LED Lighting Regulations in the United States: An Overview

LED lighting Safety Standards in the US

LED lighting manufactured or imported for sale in the United States must comply with various regulations and standards. On top of that, there are also voluntary standards that in practice are required.

This guide explains how regulations such as 47 CFR Part 15, 10 CFR Part 305, and RoHS, are relevant to LED lighting products. In addition, we also cover relevant UL standards and explain the importance of lab testing before selling LED lighting.

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47 CFR Part 15 – Radio Frequency Devices

47 CFR Part 15 establishes requirements for electronic devices emitting radiofrequency energy between 9 kHz and 3,000,000 MHz, which generally includes LED lighting products. Ensuring compliance with 47 CFR Part 15 – Radio Frequency Devices often involves the following:

a. Making sure the products comply with relevant standards

b. Go through the necessary authorization procedure.

c. Providing a user manual, technical report, and other necessary documentation

d. Affixing the necessary label on the product and its packaging

Unintentional radiators

FCC

Unintentional radiators generate radiofrequency energy used within the device but do not intend to emit energy via induction or radiation. Most lighting products, including LED products, are unintentional radiators.

Here we list the main requirements for unintentional radiators:

Undergo the Supplier Declaration of Conformity (SDoC) authorization procedure
Ensure compliance with FCC rules via lab testing
Draft an SDoC compliance information statement
Maintain test reports and user manuals
Provide technical documentation
Provide proper labeling

Intentional radiators

Intentional radiators are made to purposefully generate radiofrequency energy via induction or radiation. Lighting devices that have Wi-Fi or Bluetooth capabilities are generally considered to be intentional radiators and thus must comply with requirements, such as:

a. Undergo the certification procedure, by filing a grant of certification with a Telecommunication Certification Body (TCB)

b. Comply with relevant rules and standards (e.g. ANSI C63.10.2020), by ensuring that the device is lab-tested by an FCC-recognized accredited testing lab

c. Submit a technical report

d. Label the product (FCC identifier and compliance information statement)

Seasonal and decorative lights: 16 CFR Part 1120 – Substantial Product Hazard List

16 CFR Part 1120 covers products that have characteristics that can cause a substantial risk of injury to consumers. 16 CFR Part 1120 also covers decorative lighting with the following characteristics:

Nominal input voltage of 120 V
Portable
Connected by a plug
For temporary use

This includes products such as:

Stars
Wreathes
Candles without shades
Light sculptures
Plastic blow-molded figures
Animated figures

Products outside the scope of 16 CFR Part 1120

16 CFR Part 1120 also lists products that are not covered. Here are some examples:

Products with batteries
Solar-powered products
Products that use a transformer or low-voltage power supply
Portable lamps used to illuminate the seasonal decorations

UL 588 – Standard for Safety for Seasonal and Holiday Decorative Products

Covered products (e.g. stars) are deemed to be substantial product hazards if they do not comply with the requirements of UL 588, which is incorporated under 16 CFR Part 1120.

These requirements concern the following characteristics:

Minimum wire size
Sufficient strain relief
Overcurrent protection

10 CFR Part 430 – Energy Conservation Program for Consumer Products

16 CFR Part 430 is a regulation within the Energy Policy and Conservation Act (EPCA) and sets test procedures and energy conservation standards for certain types of consumer products, such as LED and OLED light products.

For example, Appendix BB to Subpart B sets a uniform test method for the following specifications of LED lamps:

Input power
Lumen output
Lamp efficacy
Correlated color temperature
Power factor
Time to failure
Standby mode power

Examples of covered products include:

Integrated and non-integrated LED lamp
OLED lamp
LED downlight retrofit kit

10 CFR Part 429 – Certification, Compliance, and Enforcement for Consumer Products and Commercial and Industrial Equipment

10 CFR Part 429 establishes certification and compliance requirements for products covered by 10 CFR Part 430, and 10 CFR Part 431

Manufacturers must create a certification report containing the information such as:

Product or equipment type and class
Manufacturer’s name and address
Private labeler’s name and address (if applicable)
Brand name
Basic model number and manufacturer’s individual model number
Whether it is a new or discontinued model
Test sample size (number of units tested for the basic model)
Product-specific information

16 CFR Part 305 – Energy Labeling Rule

16 CFR Part 305 sets energy labeling requirements for consumer products that include general service LED or OLED lamps.

According to 16 CFR Part 305.5, LED or OLED are considered general service lamps, and so, must include information such as the following in their label:

Light output of each lamp (expressed as “Brightness”)
Estimated annual energy cost (expressed as “Estimated Energy Cost” per kWh)
Life of each lamp (expressed in years)
Correlated color temperature of each lamp (expressed as “Light Appearance”)
Wattage of each lamp (expressed as energy used)
Design voltage of each lamp, if it’s not 120 volts
A “Contains Mercury” statement, if it contains mercury

You can refer to prototype labels 5, 6, and 7 in Appendix L to 16 CFR Part 305 for more details.

Part 305 may require products to undergo testing to determine the values necessary for the label, such as:

Energy efficiency rating
Light output
Energy usage

UL Standards

Even though UL standards are voluntary, unless they are incorporated by reference in a regulation, you are still required to ensure your products are safe. Thus, in practice, you must make sure your products comply with relevant safety standards.

Additionally, marketplaces such as Amazon might require your LED product to comply with the relevant standard, or else it might not accept or list your product.

Here are a few UL standards relevant to LED products:

Title	Description
UL 8750	This standard covers requirements for LED equipment for use in lighting products
UL 8753	This standard specifies requirements for, and covers, field-replaceable LED light engines
UL 588	This standard covers safety requirements for seasonal and holiday decorative products, including light sculptures

RoHS

Some states regulate certain electronic products under RoHS state laws. This includes:

California
New Jersey
Illinois
New
Rhode Island
Wisconsin

While requirements are different according to the state, in general, they concern substance restrictions, reporting and registration.

Here are some examples of restricted substances:

Lead < 0.1%
Cadmium < 0.01%
Mercury < 0.1%
Hexavalent Chromium < 0.1%
PBBs < 0.1%
PBDEs < 0.1%

Lab Testing

You often need to have your product tested to prove it complies with relevant requirements, such as electromagnetic compatibility or substance restrictions.

Some regulations may require product testing. However, you might still need to ensure your product is safe, so, ensuring your product undergoes testing using UL standards is a practical necessity.

Regulation	Lab testing
47 CFR Part 15 – Radio Frequency Devices	You should ensure that your products are tested against relevant standards such as ANSI C63.10 or ANSI C63.4
UL standards	UL standard compliance may include different requirements and tests according to the product. For example, it could be requirements concerning electrical safety, electromagnetic compatibility, mechanical safety, and more
10 CFR Part 430	You should ensure that your product undergoes the necessary testing, for example, in order to determine factors such as time to failure or lumen output.
16 CFR Part 305	Testing is generally required to assess the values that must be affixed in the label, such as energy efficiency rating.
RoHS	Your product should undergo testing to ensure that it does not contain any substance above permitted limits.

LED light products testing companies

We list below a few companies that offer to test light products, such as LED products, in the United States.

Bureau Veritas
QIMA
TÜV SÜD
CSA Group
TetraInspection
FusionOptix

Additional Requirements

Here are a few more regulations, and explanations regarding their relevance to LED products.

Regulation	Description
Country of Origin	Consumer products, including LED light products, must carry a Country of Origin marking. For instance, if the product is manufactured in China, the marking must state: “Made in China”.
Toxic Substances Control Act	The TSCA regulates certain substances that can be found on components or parts, such as persistent, bioaccumulative, and toxic (PBT) substances, which are commonly found in plastics. Thus, you should test your product to ensure that it does not contain restricted substances above the limit.
California Proposition 65	LED lighting products might contain substances on the Proposition 65 List, such as phthalates and cadmium. You must therefore have your products tested to ensure they either don’t contain those substances above the set safe harbor levels.

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Risks

LED lighting products manufactured overseas are not exclusively made to comply with US standards and regulations. For example, most LED products manufactured outside the United States are not UL tested, or even designed to pass UL testing. This can also be said about FCC compliance and energy efficiency requirements.

The bottom line is that compliance and general safety cannot be taken for granted when importing LED lighting to the United States. Most LED lighting products are manufactured for other markets and are not designed to comply with US regulations and UL standards.

It’s therefore critical to work with manufacturers that have a solid compliance track record of exporting compliant LED lighting to the United States – and follow up with third-party testing before shipping LED lighting products into the United States.