Product Compliance in the LED Industry: A Case Study

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Indeed, many Chinese manufacturers claim compliance with the relevant European Union (CE Mark) and American (FCC and UL) directives and safety standards. But does this really mean that they can maintain the full set of compliance documents for all, or least part, of their products? Well, we decided to find out. In this article, we offer insider insights into the actual state of EU and US product compliance among LED manufacturers.

LED Lighting Safety Standards & Required Documentation

As explained in this article, it’s a common misconception that it’s either the manufacturer’s responsibility to ensure compliance or that the importer must only obtain a product certificate, test report or declaration of conformity. That is, however, not the case. First, as you may already be aware of, the importer is responsible for ensuring compliance – not the manufacturer. Second, as part of this responsibility, the importer must prepare all relevant documents.
In theory, the Chinese manufacturer should be able to produce these documents. Take the CE Technical File for example, which must include the following documents:

• Declaration of Conformity
• Test Reports
• Circuit Drawings
• Bill of Materials / Component List
• Risk Analysis
• Summary of Standards & Directives
• Labels
• User Guide

As mentioned, many importers make the assumption that they’re set as long as the supplier can produce a Declaration of Conformity, and the products are labelled with the CE mark. As said, this is entirely incorrect. A full set of compliance documents is mandatory. Now, how many suppliers can actually provide the full set of documents, rather than just the DoC?

Our Findings in the LED Industry

In order to not distort the result, we only picked relatively large LED manufacturers in the Pearl river delta. Some of which are established for over a decade’s experience in manufacturing LED lighting for the EU, US and other markets. Hence, we do believe that our results are representative for the industry as a whole.

At first, we listed ODM SKUs directly from each supplier’s catalog. Next, we made a list of all the required documentation, which must be provided by the supplier in order to ensure compliance with, in this specific case, the applicable EU directives. The result, for two of the suppliers that participated, follows in the tables below.

Supplier A

SKU	DoC	Test Report/s	Support Documents
RX2-E27	EMC:YesLVD:YesRoHS:No	EMC:YesLVD:YesRoHS:No	Circuit Drawings: None Bill of Materials / Component List: None Risk Analysis: None Labels: None User Guide: None
RX5- E27	EMC:No LVD:No RoHS:No	EMC:No LVD:YesRoHS:No	Circuit Drawings: None Bill of Materials / Component List: None Risk Analysis: None Labels: None User Guide: None
GX1- GU10	EMC:YesLVD:YesRoHS:Yes	EMC:YesLVD:YesRoHS:Yes	Circuit Drawings: YesBill of Materials / Component List:YesRisk Analysis: None Labels: None User Guide: None
SD1 – E14	EMC: No LVD: No RoHS: No	EMC: No LVD: No RoHS: No	Circuit Drawings: None Bill of Materials / Component List:YesRisk Analysis: None Labels: None User Guide: None
SD2 – E14	EMC: YesLVD: No RoHS: No	EMC: YesLVD: No RoHS: No	Circuit Drawings: None Bill of Materials / Component List: None Risk Analysis: None Labels: None User Guide: None

Supplier B

SKU	DoC	Test Report/s	Support Documents
XGB1	EMC:No LVD:No RoHS:No	EMC:No LVD:No RoHS:Yes	Circuit Drawings: None Bill of Materials / Component List: None Risk Analysis: None Labels: None User Guide: None
A37 4W	EMC:No LVD:No RoHS:No	EMC:No LVD:No RoHS:No	Circuit Drawings: None Bill of Materials / Component List: None Risk Analysis: None Labels: None User Guide: None
A38 4.5W	EMC:No LVD:No RoHS:No	EMC:No LVD:No RoHS:No	Circuit Drawings: None Bill of Materials / Component List: None Risk Analysis: None Labels: None User Guide: None
A38 7W	EMC:YesLVD:YesRoHS:No	EMC:YesLVD:YesRoHS:Yes	Circuit Drawings: None Bill of Materials / Component List: None Risk Analysis: None Labels: None User Guide: None
GU10 4.5W	EMC:No LVD:No RoHS:No	EMC:No LVD:No RoHS:No	Circuit Drawings: None Bill of Materials / Component List: YesRisk Analysis: None Labels: None User Guide: None

Our research included in total eight LED manufacturers, and more than 15 SKUs each. However, the table data above is representative of the result as a whole. Before we move, I’ll summarise the issues we’ve now identified:

1. The manufacturers can only provide products that are partially compliant. They cannot provide a full set of documents for a single SKU.
2. Many products have no compliance documents, including test reports, at all.
3. While the manufacturers surely do possess Circuit Drawings and Component Lists, they hesitate to share such documents – even if the buyer is required to access them.

What is very clear after this research is that very few, if any LED manufacturer, can provide a full set of compliance documents. That may at first seem strange, considering that these manufacturers have exported to said markets for years. Indeed, they evidently possess the technical expertise to manufacture products in compliance with EU and US regulations.

Our Conclusion

What is very clear after this research is that very few, if any LED manufacturer, can provide a full set of ‘ready made’ compliance documents. That may at first seem strange, considering that these manufacturers have exported to said markets for years. Indeed, they evidently possess the technical expertise to manufacture products in compliance with EU and US regulations.
While existing regulations are based on the assumption that the manufacturer provide the importer with all required compliance documents (which is the case in domestic trade within the EU, for example), this strategy clearly doesn’t work when importing from China, and possibly other developing Asian countries.

Instead, the importer can no longer assume the role of trader. The main responsibility of ensuring compliance, falls in practice entirely on the importer. Hence, the role of the importer today is more of the role of a product developer and engineer.

The supplier, on the other hand, is only there to provide the resources for the importer. One such resource is the supplier’s ability, in terms of technical expertise, to manufacture product in compliance with all applicable regulations, in the buyer’s market. However, the importer must still manage all aspects of product compliance, outside of component procurement and assembly.
Now, keep in mind that the results of this study would have been far worse wouldn’t we already know that these manufacturers are among the top LED suppliers in China. Only a minority of the suppliers are on this level. So, how can a supplier’s ability to ensure compliance be assessed? There may not be a failsafe method. But, what we do look for is previous compliance. In other words, we assess the supplier’s existing product compliance documents to get an idea of whether or not they have the technical expertise to manufacture compliant goods. That is about as safe as it gets. But, an existing test reports or DoC does not substitute the need for testing, and other procedures.

This conclusion is not only relevant to LED lighting importers. Instead, this applies to virtually all businesses, including electronics, toys and industrial products.

The stakes are high, to say the least. As some of you may know, authorities in the European Union and the United States stepped up enforcement after multiple reports of hazardous Balance Scooters, most of which are assembled in Shenzhen. Amazon.com quickly followed suit, and required all sellers of Balance scooters (or Hoverboards) to provide various compliance documents. Those who failed to so, which may well have been the majority of the sellers, were suspended from trading.

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