Compliance Checklist
CE marking for lighting products on Amazon Germany: directives, energy labeling, testing procedures, costs and common mistakes at a glance.
Overview
CE marking is mandatory for all lighting products on Amazon.de – from LED lamps and luminaires to LED strips and smart lighting. It confirms conformity with the Low Voltage Directive (2014/35/EU), the EMC Directive (2014/30/EU) and the Ecodesign Regulation (EU) 2019/2020. Since September 2021, the rescaled EU energy label (A to G) also applies to light sources. Without correct CE marking and energy label, lighting products may not be sold in the EU.
Does this apply to my product?
The CE marking obligation applies to all lighting products sold on Amazon.de: LED lamps (retrofits, GU10, E27, E14), luminaires (ceiling lights, floor lamps, desk lamps, outdoor lights), LED strips and tapes, smart lighting products (WiFi/Zigbee/Bluetooth-enabled light sources), ballasts, drivers and transformers for lighting. Decorative lighting and battery-operated luminaires also fall under this obligation.
Step-by-Step Guide
Determine which EU directives and regulations apply to your lighting product. Light sources and luminaires typically fall under multiple regulations simultaneously.
Estimated time: 1-3 Tage
Low Voltage Directive (LVD) 2014/35/EU checkedRequired
Applies to luminaires and light sources with rated voltage 50-1000V AC or 75-1500V DC. Covers most mains- or transformer-powered lighting products. Low-voltage LED strips (12V/24V DC) are exempt from the LVD but fall under the General Product Safety Regulation.
EMC Directive 2014/30/EU checkedRequired
Applies to all lighting products that can cause electromagnetic interference or be affected by it. LED drivers and electronic ballasts typically generate high-frequency interference that must be tested.
Ecodesign Regulation (EU) 2019/2020 checkedRequired
Since September 2021, new ecodesign requirements apply to light sources and separate control gears. The regulation defines minimum efficiency values, lifetime requirements and mercury limits. Conventional halogen lamps are largely banned.
Radio Equipment Directive RED 2014/53/EU checked (Smart Lighting)
Mandatory for smart lighting products with radio: WiFi, Bluetooth, Zigbee, Z-Wave. For RED-obligated light sources, a Notified Body is often required. Plain LED lamps without radio are exempt from RED.
Specific harmonized standards exist for lighting products. Finding the right standard for your product category is crucial for an efficient testing process.
Estimated time: 1-3 Tage
Applicable harmonized standards identifiedRequired
Key standards for lighting: EN 60598 (luminaires – safety), EN 62560 (self-ballasted LED lamps – safety), EN 62471 (photobiological safety of lamps and lamp systems), EN 61347 (LED drivers/control gear), EN 55015 (EMC emission), EN 61547 (EMC immunity).
Accredited test laboratory selectedRequired
Choose an ISO 17025 accredited test laboratory experienced with lighting products. In Germany: TÜV, DEKRA, VDE Testing and Certification Institute. Specialized lighting labs often offer more affordable packages for standard products.
Your lighting product is tested against the harmonized standards. Besides electrical safety and EMC, photobiological safety is particularly important for light sources.
Estimated time: 2-6 Wochen
Safety tests per EN 60598 / EN 62560 passedRequired
Tests include: insulation resistance, creepage and clearance distances, temperature rise (particularly critical for LED luminaires due to thermal management), protection against electric shock, IP rating (especially for outdoor luminaires), fire protection requirements for materials.
EMC tests passed (EN 55015 + EN 61547)Required
Lighting-specific EMC tests: EN 55015 for conducted and radiated emissions, EN 61547 for immunity, EN 61000-3-2 for harmonic currents (flicker), EN 61000-3-3 for voltage fluctuations. LED drivers are frequent problem sources.
Photobiological safety per EN 62471 assessedRequired
Evaluates the risk of UV radiation, blue light hazard and infrared radiation. LED products must be classified into risk groups (RG0 to RG3). For the consumer market, only RG0 (no risk) and RG1 (low risk) are permissible.
Since September 2021, light sources must carry the rescaled EU energy label (A to G). Additionally, a product datasheet must be registered in the EU product database EPREL.
Estimated time: 2-5 Tage
Energy efficiency class calculated and label createdRequired
The energy efficiency class is calculated according to Delegated Regulation (EU) 2019/2015. The basis is the Energy Efficiency Index (EEI). The rescaled label ranges from A (most efficient) to G. Most LED lamps currently fall into class D to F – class A is deliberately kept free for future technologies.
Product datasheet registered in EPRELRequired
Before placing on the market, the product datasheet must be registered in the European Product Registry for Energy Labelling (EPREL). The QR code generated there must be printed on the energy label.
Create the complete technical documentation and the EU Declaration of Conformity. Affix the CE marking correctly on the product.
Estimated time: 2-5 Tage
Technical documentation compiledRequired
Content: product description with technical data (lumen, color temperature, CRI, lifetime), circuit diagrams/construction drawings, applied standards and directives, all test reports, risk assessment, energy label calculations, EPREL registration, photos of labeling, user manual in German language.
EU Declaration of Conformity (DoC) prepared and signedRequired
The DoC must contain: manufacturer/importer data, product identification, all applied directives (LVD, EMC, Ecodesign, RED if applicable) and standards, date and signature. For lighting typically: LVD + EMC + Ecodesign + RoHS.
CE marking correctly affixed on product and packagingRequired
The CE mark must be visibly, legibly and permanently affixed on the luminaire or light source. Minimum height 5mm. For small light sources (e.g. GU10), affixing on the packaging is permissible if the product is too small. Additionally, manufacturer name and type designation must be indicated.
In addition to CE marking on the product, you must provide the energy label and additional compliance data for the Amazon.de marketplace.
Estimated time: 2-4 Tage
Energy label provided in Amazon listingRequired
Amazon.de requires the EU energy label as an image in the listing. The energy efficiency class must be specified in the product attributes. The EPREL link/QR code must be accessible. Amazon may suppress the listing if the energy label is missing.
GPSR mandatory fields in Amazon Seller Central completedRequired
Since December 2024, Amazon requires the specification of the Responsible Person in the EU, manufacturer data and contact information according to the General Product Safety Regulation (GPSR).
Compliance documents uploaded for AmazonRequired
Upload the DoC, test reports and energy label to Seller Central. Amazon may request these during compliance checks. Keep documents up to date at all times – especially after product changes or new standard versions.
Common Mistakes to Avoid
Using old energy label (A++ to E) instead of rescaled label (A to G)
Consequence: Since September 2021, only the rescaled labels (A-G) are valid. Products with old labels violate Regulation (EU) 2019/2015. Amazon can suppress listings, market surveillance can impose fines.
Prevention: Calculate the energy efficiency class according to current Regulation (EU) 2019/2015 and register the product in EPREL. Update all listings and packaging.
Photobiological safety (EN 62471) not assessed
Consequence: Missing assessment of blue light hazard. LED products with high blue light component can cause eye damage. Market surveillance can withdraw the product from the market.
Prevention: Have photobiological safety tested per EN 62471. Ensure consumer products reach risk group RG1 at most. Document the risk group in the technical documentation.
EPREL registration forgotten or QR code missing on energy label
Consequence: Without EPREL registration, the light source may not be sold in the EU. The energy label without QR code is invalid. Market surveillance can impose sales bans.
Prevention: Register the product in EPREL before placing on the market (eprel.ec.europa.eu). Print the generated QR code on the energy label. Keep EPREL data up to date.
CE mark adopted from supplier without own verification
Consequence: As an importer, YOU are responsible. Chinese test reports for lighting are often incomplete or do not correspond to current standard versions. Fines up to 100,000 EUR may be imposed during inspections.
Prevention: Request the complete technical documentation and verify that the correct standard versions were applied. Have critical tests (especially EMC and photobiological safety) repeated in an EU-accredited laboratory.
IP rating for outdoor luminaires not correctly specified or tested
Consequence: Outdoor luminaires without sufficient IP rating (at least IP44 for splash-protected areas, IP65 for direct weather exposure) can lead to short circuits and safety risks. Product liability and recall are possible.
Prevention: Determine the required IP rating based on the intended location of use. Have the IP test performed in an accredited laboratory and specify the IP class correctly in the listing.
Frequently Asked Questions
Yes, LED strips need a CE mark (EMC Directive, LVD if applicable). Whether an energy label is required depends on whether the LED strip qualifies as a 'light source' under Regulation (EU) 2019/2020. LED strips marketed as lighting generally require an energy label. Purely decorative LED strips (e.g. RGB strips without white light) may be exempt – verify the exact product classification.
Most commercially available LED lamps fall into classes D to F under the rescaled label. Highly efficient LED lamps achieve class C or rarely B. Class A is deliberately kept free and currently not achievable by any product. Don't be concerned: class D-E is currently normal for LED lamps and not a competitive disadvantage.
For a simple LED ceiling light without radio, expect approx. 2,500-5,000 EUR for the complete conformity assessment: safety test (EN 60598), EMC test (EN 55015/EN 61547), photobiological assessment (EN 62471), energy label calculation and technical documentation. For smart luminaires with Bluetooth or WiFi, RED tests are added and costs increase to 5,000-10,000 EUR.
Yes, photobiological safety assessment per EN 62471 is required for all LED products. The risk group must be stated in the technical documentation and, if applicable, on the product. For the consumer market on Amazon.de, only products of risk group RG0 (no risk) and RG1 (low risk) are permissible. RG2 and RG3 are only allowed for professional applications.
Not without your own conformity assessment. As an importer, you are responsible for CE conformity under EU law. Check the supplied test reports for completeness and whether current standard versions were applied. Have critical tests repeated in an EU laboratory. Create the EU energy label with EPREL registration and ensure a Responsible Person in the EU is designated (GPSR).