Update January 2021 - Following the UK’s exit from the European Union, the UK Conformity Assessed (UKCA) mark has replaced the CE mark for products sold in Great Britain. Further details in our article here.
Making and Selling Lamps
We often receive enquiries for our PAT testing courses from people looking to start a small business making and selling small electrical items, typically lamps and other lighting products. This article provides some information on the basic requirements for selling lighting equipment in the UK.
CE Marking & Product Standards
230V Lamps need to comply with the Low Voltage Directive (LVD) and as such must be CE marked. Before CE marking a product you will need to create a Technical File, carry out a Conformity Assessment and sign a Declaration of Conformity. The technical file should contain information on how your lamp meets the safety requirements. This would normally include a product description, drawings, wiring diagrams, parts list, test reports, quality control procedures etc.
- Electrical Equipment (Safety) Regulations 2016 Guidance
- Chartered Trading Standards Institute - Electrical Equipment
Complying with a product standard is not compulsory, manufacturers are free to choose another solution to demonstrate compliance with the mandatory legal requirements, however if the electrical equipment complies with a harmonised European standard, it is automatically taken to be safe. BS EN 60598 is the main standard for lighting equipment. The standard comprises of two parts. 60598-1 covers the general safety, construction, marking, wiring and testing requirements. The second part, 60598-2, is a series of accompanying standards with the requirements specific to the lighting type and application. The most relevant to most lamp makers will be 60598-2-4 Portable General Purpose Luminaires.
Copies of product Standards are available for purchase from the British Standards Institute (BSI) website. The BSI also runs an online standards library. This is a paid for subscription service, however you can often access the online standards library for free by visiting your local library.
The details of any electrical testing required will be specified in the product standard you are using as part of your conformity assessment. For example, if you are using BS EN 60598-1, the product standard for portable luminaires, the electrical tests and corresponding limits are as shown below.
|Class 1||Class 2|
|Earth Continuity||0.5 Ω||n/a|
|Electric Strength||5 mA||5 mA|
|Insulation Resistance||2 MΩ||2 MΩ|
The earth continuity should be measured with a minimum test current of 10A. The requirement for a 10A test means that most battery operated PAT instruments are unsuitable for production testing. The high current test ensures the earth path has a sufficiently low resistance and also detects any weak points, e.g. a single-strand connection. Most approval organisations, such as ASTA BEAB, recommend using a test current of 25A. The maximum allowable value is 0.5 Ω, however we would recommend using the lower limit of (0.1+R)Ω, as required by a standard PAT test.
The electric strength test (also called hipot, dielectric strength, or flash test), is used to determine the effectiveness of the insulation by applying a high voltage between the live conductors and metal parts and measuring any current leakage. The minimum required test voltage is 1.5 kV ac. This test is useful in detecting faults such as damaged or crushed insulation, loose wire strands and inadequate clearance distances.
As an alternative to the electric strength test, an insulation resistance test can be used. This measures the resistance of the insulation using a 500 Vdc test voltage. The insulation resistance test is a less vigorous test than the electric strength, so we recommend carrying out an electric strength test where possible.
Most mains powered PAT instruments can carry out a 10A earth continuity and a 500V insulation test, however as the electric strength test is not required for PAT testing, only a few models have this feature. PAT instruments that have an electric strength (flash) test include:
- • Martindale EasyPAT 2100
- • Martindale MicroPAT Plus
- • Megger PAT350
- • Megger PAT 450
- • Metrel OmegaPAT Plus
- • Seaward Supernova Elite
Other manufactures such as Clare Instruments have a range of test instruments specifically designed for production testing. SafeTest Manufacturing/Luminaire (STM/L)
BS EN 60335-1 provides best practice recommendations for safety testing household and similar electrical appliances. The standard covers:
- • The general requirements for the safety of household and similar electrical appliances.
- • Common hazards of household equipment that could cause injury.
- • The requirements and conditions to test the safety of domestic electrical appliances.
- • Defines the classification and marking of electrical equipment.
- • Demonstrates how to ensure protection against live parts.
- • Explains heating and void, as well as leakage currents and electric strength at operating temperatures.
- • Other topics include moisture resistance, stability and mechanical hazards, internal wiring and connections.
BS EN 60335-1 recommends that all manufactured items are subjected to an end of line electrical safety test.
There are some differences between production testing and a standard PAT test, however for most small scale makers, attending a PAT course is a good way to learn the basic test procedures that can then be applied to production testing.
Lighting products are subject to EU energy labelling requirements and as such are required to have an energy label indicating their energy efficiency. The label should include the company name, the model, the energy efficiency of the lamp and the weighted energy consumption per 1,000 hours.
If you sell electrical equipment you must meet the requirements of the waste electrical and electronic equipment regulations (WEEE). For most small manufacturers, the easiest way to do this is by joining the Distributer Takeback Scheme (DTS). You pay a fee that covers your WEEE obligations, with the money going towards supporting the recycling centres run by local authorities.
As a manufacturer of electrical equipment you also have additional responsibilities. You must register with your environmental regulator and you must also:
- • Mark products with the crossed out wheeled bin symbol and a date mark
- • Provide information on reuse and environmentally sound treatment of the products and components (includes materials, dangerous substances and preparations) within one year of putting them on the market
- • Make sure that distributors you supply have your producer registration number
- • Keep records for at least 4 years of the amount of EEE put on the market by category
The Restriction of Hazardous Substances (RoHS) regulations control the levels of hazardous substances and chemicals within electrical and electronic equipment. As a manufacturer you will need to complete a RoHS declaration of conformity and have supporting technical documentation to show compliance. This will usually just require the keeping RoHS product compliance certificates for the components used.
Extra Low Voltage Equipment
The Low Voltage Directive (LVD) applies to all electrical equipment operating between 50 and 1,000 Vac or 75 and 1,500 Vdc. Equipment operating below 50 Vac or 75 Vdc is classified as Extra Low Voltage and is not covered by the Directive.
A lamp using 12V LEDs supplied with an AC adaptor would still come under the scope of the Low Voltage Directive because the AC adaptor is mains powered. However, if the 12V lamp is sold separately to the AC adaptor, then the Low Voltage Directive would only apply to the AC adaptor. The AC adaptor must be CE marked and you should ask your supplier for a copy of their Declaration of Conformity.
Product liability Insurance
As a manufacturer there is always a possibility that one of your products could cause damage to a third party; that could be property or another person. Product liability insurance is not a legal requirement, but is does cover you against claims made against your business.
The Lighting Industry Association (LIA) is the largest trade association for lighting professionals in the UK. They offer a range of membership services including a testing laboratory to independently verify the safety and performance of lighting products. www.thelia.org.uk
The Low Voltage Directive and the regulations apply to electrical equipment. In general components as such are not covered by the requirements of the regulations but components which are in themselves ‘electrical equipment’ need to satisfy the requirements of the regulations and in particular be CE marked.
S.Lilley & Son, is the UK's leading manufacturer of lampholders and components for the Lighting Industry. All of the products in their range are tested at independent laboratories and certified to current BSEN ISO standards.
Flexform Ltd is a UK cable manufacturing company focused on decorative flexible cables used within the lighting industry. Flexform are members of the LIA and have been certified in their quality assurance scheme.
Upcycling and Refurbished Lamps
If you are refurbishing/restoring a lamp, then this would be classified as second-hand equipment and does not need to be CE marked. We have and article on selling second-hand electrical equipment here. Second-Hand Electrical Appliances
If you are upcycling an item that was not previously a lamp, for example repurposing an old fire extinguisher into a lamp, this is effectively a new product and will therefore need to comply with the Low Voltage Directive and be CE marked.
In this article we have used the term lamp, rather than luminaire. Technically, the term ‘lamp’ refers specifically to the replaceable component that produces light, what is usually called a ‘bulb’. A luminaire is the complete electric light unit consisting of one or more lamps.
This website is provided for information purposes only and while every effort has been made to ensure that information is accurate and up-to-date, we cannot guarantee accuracy and we are not responsible for any errors or omissions. We therefore recommend that you carry out your own research and seek professional advice where necessary.