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인사이트 · 2026-10-03

Lighting: safety, energy and the label are separate gates

Lighting is the category most easily misled by the idea that one mark covers everything. Its safety, electromagnetic compatibility, energy consumption and labelling sit under different regulations, each with its own conformity route, and none substitutes for another.

One luminaire, several gates

Asking whether a luminaire has passed the standard usually produces nothing useful, because its obligations split into lines that do not substitute for each other: electrical safety, electromagnetic compatibility, energy performance, and the energy label. The EU adds a separate ecodesign regulation for light sources on top. These lines come from different regulations, and the conformity routes differ - some can be self-declared, others need a third party.

Keeping those lines apart is the step that is easiest to get right, and easiest to get wrong.

EU: one line for safety, two for energy

Safety falls under the Low Voltage Directive, LVD 2014/35/EU, which applies to luminaires within its voltage range; electromagnetic compatibility under EMC 2014/30/EU; hazardous substances under RoHS 2011/65/EU; and products with wireless functions also under RED. The supporting luminaire safety standards are the EN 60598 series.

Energy needs saying separately, because two regulations divide the work: ecodesign requirements under (EU) 2019/2020, and the energy label under (EU) 2019/2015. The first governs what the product has to achieve; the second governs how the label on the shelf is drawn and graded. Both sit under the ErP 2009/125/EC framework, but they are two independent technical documents that both have to be met.

That is the point worth keeping from this article: finishing the ecodesign testing does not mean the label is right. The label has its own format, registration and display requirements, and it hangs off a different regulation.

UK: running in parallel

The UK keeps the Electrical Equipment (Safety) Regulations 2016 and its own EMC regulations, uses the UKCA mark in Great Britain, and recognises CE indefinitely, so the same shipment can take either route into GB. The energy label has its own UK rules.

The same warning as in the appliances article applies: the two lists of harmonised standards are not identical item for item, so check a test report against the list of the market it is aimed at.

US: safety through listing, obligations on EMC and energy

There is no single federal luminaire safety act in the US, and no unified mandatory mark equivalent to CE. What is mandatory federally sits in two places: products with digital circuitry or radio functions fall under FCC Part 15, and the energy performance of general lighting under DOE standards at 10 CFR 430, with labelling under the FTC EnergyGuide rule at 16 CFR 305.

So what carries safety? Standards such as UL 1598 and UL 8750, listed by a third-party certification body, plus the requirements of sales channels and insurers. The standards themselves are voluntary, but hard to avoid in practice. In the US, what a buyer should ask for is the test report and the listing record, not a mark.

Japan and Korea: PSE and KC

Japan regulates under the Electrical Appliance and Material Safety Act (DENAN); luminaires and LEDs fall within it and carry the PSE mark, in two tiers. Products designated as specified electrical appliances need third-party inspection by a registered inspection body and carry the diamond mark; the rest may be self-declared with the circle mark.

Korea regulates under the Electrical Appliances and Consumer Products Safety Control Act, and under the KC mark the three tiers apply again: safety certification, safety confirmation, and a supplier's declaration of conformity. In both countries the tier follows the regulatory list rather than how complex the product looks, so two similar luminaires from one factory can land in different tiers.

China: GB 7000 plus CCC

China builds on GB 7000.1 and the GB 7000 series parts for luminaire safety, with EMC under GB 4343.1 for disturbance and GB 17625.1 for harmonics, and energy under its own standards and energy label scheme. Luminaires inside the CCC mandatory certification catalogue need certification through a designated body, including a factory inspection; those outside carry product liability under the mandatory standards and a declaration.

The inside and outside distinction still matters here: whether a product ships as an engineering accessory or retails on its own can change the answer.

Canada and Australia-NZ: mandatory at provincial and state level

Canada has no federal electrical safety act; the obligation comes from provincial law, which typically requires certification by an SCC-accredited body, with energy under NRCan regulations.

In Australia and New Zealand the obligation sits in state electrical safety law and is managed through the EESS tiers: higher-risk levels need third-party certification and registration, lower-risk levels lean on a declaration, and the common mark is RCM. The technical standards for luminaires are the AS/NZS 60598 series. As with appliances, both markets share one trait: the mark is national, enforcement is local.

Gulf and Brazil: designated bodies and local representatives

The Gulf states regulate under the GSO technical regulation for low-voltage electrical equipment, requiring assessment by a designated body and the G-Mark, with Saudi Arabia routing through SABER. Brazil applies mandatory certification through INMETRO and generally requires a local representative; luminaires with wireless functions also need ANATEL certification.

In both, finding a local entity to hold the paperwork often takes longer than the testing itself, the same pattern as in appliances.

Ten markets side by side

Set the lines next to each other and you can see the obligation landing at different layers:

Finishing the safety line only clears the first gate. The EU energy and labelling line, and the US EMC and energy line, each stop the shipment again.

What to ask before you order

Ask for lighting evidence line by line; asking in one lump is the fastest way to hear "we are certified". On safety, which edition the test was run against and which laboratory issued the report. On EMC, whether it covers the frequency and limit requirements of the target market. On energy, the measured value, the regulation it was assessed against and the label version - and ask where the label was registered.

That last question is easily skipped. The EU energy label has to be registered in the product database, and the work is often treated as drawing a picture; it surfaces only when a platform rejects the listing. To work through this in order, start with the free verification checklist. The previous article in this series, appliance rules, covers the same structure; the next, batteries and staged compliance, covers a different kind of difficulty. To see how certifications are recorded in a report, look at a report sample, or get in touch.