GPSR for LED Lighting: LVD, EMC, Energy Labels (EPREL) and Ecodesign for Lamps and Luminaires

First, classify your light

Which rules apply depends on the power supply, whether there is a radio function, and whether the product is a 'light source' or a 'containing product':

All electrical lighting must also meet RoHS 2011/65/EU and WEEE 2012/19/EU registration duties. The LVD, EMC Directive, RED, RoHS and the Ecodesign Directive are all listed in Article 4(5) of Regulation (EU) 2019/1020, so lighting needs an EU economic operator whose name and contact details appear on the product, packaging, parcel or an accompanying document.

LVD and EMC: the base for mains lighting

Article 1 of the LVD 2014/35/EU limits it to electrical equipment with a voltage rating between 50 and 1000 V AC or 75 and 1500 V DC. Bulbs, luminaires and drivers connected to 230 V mains are in scope. The manufacturer's duties in Article 6 include:

• design to the safety objectives in Annex I, draw up technical documentation, complete conformity assessment, issue an EU declaration of conformity (DoC) and affix CE; keep both for 10 years;
• a type, batch or serial number on the product, or on the packaging or accompanying document if it does not fit;
• manufacturer name, registered trade name or mark and a single postal contact address on the product;
• instructions and safety information in a language easily understood by consumers in the country of sale.

The EMC Directive 2014/30/EU covers emissions and immunity; LED drivers are a common source of interference, so almost every light with electronics needs an EMC assessment. Common lighting safety standards include the EN 60598 series (luminaires) and EN 62471 (photobiological safety, such as blue-light hazard). Check the Official Journal list and your lab for the versions that give a presumption of conformity.

One DoC can cover the LVD, EMC, RoHS and the ecodesign regulation. Ecodesign is CE legislation too: Article 5 of 2019/2020 requires internal design control or a management system under the Ecodesign Directive, so its requirements belong in the same technical file. For the CE / GPSR split see GPSR vs CE marking.

Ecodesign Regulation (EU) 2019/2020: light sources and containing products

Applicable since 1 September 2021, it covers light sources and separate control gears (drivers), including those placed on the market in a containing product (Article 1). Key points:

• What counts as a light source: Article 2(1) requires all of a set of optical characteristics, including chromaticity within a range, a luminous flux between 60 and 82 000 lm and a colour rendering index above 0. Very dim decorative lights under 60 lm may fall outside the definition, but check each criterion in the annexes rather than assuming.
• Annex II requirements: maximum on-mode power (efficiency), functional requirements (such as colour rendering and flicker metrics) and information requirements: the useful luminous flux (lm) and colour temperature (K), and beam angle for directional sources, on the light source where there is space, plus a set of parameters on the packaging.
• Containing products (Article 4): manufacturers, importers or authorised representatives of luminaires must ensure light sources and separate control gears can be replaced with commonly available tools without permanent damage, unless the technical documentation gives a functional reason why not. They must state whether end-users or qualified persons can replace them, on a free website and, for products sold to end-users, on the packaging at least as a pictogram and in the instructions. Light sources must also be removable at end of life.
• Software updates (Article 7, as amended by (EU) 2021/341): after a firmware or software update, energy consumption and other declared parameters measured with the same standard must not get worse without the user's explicit prior consent; rejecting an update must not change performance; and no update may make the product non-compliant. This matters for smart bulbs.

Annex III exempts, among others, light sources in battery-operated products (torches, toys with lights, desk lamps working only on batteries, solar garden lights), bicycle lights and electronic displays. 'Battery-operated' means running only on DC from a source inside the same product, without being connected directly or indirectly to the mains. Whether a rechargeable lamp that can run while charging qualifies depends on its design (to be re-checked case by case).

Energy labelling (EU) 2019/2015 and the EPREL database

Also applicable since 1 September 2021 with the rescaled A–G classes, the labelling regulation sits on the framework Regulation (EU) 2017/1369.

Who registers in EPREL? Article 4(1) of Regulation 2017/1369 requires the 'supplier' to enter the Annex I information into the public and compliance parts of the database before placing a unit of a new model on the market. Article 2 defines the supplier as an EU manufacturer, the authorised representative of a non-EU manufacturer, or the importer placing the product on the EU market. A Chinese manufacturer will therefore normally register through its authorised representative or EU importer, and marketplace sellers show the matching label and sheet in the listing. Changes relevant to the label or sheet make it a new model that needs a new entry (Article 4(4)).

Luminaires (containing products) do not carry an energy label themselves, but the light sources in them must comply and be registered. Light sources in battery-only products are exempt (Annex IV point 2(c)).

USB and battery lights: why the GPSR matters more

Sellers often see 5 V USB night lights, battery fairy lights and solar garden lamps as 'no certification needed'. The texts say otherwise:

• They are outside the LVD, and battery-only lights are also outside ecodesign and energy labelling.
• EMC and RoHS (as electrical equipment) still apply, and the battery falls under the Batteries Regulation; see GPSR for battery products.
• Under GPSR Article 2(1), risks not covered by harmonisation legislation, such as overheating, poor insulation, battery fire, optical radiation and children swallowing small parts or button cells, remain under the GPSR Article 5 general safety requirement.

Article 6(1) requires the safety assessment to consider the product's characteristics, its use with other products such as chargers, warnings and instructions, and vulnerable consumers, especially children. A lamp shaped like a toy or food must be assessed for the risk of children playing with it or putting it in their mouth (Article 6(1)(f)); if it is actually designed for play it may be a toy under toy rules, see children's products.

In practice, even where no LVD report is legally required, test against relevant safety standards and keep a risk assessment. That is your evidence if an accident happens or a platform or authority asks. Searching Safety Gate for similar products shows which risks authorities act on.

Labels, listings and documents

GPSR Article 19 requires listings to show the manufacturer's and responsible person's names, postal and electronic addresses, a picture and type, and warnings (for example indoor use only, do not cover, disconnect before changing the bulb). Accidents causing death or serious injury, such as a fire or electric shock, must be notified by the manufacturer through the Safety Business Gateway (Article 20). You can draft label layouts with gpsrtools.com and then check them against the rules; full label rules are in GPSR label requirements.

Keep ready: a DoC covering every applicable act, the technical file (circuit diagrams, risk assessment, list of standards, test reports; 10 years), ecodesign calculations and test results, EPREL registration numbers, RoHS evidence, and WEEE and battery registration numbers.