LED Product Compliance – Case Study

In reality, many Chinese manufacturers claim to comply with EU (CE marking) and American (FCC and UL) safety directives and regulations. But does that really mean that they can have all or part of the compliance documentation of all, or at least some of their products? Well, we decided to find out. In this article, we provide you with reliable news related to product compliance in the LED industry through a case study

Safety regulations for LED lighting and necessary documentation

It is a common misconception that it is the responsibility of the manufacturer to ensure compliance, or that the importer should only have a product certificate, a test report, or a declaration of conformity. This, however, is not the case. Firstly, as you should already know, it is the importer, not the manufacturer, who is responsible for ensuring compliance. Second, as part of this responsibility, the importer must prepare all relevant documents.

The documents to be produced

In theory, the Chinese manufacturer should be able to produce these documents. Take, for example, the CE technical file which must include the following documents:

• Declaration of conformity
• Test reports
• Circuit Prospectus
• Bill of Materials / Parts List
• Risk analysis
• Summaries of Regulations and Directives
• Labels
• User Manual

As mentioned above, many importers assume that they are in compliance as long as the supplier can produce a declaration of conformity and that the products are labelled with the CE marking. As mentioned above, this is completely wrong. The full set of compliance documents is mandatory, so how many suppliers can actually produce this full set of documents, rather than just the Declaration of Conformity (DoC)?

Our findings in the LED industry

In order not to distort the result, we have chosen only those relatively large LED manufacturers, located in the delta of the Pearl River. Some of them have established themselves with decades of experience in the production of LED lighting in the European Union, the United States and other markets. Therefore, we believe that our results are representative of this industry as a whole.

At first, we listed the ODM SKUs directly from each vendor’s catalog. Next, we created a list of all the necessary documentation, which must be produced by the supplier, to ensure compliance, in this specific case, with the directives in force in the European Union. In the tables below you will find the result obtained by two of the suppliers who participated.

Supplier A

Supplier B

Our research involved a total of eight LED manufacturers and more than 15 SKUs for each of them. However, the data in the table above represents the result as a whole. Before proceeding, I will try to summarize the problems we have identified:

1. Manufacturers can only produce products that are partially compliant. They cannot produce a complete set of documents for a single SKU.
2. Many products do not have compliance documents at all, including test reports.
3. While manufacturers certainly own the circuit drawings and component list, they hesitate to share those documents, even if the buyer is required to access them.

What is very clear after this research is that very few, if any, LED manufacturers are able to produce a complete set of compliance documents. At first glance, this might seem strange, considering that these manufacturers have been exporting their goods to these markets for years. Evidently, they have the technical expertise to make products that comply with EU and US regulations.

Our Conclusion

What becomes very clear after this research is that very few, if any, LED manufacturers are able to produce a complete set of compliance documents. At first glance, this might seem strange, considering that these manufacturers have been exporting their goods to these markets for years. Evidently, they have the technical expertise to make products that comply with EU and US regulations.

Although current regulations are based on the assumption that the manufacturer delivers all required compliance documents to the importer (such as, for example, in the case of trade within the European Union), clearly this strategy does not work when importing from China and, possibly, from other developing Asian countries.

The importer

On the contrary, the importer can no longer assume the role of the trader. The primary responsibility for ensuring compliance lies with the importer, whose role today is greater than that of a product developer or engineer.

The supplier, on the other hand, is only there to procure the resources for the importer. One of these assets is the supplier’s ability, in terms of technical expertise, to produce products that comply with all applicable regulations in the buyer’s market. However, the importer still needs to manage all aspects related to product compliance, beyond the procurement of components and their assembly.

The results of this case study

Remember that the results of this study would have been much worse if we hadn’t already been aware that these manufacturers are among the best suppliers of LEDs in China. Yet, only a minority of them are at this level. So, how can a supplier’s ability to ensure compliance be assessed? There is no such thing as a foolproof method. Nevertheless, what we really do is look for antecedent conformity. In other words, we evaluate the supplier’s existing compliance documents related to the supplier’s product, to get an idea of whether or not the supplier has the technical expertise to make compliant products. That’s it, but existing test reports or the Declaration of Conformity (DoC) are not a substitute for the need to carry out testing and other procedures.

This conclusion is not only relevant to LED lighting importers. On the contrary, it applies to almost all products on the market, including electronics, toys and industrial products.

The stakes are, to say the least, high. As some of you may know, authorities in the European Union and the United States have stepped up compliance with regulations after receiving numerous reports of dangerous hoverboards, most of which are assembled in Shenzhen. Amazon.com immediately followed suit and asked all Hoverboard sellers to produce the various compliance documents. Those who failed to do so, and it could be most sellers, were suspended from sales.

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