named in DoC and on product/packaging); (2) EU technical file must be in EU-accessible format and retained for 10 years; (3) DoC must list all applicable EU directives and regulations (LVD + EMC + RoHS + ErP); (4) CE mark minimum 5 mm height and must not be obscured. EU EPREL registration (Ecodesign) and REACH SVHC tracking (see ledeu-rohs-02) are additional obligations not covered by CCC.[INFORMATIONAL] CE marking for LED luminaires requires a multi-directive technical file covering LVD, EMC, RoHS, and Ecodesign; a combined DoC; CE mark on product; and EU Authorised Representative for non-EU manufacturers. CCC and CE are parallel non-mutual processes. The self-declaration route under LVD (no Notified Body required for standard luminaires) is more accessible than CN's mandatory third-party CCC, but the documentation burden is significant — and EPREL registration, REACH SVHC tracking, and EU energy label obligations add to the compliance scope. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
Electrical Safety — General Luminaire (LVD + EN 60598-1) China's equivalent is GB 7000.1-2015 (Luminaires — Part 1: General requirements and tests), which is technically aligned with IEC 60598-1:2014 (the base of EN 60598-1). For luminaires sold in the Chinese residential market, CCC (China Compulsory Certification) is mandatory under CNCA-C10-01. CCC testing is conducted by CNCA-authorized laboratories. CCC certification covers safety aspects broadly equivalent to GB 7000.1 but the conformity assessment process, documentation language, and CE marking obligations are separate and non-mutual with LVD.GB 7000.1-2015 — Luminaires — Part 1: General requirements and tests (SAC/SAMR)
CNCA-C10-01 — CCC certification rules for luminaires		 LED luminaires placed on the EU market must comply with the Low Voltage Directive 2014/35/EU. EN 60598-1:2021 (Luminaires — Part 1: General requirements and tests) is the current voluntary harmonised standard route that may confer a presumption of conformity for the LVD safety objectives when correctly applied; EN 60598-1:2015+A1:2018 was superseded, with its date of withdrawal in May 2024. Key requirements cover protection against electric shock (touch current, insulation resistance, creepage and clearance distances), thermal protection, mechanical strength, and wiring terminals. Manufacturers must prepare a Declaration of Conformity (DoC) and a technical file; CE marking is mandatory on the product. For standard luminaires, a Notified Body is not required — the self-declaration route under LVD applies whether conformity is demonstrated via harmonised standards or another adequate technical solution.Directive 2014/35/EU (Low Voltage Directive)
EN 60598-1:2021 — Luminaires — Part 1: General requirements and tests (supersedes EN 60598-1:2015+A1:2018; date of withdrawal May 2024)		 EU allows manufacturer self-declaration under LVD (no mandatory Notified Body for standard luminaires); China requires compulsory third-party CCC for residential luminaires. EU requires DoC in at least one EU official language and CE marking (min 5 mm height) on the product. An EU Authorised Representative is required if the manufacturer has no establishment in the EU. While EN 60598-1:2021 and GB 7000.1 share a common IEC 60598-1 base, creepage/clearance requirements at specific pollution-degree assumptions and some test conditions may differ; existing CN test reports cannot be directly reused for EU DoC — re-testing to EN 60598-1:2021 (EU edition with any EU deviations) by an ILAC MRA-recognised lab is advisable. Technical file must be retained for 10 years and be accessible to EU market surveillance authorities.[INFORMATIONAL] CE marking under LVD 2014/35/EU is mandatory for LED luminaires entering the EU market. EN 60598-1:2021 is the current voluntary harmonised route that may confer presumption of conformity; EN 60598-1:2015+A1:2018 was superseded, with its date of withdrawal in May 2024. The standard is not the mandatory legal obligation itself, and alternatives are allowed if conformity with the LVD is demonstrated. Chinese CCC certification under GB 7000.1-2015 does not satisfy the EU LVD conformity assessment pathway. Manufacturers commonly test to EN 60598-1:2021 and prepare an EU-language DoC with a complete technical file. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
LED Driver / Control Gear Safety (EN 61347-2-13) China's equivalent is GB 19510.14-2014 (Control gear for lamps — Particular requirements for DC or AC supplied electronic controlgear for LED modules), which is technically aligned with IEC 61347-2-13. CCC certification may be required for LED drivers in certain power ranges sold in the Chinese residential market. Chinese CCC test reports under GB 19510.14 are not accepted under the EU LVD conformity assessment pathway.GB 19510.14-2014 — Control gear for lamps — Part 2-13: Particular requirements for DC or AC supplied electronic controlgear for LED modules (SAC/SAMR) LED drivers (control gear for LED modules) intended for the EU market must comply with LVD 2014/35/EU. EN 61347-2-13:2014+A1:2017 (Lamp controlgear — Part 2-13: Particular requirements for DC or AC supplied electronic controlgear for LED modules) is a voluntary harmonised standard route that may confer a presumption of conformity for relevant LED-driver safety objectives when correctly applied. It specifies isolation class, dielectric strength, thermal endurance, and safety marking requirements for LED drivers. If the driver is sold as a separate product (not integrated into the luminaire), it requires its own DoC and CE marking in addition to the luminaire-level compliance.Directive 2014/35/EU (Low Voltage Directive)
EN 61347-2-13:2014+A1:2017 — Lamp controlgear — Part 2-13: Particular requirements for DC or AC supplied electronic controlgear for LED modules		 EN 61347-2-13 and GB 19510.14 are both derived from IEC 61347-2-13 and are largely harmonized in technical content. Key EU-specific gaps: (1) if the LED driver is sold as a standalone product separately from the luminaire, a separate DoC and CE marking is required for the driver itself under the LVD; (2) if the manufacturer uses the voluntary harmonised route, the DoC should reference the specific EN 61347-2-13 version applied, while alternative evidence may also be used to demonstrate LVD conformity; (3) Chinese CCC covers certain power ranges — check whether the specific driver power/voltage range triggers CCC or only voluntary CQC in CN. An EU Authorised Representative is needed if the driver manufacturer has no EU establishment.[INFORMATIONAL] LED drivers placed on the EU market as standalone products require CE marking under LVD 2014/35/EU. EN 61347-2-13:2014+A1:2017 is a voluntary harmonised route that may confer presumption of conformity; it is not the mandatory legal obligation itself. Chinese GB 19510.14 CCC certification does not satisfy the EU pathway. When the driver is integrated into a luminaire and not sold separately, its safety evidence forms part of the luminaire technical file, commonly alongside EN 60598-1 evidence where that voluntary route is used. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified

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