CROSS-STANDARD public interest · LED luminaire
China-to-Turkey 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 Turkey's CE marking requirements (Turkey applies the EU LVD, EMC, RoHS and Ecodesign directives via the EU-Turkey Customs Union), TSE / TS EN national standard adoptions and the TSE mark, the EU-aligned Turkish energy-efficiency label, 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
| Compliance item | Common China baseline | Turkey (TSE / CE) | Gap / action | Source + verification date |
|---|---|---|---|---|
| Ecodesign Minimum Efficacy and Performance (Turkey EU-aligned Ecodesign Regulation) | 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. China's grid is 220/380 V, 50 Hz. GB 30255 does not comprehensively cover power factor, CRI minimums, or lifetime requirements in the same binding way as the Turkish EU-aligned Ecodesign regulation.GB 30255-2019 — Energy efficiency requirements for LED room luminaires (SAC/SAMR) | Turkey applies an EU-aligned Ecodesign regulation that transposes Commission Regulation (EU) 2019/2020 into Turkish law through the EU-Turkey Customs Union, administered by the Ministry of Trade (T.C. Ticaret Bakanlığı). It sets mandatory minimum performance requirements for light sources placed on the Turkish market: 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 the current Turkish transposition / 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. The Turkish grid is 230/400 V, 50 Hz, and products must be rated for this supply. Products not meeting the minimum requirements cannot be placed on the Turkish market.Turkey EU-aligned Ecodesign Regulation (transposing Commission Regulation (EU) 2019/2020 — Ecodesign requirements for light sources and separate control gears) — Ministry of Trade (T.C. Ticaret Bakanlığı) TS EN national adoptions of light-source performance standards (TSE) |
Turkey's EU-aligned 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 the Turkish Ecodesign minimum. Beyond efficacy, Turkey 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). Both grids are 50 Hz, but Turkey is 230/400 V vs China's 220/380 V — confirm voltage rating and tolerance for the Turkish supply. Manufacturers achieving only CN Grade 3 must upgrade product performance before Turkish market entry. Note: exact lm/W thresholds vary by product sub-category; always verify against the current Turkish transposition (EU-aligned) Annex II for the specific product sub-category.[INFORMATIONAL] Turkey's EU-aligned Ecodesign regulation (transposing Reg (EU) 2019/2020 via the Customs Union) sets mandatory minimum efficacy, CRI, lifetime, and power factor requirements for LED light sources placed on the Turkish market. Chinese Grade 3 products (≥70 lm/W) may not meet the minimums. Turkey additionally mandates CRI ≥80, lifetime ≥6,000 h, and power factor ≥0.9 (≥25W) — requirements not fully mirrored in GB 30255. The supply is 230/400 V, 50 Hz (same 50 Hz as China, voltage differs from China's 220/380 V). Verify exact thresholds for the specific product sub-category in the current Turkish transposition before market entry. | T.C. Ticaret Bakanlığı (Ministry of Trade of Türkiye)2026-06-15 · reference |
| EU-aligned Turkish Energy Label A-G (Rescaled) + Registration | 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 Turkish (EU-aligned) energy-labelling 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 |
Turkey applies an EU-aligned energy-labelling regulation that transposes Commission Delegated Regulation (EU) 2019/2015 through the EU-Turkey Customs Union, administered by the Ministry of Trade (T.C. Ticaret Bakanlığı). It mandates a rescaled A-G energy label for regulated light sources. 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 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 registration and labelling obligation. Mandatory steps for in-scope products before market placement in Turkey: (1) calculate the EEI and determine the A-G class; (2) register the product as required under the Turkish energy-labelling regime (EU-aligned; the EU EPREL framework is the reference model for the registry obligation — confirm the current Turkish registration channel with the Ministry of Trade); (3) display the EU-aligned Turkish energy label on product packaging, physical product (where required), and online product listings sold into Turkey.Turkey EU-aligned Energy Labelling Regulation (transposing Commission Delegated Regulation (EU) 2019/2015 — Energy labelling of light sources; rescaled A-G label and registration) — Ministry of Trade (T.C. Ticaret Bakanlığı) | The EU-aligned Turkish energy-label registration is a mandatory pre-market step with no CN equivalent. The Turkish 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 Turkish label class. Both schemes are mandatory but non-mutual: a product must be registered separately for the Turkish (EU-aligned) regime and with CQC/CECP for CN. Additionally, the Turkish label must also include the blue light hazard class (see ledtr2-photobio-02). Online retailers selling into Turkey must display the EU-aligned Turkish energy label on product listing pages — a requirement that CN-market product pages do not carry.[INFORMATIONAL] The EU-aligned Turkish rescaled A-G energy label and product registration are mandatory for in-scope light sources under Turkey's transposition of 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 registration obligation attaches to the contained source. Verify your product configuration before assuming the luminaire as a whole must be registered. Chinese CEL registration does not substitute. The EEI-based Turkish class and lm/W-based CN grade are calculated differently and cannot be directly cross-mapped. Confirm the current Turkish registration channel with the Ministry of Trade early — it must precede first market placement. | T.C. Ticaret Bakanlığı (Ministry of Trade of Türkiye)2026-06-15 · reference |
| EMC Emissions — TS EN 55015 Conducted and Radiated (Turkey EU-aligned EMC Regulation) | 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 Turkish (EU-aligned) EMC 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 Turkish market must comply with Turkey's EU-aligned EMC regulation, which transposes EMC Directive 2014/30/EU through the EU-Turkey Customs Union and is administered by the Ministry of Trade. TS EN 55015 (the Turkish adoption of 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) on the 230/400 V, 50 Hz Turkish supply. CE marking requires an EMC Declaration of Conformity referencing the EU-aligned EMC transposition. Luminaires with integrated wireless functionality (e.g., Bluetooth dimming, Wi-Fi smart lighting) also fall under Turkey's EU-aligned Radio Equipment regulation (transposing RED 2014/53/EU).Turkey EU-aligned EMC Regulation (transposing Directive 2014/30/EU) — Ministry of Trade (T.C. Ticaret Bakanlığı) TS EN 55015 (Turkish adoption of EN 55015:2019+A11:2020) — Limits and methods of measurement of radio disturbance characteristics of electrical lighting and similar equipment (TSE) |
TS EN 55015 and GB 17743 are both derived from CISPR 15 and emission limits are largely harmonized. Key gaps: (1) Turkey requires a separate EMC DoC in addition to the LVD DoC (both are referenced in the overall CE marking DoC under the EU-aligned transpositions); (2) EMC testing should be conducted at an ILAC MRA-member accredited laboratory for Turkish/EU DoC purposes — Chinese CNAS-accredited labs are generally ILAC members and may issue reports accepted for compliance, but confirm the lab's market scope; (3) if the luminaire incorporates wireless functionality, Turkey's EU-aligned Radio Equipment regulation (transposing RED 2014/53/EU) applies and the EMC DoC must also reference it; (4) the DoC must cite the specific TS EN 55015 amendment version in force; (5) the supply is 230/400 V, 50 Hz — same 50 Hz as China, voltage differs from China's 220/380 V, so conducted-emission test conditions reflect the Turkish mains.[INFORMATIONAL] CE marking for LED luminaires in Turkey requires EMC compliance under Turkey's EU-aligned EMC regulation (transposing Directive 2014/30/EU via the Customs Union). TS EN 55015 (Turkish adoption of EN 55015:2019+A11:2020) is a voluntary harmonised route that may confer presumption of conformity for emissions; alternatives are allowed if conformity is demonstrated. Emission limits are broadly harmonized with CN GB 17743 (both CISPR 15-derived), but a separate Turkish EMC DoC is required and testing must be at an ILAC MRA-recognised laboratory. The supply is 230/400 V, 50 Hz. Smart luminaires with wireless functions additionally require compliance with Turkey's EU-aligned Radio Equipment regulation. | T.C. Ticaret Bakanlığı (Ministry of Trade of Türkiye)2026-06-15 · reference |
| EMC Immunity — TS 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 TS 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 Turkish market must meet the essential requirements of Turkey's EU-aligned EMC regulation (transposing Directive 2014/30/EU), including adequate immunity in their intended electromagnetic environment. TS EN 61547 (the Turkish adoption of 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, at 50 Hz for the Turkish grid), and voltage dips/interruptions (IEC 61000-4-11, referenced to the 230 V Turkish supply).Turkey EU-aligned EMC Regulation (transposing Directive 2014/30/EU) — Ministry of Trade (T.C. Ticaret Bakanlığı) TS EN 61547 (Turkish adoption of EN 61547:2009) — Equipment for general lighting purposes — EMC immunity requirements (TSE) |
Turkey mandates conformity with the EU-aligned EMC regulation essential requirements (transposing Directive 2014/30/EU); TS 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 TS 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: the Turkish DoC must cover EMC immunity evidence; CN CCC documentation may not include equivalent immunity test reports. Manufacturers using the harmonised route should include TS EN 61547 immunity test reports from an ILAC-recognised laboratory in the technical file. Immunity tests reference the 230 V, 50 Hz Turkish supply.[INFORMATIONAL] LED luminaires must satisfy Turkey's EU-aligned EMC regulation essential requirements (transposing Directive 2014/30/EU), including immunity. TS EN 61547 (Turkish adoption of 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 Turkish 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 Turkish DoC and technical file must contain adequate EMC immunity evidence referenced to the 230 V, 50 Hz supply. | T.C. Ticaret Bakanlığı (Ministry of Trade of Türkiye)2026-06-15 · reference |
| Photobiological Safety — Blue Light Hazard (TS 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 adopted by Turkey as TS EN 62471). 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 Turkish EU-aligned Ecodesign framework.GB/T 20145-2006 — Photobiological safety of lamps and lamp systems (SAC/SAMR — recommended standard) | Turkey's EU-aligned Ecodesign regulation (transposing Commission Regulation (EU) 2019/2020, Annex II) makes photobiological risk classification and technical documentation a legal obligation for regulated LED light sources and relevant luminaires placed on the Turkish market. TS EN 62471 (the Turkish adoption of EN 62471:2008 — Photobiological safety of lamps and lamp systems) is the referenced technical method commonly used to derive the risk group; IEC 62471-7:2023 adds LED/light-source-specific photobiological safety guidance that may be useful for technical assessment where accepted by the chosen conformity route. The mandatory obligation is the regulation, not either 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.Turkey EU-aligned Ecodesign Regulation (transposing Commission Regulation (EU) 2019/2020 — Annex II: photobiological safety) — Ministry of Trade (T.C. Ticaret Bakanlığı) TS EN 62471 (Turkish adoption of EN 62471:2008) — Photobiological safety of lamps and lamp systems (harmonised standard for risk group classification) (TSE) IEC 62471-7:2023 — Photobiological safety of lamps and lamp systems — Part 7: Light sources and luminaires primarily emitting visible radiation |
Turkey's EU-aligned Ecodesign regulation (Annex II) requires photobiological risk group classification and declaration for regulated light sources — this is not optional. TS EN 62471 is the referenced technical method commonly used to determine the risk group, and IEC 62471-7:2023 can provide LED/light-source-specific technical guidance, 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 Turkish market should document a defensible risk-group assessment, commonly by testing to TS EN 62471 and considering IEC 62471-7:2023 where relevant; 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 Turkey's EU-aligned Ecodesign regulation (transposing Reg (EU) 2019/2020). TS EN 62471 (Turkish adoption of EN 62471:2008) is the referenced technical method commonly used to derive the classification, and IEC 62471-7:2023 may support LED/light-source-specific assessment; neither should be described as the standalone mandatory legal obligation. Chinese GB/T 20145-2006 testing may be useful as a reference, but Turkish technical documentation should show a classification aligned with the Turkish (EU-aligned) Ecodesign framework. Manufacturers should formally document the risk group in the technical file; RG2/RG3 products require additional labelling and usage warnings. | T.C. Ticaret Bakanlığı (Ministry of Trade of Türkiye)2026-06-15 · reference |
| Blue Light Hazard Class on Turkish Product Label (EU-aligned Energy Labelling) | 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 the Turkish EU-aligned energy-labelling regulation.GB 30255-2019 — Energy efficiency requirements for LED room luminaires (SAC/SAMR — no blue light class requirement) | Turkey's EU-aligned energy-labelling regulation (transposing Commission Delegated Regulation (EU) 2019/2015, Annex VI) requires blue light hazard class information on labels for in-scope products. The class is derived from the photobiological risk assessment, commonly using TS 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 Turkish market.Turkey EU-aligned Energy Labelling Regulation (transposing Commission Delegated Regulation (EU) 2019/2015 — Annex VI: blue light hazard class labelling) — Ministry of Trade (T.C. Ticaret Bakanlığı) | The Turkish 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 Turkish export, the blue light hazard class required by the EU-aligned Turkish energy-labelling regulation must be added to product labels and packaging. This requires: (1) documenting a photobiological risk assessment, commonly using TS EN 62471 risk group testing; (2) updating label artwork to include the blue light class in the EU-aligned Turkish label layout per Annex VI; (3) ensuring the class is visible on any online product listings sold into Turkey (required by the energy labelling framework). This is an additional labelling compliance step beyond the core energy label A-G class.[INFORMATIONAL] The Turkish blue light hazard class label is required by Turkey's EU-aligned energy-labelling regulation (transposing Delegated Reg (EU) 2019/2015 Annex VI) and has no Chinese regulatory equivalent. Chinese manufacturers should document the photobiological risk group, commonly using TS EN 62471 as the technical method, and add the plain-language blue light class to Turkish-market product labels and online listings. The mandatory obligation is the Turkish regulation; TS EN 62471 is the technical route for deriving the class. | T.C. Ticaret Bakanlığı (Ministry of Trade of Türkiye)2026-06-15 · reference |
| RoHS — 10 Restricted Substances (Turkish RoHS Regulation, EU-aligned) | 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/Turkish 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 the EU 2015/863 amendment (and mirrored in the Turkish transposition) 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) |
Turkey's RoHS regulation (the EU-aligned national transposition of Directive 2011/65/EU as amended by Directive (EU) 2015/863, applied through the EU-Turkey Customs Union and administered via the relevant Turkish ministry) restricts 10 substances in homogeneous materials in electrical and electronic equipment (EEE) placed on the Turkish 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 Turkey includes RoHS compliance. Exemptions exist for specific applications — check the current Turkish transposition Annexes (mirroring EU Annex III and IV) for any applicable exemptions.Turkish RoHS Regulation (EU-aligned national transposition of Directive 2011/65/EU (RoHS 2) — Restriction of Hazardous Substances in EEE) EU-aligned amendment transposing Commission Delegated Directive (EU) 2015/863 (adding 4 phthalates) |
The most significant gap is the 4 phthalates (DEHP, BBP, DBP, DIBP) added by the EU (EU) 2015/863 amendment and mirrored in the Turkish RoHS transposition. These are not in CN GB/T 26572 — CN-compliant products have not been tested for phthalates under CN RoHS. For Turkish market entry, manufacturers must test all homogeneous materials (especially plastics, cables, insulation, gaskets) for the 4 phthalates. Additionally, Turkish 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 the current Turkish RoHS transposition Annexes (mirroring EU Annex III/IV) for any exemptions that may apply to specific LED luminaire components.[INFORMATIONAL] Turkey's RoHS regulation (EU-aligned transposition of 2011/65/EU as amended by (EU) 2015/863) applies to LED luminaires placed on the Turkish 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. | T.C. Ticaret Bakanlığı (Ministry of Trade of Türkiye)2026-06-15 · reference |
| KKDIK (Turkish REACH-equivalent) SVHC Supply Chain Notification vs CN Chemical Regulations | China does not have a direct equivalent to the KKDIK / 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) |
Turkey's KKDIK Regulation (Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals — the Turkish REACH-equivalent, administered by the Ministry of Environment, Urbanisation and Climate Change) mirrors the EU REACH framework, including a duty to communicate information on Substances of Very High Concern (SVHC) in articles. As under REACH Article 33, where an article contains an SVHC from the Turkish Candidate List at a concentration above 0.1% w/w, the supplier must proactively inform business customers (B2B), commonly within 45 days of a request, and provide the same information to consumers on request. The Turkish SVHC/Candidate List under KKDIK is aligned with the ECHA Candidate List and is updated periodically. The Turkey-established importer (ithalatçı) or manufacturer placing the article on the Turkish market is responsible for maintaining compliance with each Candidate List update. SVHC compliance is an ongoing obligation, not a one-time test.KKDIK Regulation (Kimyasalların Kaydı, Değerlendirilmesi, İzni ve Kısıtlanması — Turkish REACH-equivalent on Registration, Evaluation, Authorisation and Restriction of Chemicals) — Ministry of Environment, Urbanisation and Climate Change Turkish SVHC / Candidate List under KKDIK (aligned with the ECHA Candidate List) |
The KKDIK SVHC notification obligation is an ongoing compliance duty with no CN equivalent. Chinese LED luminaire manufacturers entering the Turkish market must: (1) establish a process to screen their supply chain against the Turkish (KKDIK) Candidate List, which is aligned with the ECHA Candidate List, for each update; (2) be prepared to respond to B2B customer requests, commonly 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 KKDIK Candidate List — not a one-time factory test. Turkish chemical-inventory notification/registration obligations under KKDIK may additionally apply for substances/articles placed on the Turkish market — verify current KKDIK requirements with the Ministry of Environment, Urbanisation and Climate Change.[INFORMATIONAL] KKDIK (Turkey's REACH-equivalent) SVHC supply chain notification is a mandatory ongoing obligation for LED luminaire importers or Turkey-established manufacturers. There is no CN equivalent. Chinese manufacturers must establish a process to track the Turkish (KKDIK) Candidate List — aligned with the ECHA Candidate List — and screen their supply chain. Turkish chemical-inventory notification/registration under KKDIK may additionally apply for substances/articles placed on the Turkish market. | T.C. Çevre, Şehircilik ve İklim Değişikliği Bakanlığı (Ministry of Environment, Urbanisation and Climate Change of Türkiye)2026-06-15 · reference |
| 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 Turkish 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 Turkey (required via the EU-aligned national transpositions applied under the EU-Turkey Customs Union) requires: (1) Compile a technical file (design drawings, component specifications, test reports for LVD, EMC, RoHS, Ecodesign, photobiological safety); (2) Prepare an EU/Turkish Declaration of Conformity (DoC) listing all applicable Turkish transpositions of the directives (LVD 2014/35/EU, EMC 2014/30/EU, RoHS 2011/65/EU) and the EU-aligned Ecodesign regulation; (3) Apply the CE mark on the product (minimum 5 mm in height); (4) Identify a Turkey-established importer (ithalatçı) as the responsible economic operator named on the product/packaging; (5) Retain the technical file (commonly 10 years from the last date of manufacture); (6) For standard luminaires, a notified/conformity-assessment body is not required — self-declaration is the standard route when harmonised standards are fully applied. In addition, TSE / TS EN national adoptions and the TSE mark may apply for certain product categories under Turkish national schemes, and import is commonly handled through ports such as Mersin or Istanbul. Market surveillance authorities (Ministry of Trade) may request the technical file at any time.Turkish transposition of Directive 2014/35/EU (LVD — CE marking framework for luminaires) Turkish transposition of Directive 2014/30/EU (EMC Directive) Turkish transposition of Directive 2011/65/EU (RoHS 2) Turkey EU-aligned Ecodesign Regulation (transposing Commission Regulation (EU) 2019/2020) Turkey EU-aligned Energy Labelling Regulation (transposing Commission Delegated Regulation (EU) 2019/2015) TS EN national adoptions and TSE mark (TSE) — applicable to certain product categories |
Turkish self-declaration route (no mandatory conformity-assessment 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 Turkey-specific requirements with no CN equivalent: (1) a Turkey-established importer (ithalatçı) must be named as the responsible economic operator on the product/packaging (the role mirrors the EU importer/authorised-representative concept; for a Chinese manufacturer with no Turkish establishment, the importer carries the responsible-operator duties); (2) the technical file must be accessible to the Turkish market surveillance authority and retained (commonly 10 years); (3) the DoC must list all applicable Turkish transpositions (LVD + EMC + RoHS + Ecodesign); (4) the CE mark minimum 5 mm height and must not be obscured; (5) TSE / TS EN national adoptions and the TSE mark may apply for certain categories. Turkish energy-label registration (Ecodesign) and KKDIK SVHC tracking (see ledtr2-rohs-02) are additional obligations not covered by CCC. Import logistics commonly route through Mersin or Istanbul ports.[INFORMATIONAL] CE marking for LED luminaires in Turkey requires a multi-directive technical file covering LVD, EMC, RoHS, and Ecodesign (via the EU-aligned Turkish transpositions); a combined DoC; CE mark on product; and a Turkey-established importer (ithalatçı) named as the responsible economic operator for non-Turkish manufacturers. CCC and CE are parallel non-mutual processes. The self-declaration route under the LVD transposition (no conformity-assessment body required for standard luminaires) is more accessible than CN's mandatory third-party CCC, but the documentation burden is significant — and Turkish energy-label registration, KKDIK SVHC tracking, the EU-aligned energy label, and possible TSE / TS EN national adoptions add to the compliance scope. Import is commonly handled through Mersin or Istanbul ports. | T.C. Ticaret Bakanlığı (Ministry of Trade of Türkiye)2026-06-15 · reference |
| Electrical Safety — General Luminaire (LVD transposition + TS EN 60598-1) | China's current general luminaire safety standard is GB/T 7000.1-2023 (Luminaires — Part 1: General requirements and tests), replacing GB 7000.1-2015 from 1 January 2026. The edition change also changes the standard designation from mandatory GB to recommended GB/T; CCC obligations for in-scope luminaires remain governed by the applicable CNCA rules and implementation requirements rather than by the GB/T designation alone. China's grid is 220/380 V, 50 Hz. CCC testing is conducted by CNCA-authorized laboratories. CCC certification covers safety aspects broadly comparable to GB/T 7000.1, but the conformity assessment process, documentation language, and CE marking obligations are separate and non-mutual with the Turkish LVD transposition.GB/T 7000.1-2023 — Luminaires — Part 1: General requirements and tests (replaces GB 7000.1-2015 from 1 January 2026; recommended GB/T designation) CNCA-C10-01 — CCC certification rules for luminaires |
LED luminaires placed on the Turkish market must comply with Turkey's transposition of the Low Voltage Directive 2014/35/EU, applied through the EU-Turkey Customs Union. TS EN 60598-1 (the Turkish adoption of 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, evaluated for the 230/400 V, 50 Hz Turkish supply. Manufacturers must prepare a Declaration of Conformity (DoC) and a technical file; CE marking is mandatory on the product. For standard luminaires, a conformity-assessment body is not required — the self-declaration route under the LVD transposition applies whether conformity is demonstrated via harmonised standards or another adequate technical solution. TSE / TS EN national adoptions and the TSE mark may also apply for certain product categories.Turkish transposition of Directive 2014/35/EU (Low Voltage Directive) TS EN 60598-1 (Turkish adoption of EN 60598-1:2021) — Luminaires — Part 1: General requirements and tests (supersedes EN 60598-1:2015+A1:2018; date of withdrawal May 2024) (TSE) |
Turkey allows manufacturer self-declaration under the LVD transposition (no mandatory conformity-assessment body for standard luminaires); China requires compulsory third-party CCC for residential luminaires. Turkey requires a DoC (commonly in Turkish, and/or an EU official language) and CE marking (min 5 mm height) on the product, with a Turkey-established importer (ithalatçı) named as the responsible economic operator if the manufacturer has no establishment in Turkey. While TS 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; the Turkish supply is 230/400 V, 50 Hz (same 50 Hz as China, voltage differs from China's 220/380 V), so test conditions reflect the Turkish mains. Existing CN test reports cannot be directly reused for the Turkish DoC — re-testing to TS EN 60598-1:2021 by an ILAC MRA-recognised lab is advisable. The technical file must be retained (commonly 10 years) and be accessible to Turkish market surveillance authorities. TSE / TS EN national adoptions and the TSE mark may additionally apply for certain categories.[INFORMATIONAL] CE marking under Turkey's transposition of LVD 2014/35/EU is mandatory for LED luminaires entering the Turkish market. TS EN 60598-1:2021 (Turkish adoption) 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 transposition is demonstrated. Chinese CCC certification and GB/T 7000.1-2023 evidence do not satisfy the Turkish LVD conformity assessment pathway. Test conditions reflect the 230/400 V, 50 Hz Turkish supply. Manufacturers commonly test to TS EN 60598-1:2021 and prepare a Turkish-language DoC with a complete technical file; a Turkey-established importer must be named. | T.C. Ticaret Bakanlığı (Ministry of Trade of Türkiye)2026-06-15 · reference |
| LED Driver / Control Gear Safety (TS 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 Turkish 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 Turkish market must comply with Turkey's transposition of LVD 2014/35/EU. TS EN 61347-2-13 (the Turkish adoption of 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, evaluated for the 230 V, 50 Hz Turkish AC supply where AC-supplied. 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.Turkish transposition of Directive 2014/35/EU (Low Voltage Directive) TS EN 61347-2-13 (Turkish adoption of EN 61347-2-13:2014+A1:2017) — Lamp controlgear — Part 2-13: Particular requirements for DC or AC supplied electronic controlgear for LED modules (TSE) |
TS EN 61347-2-13 and GB 19510.14 are both derived from IEC 61347-2-13 and are largely harmonized in technical content. Key Turkey-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 Turkish LVD transposition; (2) if the manufacturer uses the voluntary harmonised route, the DoC should reference the specific TS EN 61347-2-13 version applied, while alternative evidence may also be used to demonstrate conformity; (3) Chinese CCC covers certain power ranges — check whether the specific driver power/voltage range triggers CCC or only voluntary CQC in CN; (4) AC-supplied drivers are rated for the 230 V, 50 Hz Turkish supply (same 50 Hz as China, voltage differs from China's 220 V). A Turkey-established importer (ithalatçı) is needed as the responsible economic operator if the driver manufacturer has no Turkish establishment.[INFORMATIONAL] LED drivers placed on the Turkish market as standalone products require CE marking under Turkey's LVD transposition (2014/35/EU). TS EN 61347-2-13 (Turkish adoption of 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 Turkish pathway. AC-supplied drivers are rated for the 230 V, 50 Hz Turkish supply. When the driver is integrated into a luminaire and not sold separately, its safety evidence forms part of the luminaire technical file, commonly alongside TS EN 60598-1 evidence where that voluntary route is used. A Turkey-established importer must be named for non-Turkish manufacturers. | T.C. Ticaret Bakanlığı (Ministry of Trade of Türkiye)2026-06-15 · reference |
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- T.C. Ticaret Bakanlığı (Ministry of Trade of Türkiye) · accessed 2026-06-15 · reference · used in 10 rows
- T.C. Çevre, Şehircilik ve İklim Değişikliği Bakanlığı (Ministry of Environment, Urbanisation and Climate Change of Türkiye) · accessed 2026-06-15 · reference · used in 1 rows