Lighting

EU Declaration of Conformity for LED Lamps and LED Bulbs: requirements and checklist

By Ing. Jaroslav Křepelka, Owner, DoC solutions s.r.o. · Updated 22 September 2026

Mains-voltage LED lamps (E27, E14, GU10, B22 and similar) are covered by more EU legislation than most suppliers expect: safety and EMC like any electrical product, plus ecodesign rules written specifically for light sources and a mandatory energy label. Smart bulbs with Wi-Fi, Bluetooth or Zigbee move under a different directive altogether.

This page covers retrofit LED lamps and bulbs for general lighting. Luminaires (complete light fittings) follow the same directives but use different safety standards; we point out the difference where it matters.

Checklist: what your led lamp / led bulb declaration must contain

Lamp type or model exactly as printed on the lamp and packaging, listing every wattage, cap and colour-temperature variant covered
Name and postal address of the manufacturer (and of the authorised representative, if appointed)
The statement that the declaration is issued under the sole responsibility of the manufacturer
Low Voltage Directive 2014/35/EU and EMC Directive 2014/30/EU, or the Radio Equipment Directive 2014/53/EU instead for smart bulbs
RoHS Directive 2011/65/EU
Ecodesign: Directive 2009/125/EC and Commission Regulation (EU) 2019/2020 on light sources
The harmonised standards applied, with year and amendments, including photobiological safety
Place and date of issue, name and function of the signatory, and the signature

Which EU legislation applies

Legislation	Applies?	In the DoC?	Notes
Low Voltage Directive2014/35/EU	Applies	In the DoC: Yes	Mains lamps (220–240 V AC) are inside the 50–1000 V AC range. Not cited separately for smart bulbs, where RED covers safety.
EMC Directive2014/30/EU	Applies	In the DoC: Yes	The LED driver inside the lamp: emissions, immunity, harmonic currents and flicker on the mains. Not cited separately for smart bulbs.
Radio Equipment Directive2014/53/EU	Depends on model	In the DoC: Yes	Smart bulbs with Wi-Fi, Bluetooth, Zigbee or Thread. RED then covers safety (Article 3(1)(a)), EMC (Article 3(1)(b)) and use of the radio spectrum (Article 3(2)). Bulbs that communicate over the internet, directly or through a hub or app, must also meet Delegated Regulation (EU) 2022/30 on cybersecurity, applicable since 1 August 2025.
RoHS Directive2011/65/EU	Applies	In the DoC: Yes	Restriction of hazardous substances in electrical and electronic equipment.
Ecodesign for light sourcesDirective 2009/125/EC + Regulation (EU) 2019/2020	Applies	In the DoC: Yes	Applicable since 1 September 2021: minimum energy efficiency, functional requirements (lumen maintenance, colour rendering, flicker and stroboscopic effect, among others) and product information. Adopted under Directive 2009/125/EC. That directive has been replaced by the Ecodesign for Sustainable Products Regulation (EU) 2024/1781, but Article 79(1)(b) of that regulation keeps its CE marking and declaration of conformity provisions in force for products covered by existing implementing measures such as 2019/2020, so the declaration cites both.
Energy labelling of light sourcesDelegated Regulation (EU) 2019/2015	Applies	In the DoC: No	Energy label on the A–G scale on the packaging and in every online listing, and registration in the EU EPREL database before the lamp is placed on the market. Adopted under framework Regulation (EU) 2017/1369. Not part of the declaration of conformity.
WEEE Directive2012/19/EU	Applies	In the DoC: No	Lamps are their own WEEE category. Producer registration in every EU country where you sell and the crossed-out wheeled bin symbol. Not part of the DoC.

Typical harmonised standards

A harmonised standard gives presumption of conformity only in the version cited in the Official Journal of the EU. Always check the current list for each directive before you issue or update a declaration (European Commission: harmonised standards); the versions below are the ones commonly used at the time of writing, and the right selection depends on your product.

Electrical safety (LVD)

For a luminaire, the EN 60598-1 general requirements plus the relevant EN 60598-2 part replace EN 62560.

EN 62560:2012 + A1:2015 + A11:2019Self-ballasted LED lamps for general lighting services by voltage > 50 V — safety specifications
EN 62471:2008Photobiological safety of lamps and lamp systems (blue-light hazard)
EN 62493:2010Assessment of lighting equipment related to human exposure to electromagnetic fields

EMC

Newer editions such as EN IEC 61547:2023 and EN IEC 61000-3-2:2019 exist but, at the time of writing, are not cited in the Official Journal and so do not give presumption of conformity.

EN IEC 55015:2019 + A11:2020Limits and methods of measurement of radio disturbance characteristics of electrical lighting and similar equipment
EN 61547:2009Equipment for general lighting purposes — EMC immunity requirements
EN 61000-3-2:2014Limits for harmonic current emissions
EN 61000-3-3:2013Limitation of voltage changes, voltage fluctuations and flicker in public low-voltage supply systems

Hazardous substances (RoHS)

EN IEC 63000:2018Technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances

Ecodesign measurements

Measurements for Regulation (EU) 2019/2020Luminous flux, efficacy, colour rendering, flicker (Pst LM) and stroboscopic effect (SVM), measured with reliable, state-of-the-art methods. These values are what your ecodesign compliance and energy label rest on

Smart bulbs (RED)

Under RED the lighting safety and EMC standards above are still used, as evidence for Article 3(1)(a) and 3(1)(b). Where a version is shown, it is the one cited under RED in Implementing Decision (EU) 2022/2191 as amended; for the others, use the version listed in the Official Journal.

ETSI EN 300 328 V2.2.2Wideband transmission systems in the 2.4 GHz band (Wi-Fi, Bluetooth, Zigbee)
ETSI EN 301 489-1 and EN 301 489-17 V3.3.1EMC standard for radio equipment — wideband data transmission systems
EN 62311 or EN 62479Human exposure to electromagnetic fields
EN 18031-1:2024Cybersecurity for internet-connected radio equipment (cited in the Official Journal with restrictions)

Already have a declaration for your led lamp / led bulb?

A certification expert checks it against everything on this page and tells you exactly what to fix. Written report in 48 hours, €99 per product (excl. VAT).

Common mistakes in led lamp / led bulb declarations

The Ecodesign Regulation is missing
Regulation (EU) 2019/2020 is the item most often left out of LED lamp declarations. Ecodesign requirements are CE-marking requirements, so the regulation belongs in the DoC next to the LVD, EMC and RoHS Directives.
Repealed lighting regulations are cited
Regulations (EC) No 244/2009, (EC) No 245/2009 and (EU) No 1194/2012 were replaced by Regulation (EU) 2019/2020 from 1 September 2021. A declaration citing them was either never updated or copied from an old template.
The old energy label regulation is cited
Delegated Regulation (EU) No 874/2012 was replaced by (EU) 2019/2015 on 1 September 2021. Energy labelling does not belong in the declaration of conformity anyway: it is a separate obligation, checked through the label and EPREL.
A smart bulb is declared under LVD and EMC
Once a lamp has a radio module, the Radio Equipment Directive applies instead, with its radio standards. Since 1 August 2025 internet-connected bulbs also need to address cybersecurity, typically through EN 18031-1.
Luminaire standards cited for a lamp, or the other way round
EN 62560 covers self-ballasted LED lamps; EN 60598 covers luminaires. Citing the wrong family suggests the product was never assessed against the standard it lists.
Flicker and stroboscopic effect not backed by measurements
Regulation 2019/2020 sets limits for flicker (Pst LM ≤ 1.0) and stroboscopic effect, with the SVM limit tightened from 0.9 to 0.4 on 1 September 2024 (outdoor and industrial light sources excepted). Market surveillance authorities test these values, and the technical file must contain the measured results.
Withdrawn EMC standard versions
EN 55015:2013 was withdrawn from the Official Journal on 4 May 2022 but still appears on many declarations; the current reference is EN IEC 55015:2019 + A11:2020. The presumption of conformity is tied to the version cited.

What you need besides the declaration

EPREL registration and energy label: Register every lamp model in EPREL before placing it on the market, print the energy label on the packaging and show it, with the product information sheet, in every online listing.
Technical documentation with ecodesign data: Test reports for safety, photobiological safety and EMC, RoHS documentation, and the measured and declared ecodesign values (efficacy, lumen maintenance, colour rendering, flicker, stroboscopic effect). Authorities verify declared values against the tolerances in the regulation's verification procedure.
Product information on the packaging: For a lamp sold on its own, Regulation 2019/2020 lists what must be printed on the packaging, including the useful luminous flux, colour temperature, beam angle for directional lamps, cap type and supply voltage, L70B50 lifetime, power, colour rendering index, and a warning if the lamp cannot be dimmed or only with specific dimmers.
Marking and instructions: CE marking, the crossed-out wheeled bin symbol, type designation, manufacturer name and address, and safety and installation information in the language of every EU country where the lamp is sold.
Economic operator in the EU: An importer, authorised representative or responsible person established in the EU (Article 4 of Regulation (EU) 2019/1020), identified on the lamp, its packaging or an accompanying document.
WEEE registration: Producer registration for the lamps category in every EU country where you sell, directly or through a compliance scheme.

No EU presence yet? We can act as your EU authorised representative or responsible person.

Frequently asked questions

Does an LED bulb need an energy label?

Yes. LED light sources carry the A–G energy label under Delegated Regulation (EU) 2019/2015, on the packaging and in online listings, and must be registered in the EPREL database before they are placed on the EU market.

Does the declaration of conformity have to mention Regulation (EU) 2019/2020?

Yes. Ecodesign requirements are part of CE marking, so the ecodesign regulation for light sources belongs in the declaration together with the LVD, EMC and RoHS Directives (or RED for smart bulbs).

Which directive applies to a smart LED bulb, LVD or RED?

RED. A lamp with Wi-Fi, Bluetooth, Zigbee or Thread is radio equipment, and RED covers its electrical safety and EMC as well. Do not cite the LVD and EMC Directives separately; do address cybersecurity if the bulb connects to the internet.

What is the difference between an LED lamp and an LED luminaire for CE purposes?

The directives are the same, but the safety standards differ: EN 62560 for self-ballasted lamps, the EN 60598 series for luminaires. Regulation 2019/2020 also covers the light source inside a luminaire (a "containing product"): the luminaire's manufacturer must make sure it can be removed for verification and must state whether it can be replaced.

What does MyCECheck check on an LED lamp declaration?

Whether the right directives and the ecodesign regulation are cited, whether repealed regulations have been removed, whether the standards and their versions fit a lamp (or a smart bulb), and whether the product identification and EU economic operator are in order. You get a written report within 48 hours.