Analysis of the Differences in LED Market Access Requirements in North America and Europe

LED products, as a new generation of green lighting, are gradually rising to global applications. At the same time, with the recovery of the global economic situation and the development of China's LED industry, the scale of China's semiconductor lighting industry continues to grow, with LED general lighting still being the main driving force for market development. China's LED lighting product exports are blooming in overseas markets, and the export regional structure is becoming more balanced. Among them, the North American and European Union markets have become the two major regions for China's LED product exports. However, the regulatory requirements for LED lighting products in these two regions differ to varying degrees. How to comply with the regulatory requirements and market demands of both regions has always been a focus for Chinese manufacturers.
　　  1. Entry requirements for the United States and Canada  
　　LED lighting products exported to the North American market must also comply with the electrical safety, electromagnetic compatibility, energy efficiency, and chemical testing requirements of U.S. regulations; however, these requirements differ to varying degrees from EU directive requirements:
　　a. Electrical safety testing
　　The Occupational Safety and Health Administration (OSHA) under the U.S. Department of Labor requires that products used in the workplace must be tested and certified by a Nationally Recognized Testing Laboratory (NRTL) to ensure user safety. Therefore, most electrical products entering the U.S. market must comply with the NRTL mark, and OSHA has authorized international certification organizations as NRTL certification bodies to test and certify according to applicable product standards. For the Canadian market, electrical products sold or imported into Canada must be verified, and testing must be completed by laboratories recognized by the Standards Council of Canada (SCC).
  The standards for lighting fixtures in North America differ significantly from the EU IEC, and North American electrical safety testing does not require consideration of EMF requirements. The standards for North American lighting fixtures are usually determined based on installation applications and usage locations.

　　For example: The applicable standards for fixed installation ceiling lights, recessed ceiling lights, etc., are ANSI/UL 1598 and CAN/CSA C22.2 No.250.0. If these fixtures use LED light sources, additional consideration must be given to ANSI/UL 8750 and CSA C22.2 No.250.13 during certification. If LED fixtures use built-in electronic power supplies, in addition to passing the fixture series standard tests, their built-in electronic power supply circuits must also comply with UL1310 or UL60950-1 requirements.
　　b. Energy efficiency testing
　　Certain regions in the U.S. provide varying degrees of financial subsidies for lighting products that obtain ENERGY STAR or DLC certification. Currently, energy efficiency testing for LED bulbs and fixtures in the U.S. mainly focuses on ENERGY STAR and DLC, Lighting Facts labels, which are all voluntary requirements. The U.S. federal low energy efficiency requirements (DOE) have not yet included LED bulbs and LED fixtures in the control scope. However, in California, portable LED fixtures must meet specific energy consumption requirements.
　　1). ENERGYSTAR energy efficiency certification
　　The ENERGY STAR label is created by the U.S. Environmental Protection Agency (EPA) and the Department of Energy (DOE) to ensure that the listed products meet energy efficiency regulatory requirements, but it is a voluntary testing certification. Currently, for LED bulb products, both ENERGY STAR Lamps program V1.1 and the new version V2.0 can be adopted, but starting January 2, 2017, Lamps program V2.0 must be used. For LED fixture products, the ENERGY STAR testing requirement version Luminaire program V2.0 officially took effect on June 1, 2016. The applicable LED bulbs mainly include three types: omnidirectional bulbs, directional bulbs, and non-standard bulbs. ENERGY STAR has strict requirements for the relevant photometric parameters, flicker, lumen maintenance, and lifespan of LED bulbs, with testing methods referencing LM-79 and LM-80 standards. In the new ENERGY STAR rules for bulbs Lamp V2.0, the light efficiency requirements for bulbs have been significantly increased, broadening the product performance and range, and adding classification levels for energy efficiency and performance. The EPA will continue to focus on power factor, dimming, flicker, accelerated aging programs, and connected products.
　　2). Lighting Facts Label energy efficiency certification
　　It is a voluntary energy efficiency labeling program announced by the U.S. Department of Energy (DOE), currently only for LED fixture products. Its original intention is "Give them the Facts," aimed at making lighting products meet more specific and credible data requirements, disclosing the true performance parameters of the product in five aspects: lumens lm, initial luminous efficacy lm/W, input power W, correlated color temperature CCT, and color rendering index CRI. The range of applicable LED fixture products includes: complete fixtures powered by AC mains or DC, low-voltage 12V AC or DC fixtures, separable power supply LED fixtures, linear or modular products.
　　3). DLC energy efficiency certification
　　DLC stands for "The Design Lights Consortium." It is a voluntary energy efficiency certification program initiated by the Northeast Energy Efficiency Partnerships (NEEP) in the U.S. The DLC certification product catalog is used to promote high-performance LED fixtures that are not covered by the ENERGY STAR standard across the U.S. The current DLC technical requirements table is the new V4.0 version, which has been in effect since September 1, 2016. It mainly focuses on outdoor commercial and industrial building LED fixtures, such as outdoor wall lights, garage lights, industrial lights, outdoor LED fixtures, and LED tubes. Its main performance requirements for products include: total luminous flux, ring luminous flux, luminous efficacy, color temperature, color rendering index, lumen maintenance rate, power factor, and harmonic distortion. DLC certification requires that products must be tested by a third-party laboratory accredited by NVLAP and provide a report.
　　4). FTC energy efficiency label
　　According to the requirements of the U.S. Federal Trade Commission (FTC) regulations, LED lights entering the U.S. market for sale must have energy labels affixed to the packaging and the lamp body, disclosing information such as the product's annual energy consumption and lifespan. The FTC energy efficiency label is similar to the aforementioned Lighting Facts Label, but the FTC energy efficiency label is mandatory. For details, see FTC energy guide label requirements regulations: 16 CFR 305.
    5). California energy efficiency requirements
　　To improve the efficiency of electrical products, the California Energy Commission implemented the Appliance Efficiency Regulation on December 30, 2005. A total of over twenty categories of products must comply with energy efficiency and usage efficiency regulatory requirements to enter California. The new requirements are the CEC regulations promulgated in October 2015. For lighting products, portable LED fixtures must meet CEC energy efficiency requirements to be sold in California, and testing must be completed in CEC-recognized laboratories.
　　6). Canadian energy efficiency testing requirements
　　For lighting products, Canada currently has mandatory energy efficiency requirements under NRCan that have regulated general fluorescent lamps, general incandescent reflector lamps, and general lighting products, but there are currently no mandatory energy efficiency requirements for LED light source fixtures.
　　c. FCC/ICES testing requirements
　　FCC is a mandatory certification for the electromagnetic interference (EMI) characteristic limits of telecommunication products as stipulated by U.S. federal law, but it does not include the testing requirements for electromagnetic susceptibility (EMS); the FCC certification testing for LED lighting differs significantly from the electromagnetic compatibility (EMC) certification testing in the EU CE.
　　The methods of FCC certification are divided into three modes: Verification (self-certification), Declaration of Conformity (public declaration), and Certification. The choice of certification method depends on the type of product, such as the FCC testing standard for LED panel light products being FCC 47 CFR part 15B, with the certification type being: Verification. It is important to note that the FCC certification for LED lighting is divided into Class A (LED lighting used in industrial and commercial environments) and Class B (LED lighting used in residential environments), with completely different testing limits for the two classes. The standard for radio interference testing limits in CE certification has only one type, which is similar to the Class B limits in FCC, with an additional 9k-30MHz electromagnetic field radiation test.
　　Canada has also established mandatory electromagnetic compatibility requirements for electrical products, referred to as ICES, which is a mandatory certification from Industry Canada. The standard for LED lighting products is ICES-005, which is basically consistent with FCC part 15B, but the radiation testing is extended to 1000MHz. As of December 1, 2016, ICES-005 Issue 4 is officially implemented, and Canada no longer accepts ICES 005.
　　  2、EU Regulations  
　　In Europe, due to the policy prohibiting the sale of incandescent lamps, the demand for LED lighting fixtures is expected to gradually increase. In addition, the demand for LED lighting fixtures in various fields, including automotive, outdoor, and decorative applications, as well as indoor usage, will also surge, making compliance with EU regulatory entry requirements a challenge for Chinese manufacturers.
　　According to the European Commission directive, lighting fixtures and similar products sold in Europe must affix a CE certification label. Therefore, products must bear the CE mark and must comply with the following directive requirements for electrical safety, EMC, chemical substances, energy consumption, and energy efficiency labeling for lighting products:

　　a. Electrical safety testing

　　The Low Voltage Directive (LVD) establishes overall safety requirements for all low voltage products entering the EU. Semiconductor lighting products fall under the defined low voltage products and must therefore comply with the specifications of the Low Voltage Directive. Different LED lighting products correspond to different testing standards, as shown in the table below:

　　b. Electromagnetic Compatibility Testing
　　According to the requirements of the EU 2014/30/EU directive, battery compatibility testing includes two aspects: electromagnetic interference (EMI) and electromagnetic susceptibility (EMS). The former mainly manifests as conducted interference and radiated interference, while the latter mainly considers the product's tolerance to static discharge, radiation, pulse groups, surges, and conducted interference, i.e., anti-interference testing. The main testing standards are: EN55015; EN61547; and EN61000-3-2 power harmonic requirements, EN61000-3-3 power flicker requirements.
　　c. ERP Directive
　　For LED lighting products, the ERP directive stipulates that LED lamps and control devices must meet the following requirements:
 　　♦ Energy consumption requirements: high energy efficiency index EEI for lighting fixtures; no-load power, standby power, and load efficiency for control devices;
　　 ♦ Functional testing requirements for LED lamps: 6000h survival rate and lumen maintenance rate; number of switch cycles before failure; start-up time; 95% lumen rise time; early failure rate; color rendering index; color tolerance (requirements for color consistency); power factor PF. However, currently, the EU ERP does not impose requirements on LED flicker;
 　　♦ Product information labeling and energy efficiency labeling requirements: indicating luminous flux, nominal life, color temperature, etc. For detailed requirements and limits, please refer to the implementing rules (EUNO.1194/2012; NO.874/2012);
 　　♦ LED lighting products that meet the above electrical safety, EMC, ERP, chemical RoHS, REACH, and electronic waste recycling directive requirements can affix the CE mark. Additionally, LED bulbs and fixtures must also affix energy efficiency labels according to the measured energy consumption data.
　　  3、Conclusion  
　　In LED product testing, in addition to common mandatory requirements such as electrical, energy efficiency, and electromagnetic compatibility testing, both the EU and North American markets are seeing an increasing number of buyers valuing voluntary certification certificates and performance testing for LED lighting products, such as the GS certificate recognized in the European market, the U.S. DLC (Design Lights Consortium), and Lighting Facts testing certification listings. Furthermore, certain special optical characteristics of LED products are increasingly valued by buyers, such as flicker verification, spectral measurement, color consistency, color rendering index (CRI), LED aging tests, energy conversion efficiency, total luminous flux, and visual angle range performance requirements. Therefore, in the face of an increasingly competitive European and American market, in addition to meeting mandatory certification tests, additional performance often makes products stand out among many similar products.