Decorative Lighting Certification Guide: UL, ETL, CE, RoHS, and Compliance Requirements

Decorative lighting products imported to other countries and regions must meet the requirements for safety, environmental protection and market access. Lack of certification preparation may cause delays in customs clearance, delay project approval, delay acceptance of installations, and delay sales.

This article from Postmodernlighting will take you through the most common certifications and compliance standards in the decorative lighting industry, such as UL, ETL, CE and RoHS. It also covers the differences between these requirements and their target markets, the most common misconceptions and key procurement review points, and it will help you choose the appropriate certification strategy for your target market, while minimizing export and project risks.

1. Why Decorative Lighting Certification Matters

There are different markets with varying compliance requirements for decorative lighting products. The selection of certification must be decided according to the product type, installation environment and target sales area. It is important to understand how compliance influences direct impacts on product safety, market access and project acceptance prior to selection of a certification.

Lighting Certification Testing

1) Certification Improves Product Safety and Reduces Operational Risk

Decorative lighting is an electrical product and it’s safety is dependent on not only the design, but also the adherence to applicable safety standards. The UL and ETL testing ensure the products are electrically safe, insulated, resistant to overheating, well grounded and structurally sound to reduce the risk of electric shock, overheating and fire.

In general, the products certified will be of higher quality and have less maintenance risk in their useful life for long-term applications such as a hotel or commercial building.

2) Certification Affects Market Access, Customs Clearance, and Project Acceptance

There are country and region-specific regulatory requirements. For example, projects in the USA may have to be UL or ETL certified while products for the European Union will be CE marked and comply with other rules such as RoHS. A product that does not meet the certification requirements for the target market may be rejected for project procurement, delayed at customs or not accepted at the end of project.

2. What Are the Most Common Certifications for Decorative Lighting?

The certifications are for different markets and regulatory structures. There is no global certification.

Common Decorative Lighting Certifications

1) UL Certification

UL (Underwriters Laboratories) is a leading product safety certification in the United States. It mainly assesses electrical safety and fire safety. In the U.S., many commercial buildings, hotels, hospitals and other public infrastructure projects prefer UL certified products.

2) ETL Certification

ETL is issued by Intertek and is also a recognized North American safety certification. As long as a product complies with the same ANSI/UL standards, ETL has the same legal recognition as UL and is accepted in both the United States and Canada.

3) CE Marking

CE is not a certification given by a particular organisation. It is actually a conformity mark to let consumers know that a product meets relevant EU requirements, rather. The most common CE Directive requirements for decorative lighting products are those of the Low Voltage Directive (LVD) and the Electromagnetic Compatibility Directive (EMC). One of the key requirements to market a product in the EU is CE marking.

4) RoHS Compliance

RoHS reduces and eliminates the use of hazardous substances, such as lead (Pb), mercury (Hg) and cadmium (Cd), in electrical and electronic products. Today, there is an EU RoHS Directive in force that restricts the use of 10 hazardous substances. These are limits that must be met for components like PCBs, power supplies, cables and solder found in lighting fixtures.
It is important to note that RoHS is an environmental regulation and cannot replace product safety certifications.

5) Certification Overview (Comparison Table)

Note: CE marking does not automatically mean that products can be sold all over the world – some buyers think so. In reality, U.S. engineering projects typically still require UL or ETL certification. Similarly, UL certification will not supersede CE marking or RoHS compliance.

UL/ETL/CE/RoHS Certified

3. UL Certification: Which Decorative Lighting Products Require UL Certification?

To determine whether or not the lighting fixture in question needs to be UL approved, it is important to understand what UL evaluates and how UL requirement apply to the decorative lighting product.

1) What Does UL Certification Cover?

Underwriters Laboratories (UL) is one of the earliest product safety testing companies in the United States of America. Its main purpose is to ensure that a product is safe when used as intended and in a manner reasonably likely to be encountered by the user.

UL certification generally tests the following for decorative lighting products:

a) Electrical safety: Electrical shock protection, Dielectric strength, temperature rise and heat dissipation, grounding continuity, conductor and terminal safety, driver reliability, material flame resistance.
b) Mechanical safety test: A chandelier is put through a 4 times its weight load test for 1 hour and continuous, and its tensile strength, strain relief and outdoor fixtures moisture/water resistance are also tested.
c) Labeling and production consistency: Permanent product labels should contain model number, voltage and environmental rating (Damp Location / Dry Location).

UL Label

2) Which Decorative Lighting Products Typically Require UL Certification?

It is largely dependent on the market and project specification if UL certification is required. But, in general, decorative lighting products generally need to comply with UL standards, including:

Common decorative lighting products like pendant, wall, ceiling, floor and table lighting and lamps generally need UL certification in the United States. In the U.S., the standard for most engineering projects such as hotels, commercial buildings, office buildings, chain retail stores, and other projects is to have lighting fixtures that are UL or ETL certified. A seemingly functional product may not be approved for a project or accepted on site because the supplier does not have the necessary certification.

Common Misconception: If the driver and/or wires are UL certified, then the entire fixture is UL certified. These are two different concepts. Individual components that are UL certified do not necessarily result in the luminaire being UL certified. In general, when a project calls for UL Listed or UL Certified products, the fixture as a whole is required to undergo the necessary testing and certification, not just the component parts that are listed or certified by UL.

4. ETL Certification: How Does It Differ from UL?

ETL and UL are issued by different certification bodies and both are based on the same ANSI/UL safety standards. They are compared in the following sections with respect to scope of testing, market acceptance and typical applications.

ETL Label

1) What Does ETL Certification Cover?

ETL (Electrical Testing Laboratories), issued by Intertek is one of the NRTLs (Nationally recognized Testing Laboratories) recognized by OSHA in the United States. ETL testing is conducted based on the ANSI/UL test standard, not on a different safety standard, and for decorative lighting products. The scope of testing is basically the same as UL.

Technically speaking, both ETL and UL determine if a product meets U.S. electrical safety standards.

2) Does ETL Have the Same Market Acceptance as UL?

If a product is UL or ETL certified, it is legally recognized in the United States as long as it has been tested and certified to the same ANSI/UL standards by an OSHA recognized NRTL. ETL products are accepted by most building inspectors, commercial projects and insurance companies the same as UL products. The primary difference lies in the certification organization rather than the technical requirements.

3) When Should You Choose ETL Certification?

For decorative lighting products exported to the United States, ETL is often a practical and widely accepted choice if the customer does not specifically require UL certification. Many lighting manufacturers choose ETL for the following reasons:

• Certification lead times are generally shorter, helping accelerate new product launches.
• Communication is typically more efficient, and the certification process is relatively flexible.
• In some projects, ETL offers a more cost-effective certification process, with lower costs for future certificate updates.
• ETL fully satisfies the safety requirements of both the U.S. and Canadian markets.

It should be noted that some high-end municipal projects and certain long-established U.S. hotel brands explicitly specify “UL Only” in their procurement documents. In such cases, you should follow the project requirements.

5. CE Marking: Which Decorative Lighting Products Require CE Marking?

The compliance framework for decorative lighting in the European Union differs from that of the United States. CE marking is one of the core requirements for market access in the EU. The following sections explain the applicable regulations and the types of products that require CE marking.

CE Label

1) What Does CE Marking Cover?

Unlike UL and ETL, CE is not an independent certification. It is a conformity marking indicating that a product complies with applicable European Union regulations. The following legislation usually applies to decorative lighting products for CE compliance:

• LVD (Low Voltage Directive): guarantees electrical safety.
• EMC (Electromagnetic Compatibility Directive): The product is neither a source of nor is it affected by the EMI (Electromagnetic Interference) that is too high.
• RoHS Directive: A restriction on the use of harmful substances (usually in conjunction with CE compliance).

Additional requirements may apply depending on the product: ErP Directive for LED decorative lighting. RED (Radio Equipment Directive) for smart decorative lighting with wireless technologies such as Bluetooth.

Once the necessary tests are completed, the manufacturer must then prepare a Technical File, sign an EU Declaration of Conformity (DoC) and attach the CE marking to the product.

2) Which Decorative Lighting Products Typically Require CE Marking?

In principle, all decorative lighting products sold or placed into service within the European Union should comply with the applicable CE requirements, including but not limited to:

• Chandeliers
• Wall Lights
• Ceiling Lights
• Table Lamps and Floor Lamps
• Custom lighting for hotels and commercial projects

In the context of engineering projects, including hotels, commercial complexes and offices, buyers may want to go further than the CE mark itself. Suppliers are commonly asked to provide the EU Declaration of Conformity (DoC), test reports, and the Technical File to support project approval or import compliance.

6. RoHS Compliance: Which Decorative Lighting Products Must Comply with RoHS?

There are several testing standards, such as UL, ETL, and CE, which are mainly based on the safety of the product or the market access; the testing standard RoHS is based on the use of hazardous substances in the lighting product. The rest of this document outlines the extent of the RoHS requirements and its role in decorative lighting products.

RoHS Label

1) What Does RoHS Compliance Cover?

RoHS (Restriction of Hazardous Substances) is an EU environmental law, which limits the use of hazardous materials in electrical and electronic products. Currently restricts ten substances that are hazardous, such as: lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (Cr⁶⁺), and some phthalates. The maximum concentration allowed is 0.1% for lead and 0.01% for cadmium.

For decorative lighting products, RoHS testing typically covers the following components:

• LED light sources and drivers
• PCB assemblies
• Solder and electronic components
• Wires, cables, and insulation materials
• Plastic parts and connectors

It should be noted that RoHS is an environmental regulation and will not assess electrical safety. So it cannot replace the safety requirements like UL/ETL/CE.

2) Which Decorative Lighting Products Typically Require RoHS Compliance?

All decorative lighting products currently on the European Union market should abide by the RoHS requirements as well as chandeliers, wall lights, ceiling lights, table lamps, floor lamps and custom-made lighting solutions for hotel and commercial projects.

Metal frames, glass and natural stone are typically not part of the focus of RoHS testing, however, internal electronic components, power supplies, wiring and soldering materials are often tested during supplier audits and in the laboratory. RoHS compliance applies to the complete luminaire. If any critical electronic component exceeds the permitted limits, the entire product may fail to comply with RoHS.

It should also be noted that there is no general RoHS exemption for brass hardware. Added lead to enhance the machinability of some antique brass canopies and mounting brackets allow limits to be exceeded. The RoHS allows for some exemptions for lead in glass, but these exemptions are not unlimited. Recycled crystal materials are also more likely to exceed the allowable limits, so material composition reports should be retained for verification.

7. How to Verify Whether Decorative Lighting Certifications Are Valid

When buying lights, certification documents do not mean the lights will meet the standards. It is also important to check the validity of the certification and its authenticity, and to make sure that it is the same as the product being offered. The important points to examine are summarized below.

1) Why Certification Documents Alone Are Not Enough

During qualification, many buyers will request the UL, ETL, CE or RoHS documentation from the supplier. But just because something has certification documents doesn’t mean that the current product is certified.

• Common issues include:
• Using expired certification documents.
• Certification documents that cover a different product model.
• Certification that applies only to individual components rather than the complete luminaire.
• Using test reports from another product to support the current product.

For this reason, buyers should not rely solely on the certificate title. They should verify that the certification specifically applies to the product being purchased.

Certification Label Information

2) How to Confirm That the Certification Applies to the Actual Product

After receiving the certification documents, verify the following information carefully:

The other way is to check the product model or certification number on the official website of the certification body to ensure that the product has been certified and is still valid for UL or ETL.

Verify the Certificate Date and Certification Scope

3) How to Identify Invalid or High-Risk Certifications

In the procurement process, you should give special attention to the following situations:
The Certification has not been registered in the register of the Certification body. Be always sure that you have UL or Intertek Certification number and do not trust photos of the Certificate.
The certificate has been suspended, expired or withdrawn. Look at the certification entity’s website to verify its status, rather than checking the issue date.
The certified model doesn’t match the model on the product nameplate. Ensure that the product model and manufacturer on the certificate is precisely the same as the purchased product.
The product structure has developed but the supplier is still using the original certification. If the driver, power supply, wiring or such key structural changes are made, then the certification assessment process is typically restarted.
A component Recognition certificate is presented as a complete luminaire Listing certificate. Individual parts may be certified but not the entire luminaire.
The CE documentation only contains the test report but not the EU Declaration of Conformity (DoC) or Technical File (TCF). This could involve compliance concerns in the EU market.
The report from the RoHS lists only some of the electronic components, and excludes items like wiring, plastic parts or brass hardware. Ensure the scope of testing includes all major controlled parts which are used in the entire luminaire.

8. Conclusion

From new product development to sourcing decorative lighting for a new hotel, residential or commercial project, making sure that all certification requirements are confirmed early in the process can lessen the risk of changes to the product, project delays and compliance concerns.

Postmodern Lighting can help you identify the certifications needed for your intended market including the United States, the European Union and more. We can also offer technical documentation, test reports and project support to assist your decorative lighting products to enter the target market smoothly.