Sourcing Solar & Smart LED from China: CE & RoHS

CE and RoHS compliance for EU buyers sourcing solar panels, LED fixtures, and smart LED products from China. Directives, standards, costs, red flags.

European buyers face a compliance burden that most Asian-market buyers do not. When you import solar products or LED lighting into the EU, you are the importer of record. That means you — not the factory in Shenzhen — hold the legal obligation to prove your product meets CE and RoHS requirements before it crosses an EU border. A customs rejection or market surveillance action is your problem to solve and your fine to pay.

This guide covers the directives, standards, and documentation you need for solar products and LED lighting sourced from China. It also covers what we check on your behalf when we manage the compliance process — because the gap between a factory claiming CE compliance and a product that actually passes third-party testing is wider than most buyers expect.

If you're at the earlier stage of evaluating suppliers, read our complete electronics sourcing guide first. For buyers doing their own factory verification, the factory audit checklist covers what to check on-site.

Why compliance matters more than most buyers assume

The cheapest CE certificate is self-declaration. A manufacturer signs a Declaration of Conformity (DoC) and affixes the CE mark without any third-party testing. It is technically legal for some product categories. It is also worth very little if a market surveillance authority tests your product and finds a non-conformity. Fines start at €10,000 in most EU member states and can include a mandatory market withdrawal order — meaning you pull every unit from distribution at your own cost.

This is not a theoretical risk. The EU's RAPEX/SAFETY Gate system logs hundreds of LED lighting and solar accessory alerts per year. Products flagged include: solar garden lights with missing or inadequate insulation, LED strips failing EMC emission limits, smart LED controllers with undeclared radio modules, and products carrying CE marks that reference standards the product was never tested against.

The legal chain matters. If your supplier is in China, there is no "EU manufacturer" with legal accountability. You are the manufacturer for legal purposes once you place the product on the EU market under your brand. Distributors who later sell your product are downstream of you — they cannot be held responsible for failures in your compliance documentation.

CE marking for solar products: which directives apply

Not all solar products are treated the same. The applicable directives depend on the product's voltage range and how it is installed.

Low Voltage Directive (LVD) 2014/35/EU applies to electrical equipment with AC voltages between 50V and 1,000V, or DC voltages between 75V and 1,500V. Most solar panels operating at system-level voltages (typically above 75V DC for anything beyond a small portable charger) fall under LVD. Compliance requires meeting harmonised safety standards and producing technical documentation.

The key harmonised standards for solar modules are EN IEC 61730-1 and EN IEC 61730-2 (photovoltaic module safety qualification) and the EN IEC 61215 series (design qualification by technology type — monocrystalline, thin film, etc.). These are the standards referenced in the technical documentation for the DoC.

Electromagnetic Compatibility (EMC) Directive 2014/30/EU applies to solar products sold as standalone units and to solar systems sold as complete assemblies. The EMC directive ensures your product does not emit interference that disrupts other devices and is not itself disrupted by ambient electromagnetic fields. For solar products in fixed installations, the accompanying documentation must describe the electromagnetic characteristics and any precautions needed during installation.

General Product Safety Regulation (GPSR) applies to consumer-facing solar products operating below the LVD voltage thresholds — including small solar garden lights, solar chargers, and USB solar power banks. GPSR covers mechanical and electrical safety for equipment in the sub-50V AC / sub-75V DC range where LVD does not apply. GPSR requires testing, a conformity assessment, and adequate user instructions.

RoHS Directive 2011/65/EU (see next section) applies to consumer solar products. Note the important exemption: professionally installed photovoltaic panels for permanent energy production at fixed locations are exempt. Solar garden lights, portable solar chargers, and solar USB power banks are not exempt.

WEEE Directive requires you to register as a producer in each EU member state where you sell your products, affix the crossed-out wheelie bin symbol to products and packaging, and participate in or fund a take-back scheme. The 2024 amendment (EU 2024/884) explicitly covers solar panels placed on the market after August 13, 2012. Implementation deadline for member states was October 2025.

CE marking for smart LED products: RED vs LVD+EMC

Smart LED products — LED strips with WiFi or Bluetooth control, LED controllers with wireless connectivity, smart outdoor fixtures — require different CE treatment than standard LED luminaires.

Standard LED luminaires (outdoor fixtures, garden lights, commercial LED panels without wireless connectivity) fall under LVD 2014/35/EU and EMC 2014/30/EU. Key standards: EN 60598 (luminaires safety), EN 62368-1 (audio/video, IT and communication technology equipment — now the successor standard to EN 60950 and EN 60065), EN 55032 (electromagnetic emissions), EN 61000-3-2 and EN 61000-3-3 (harmonic current and voltage fluctuations).

Smart LED products with wireless functions fall under the Radio Equipment Directive (RED) 2014/53/EU. This is important: RED subsumes both LVD and EMC requirements for radio-enabled products. You do not need separate LVD and EMC certifications — but RED testing is more extensive because it adds radio spectrum requirements on top of safety and EMC testing.

For WiFi-based LED controllers, the relevant radio standard is EN 300 328 (wideband data transmission in the 2.4 GHz ISM band). For Bluetooth-enabled products, EN 300 328 also applies in the 2.4 GHz range. For ZigBee (also 2.4 GHz), EN 300 328 applies again.

Since August 1, 2025, products covered by RED must also comply with cybersecurity requirements under Regulation (EU) 2022/30. This means software integrity, secure data handling, and fraud prevention measures must be designed in and documented. For a basic BLE LED controller, the practical impact is limited but the documentation must address it explicitly. Products that were designed before August 2025 are not grandfathered — if they are placed on the market after August 1, 2025, they must comply.

EN 62471 (photobiological safety) applies to all LED products. It assesses optical radiation hazards — specifically the risk of blue-light retinal damage — and classifies products into Risk Groups 0 through 3. Most residential LED strips fall into Risk Group 0 or 1, but products claiming high luminous flux or used in directed applications (e.g., architectural spotlights, grow lights) may require formal photobiological safety testing. EU market surveillance has flagged products where the photobiological classification on the DoC did not reflect the actual optical output of the shipped product.

RoHS 2 compliance: the 10 restricted substances

RoHS 2 (Directive 2011/65/EU, amended by 2015/863/EU) restricts 10 substances in electrical and electronic equipment:

1. Lead (Pb) — max 0.1% by weight in homogeneous materials
2. Mercury (Hg) — max 0.1%
3. Cadmium (Cd) — max 0.01%
4. Hexavalent chromium Cr(VI) — max 0.1%
5. Polybrominated biphenyls (PBB) — max 0.1%
6. Polybrominated diphenyl ethers (PBDE) — max 0.1%
7. Di(2-ethylhexyl) phthalate (DEHP) — max 0.1%
8. Butyl benzyl phthalate (BBP) — max 0.1%
9. Dibutyl phthalate (DBP) — max 0.1%
10. Diisobutyl phthalate (DIBP) — max 0.1%

The phthalates (substances 7–10) were added by the 2015 amendment and have applied to Category 1–7 and 10 products since July 22, 2019, and to Category 8–9 products since July 22, 2021.

For LED and solar products, the highest-risk substances are lead (in PCB solder — even RoHS-compliant solder must be verified to use lead-free alloys), cadmium (historically used in certain LED phosphors and battery components), and hexavalent chromium (in some surface coatings and fasteners). Phthalates are a risk in flexible PVC cable jackets and plastic housings.

What documentation to request from the factory: A valid RoHS declaration of conformity is the minimum — but it is not sufficient on its own. Request the underlying substance test reports. These are ICP-OES (inductively coupled plasma optical emission spectrometry) reports for metals and GC-MS or FTIR reports for organics (PBB/PBDE, phthalates). The test reports should be from an accredited lab, reference the specific product model, and be dated within the last 12–18 months. If the factory cannot produce substance test reports and only has a signed declaration, treat that as a risk indicator.

2026 compliance update: Several lead exemptions are being narrowed or expiring in 2026. For LED lighting specifically, some lead exemptions in specific LED component types have revised terms. If your product category uses any exemption-based lead applications, verify the exemption's current expiry date. The EU RoHS exemption database at echa.europa.eu is the authoritative source.

EN standards that matter for LED and solar products

A complete harmonised standards list for any directive is published in the Official Journal of the EU and maintained by CEN/CENELEC. The standards we cite here reflect the versions in force as of mid-2026, but always verify current status before finalising your technical documentation — standards are revised and superseded on rolling cycles.

How to verify compliance before production

Document audit at the sampling stage: Before you place a production order, request the following from your factory:

• CE declaration(s) of conformity for the specific product model
• Technical file index (you don't need the full file, but the index tells you what's in it)
• Accredited third-party test reports for the relevant standards (not self-test reports)
• RoHS substance test reports from an accredited lab (not just a signed declaration)
• WEEE producer registration number for each target EU member state
• For RED products: approved test reports from a notified body or accredited TCB

When you review test reports, check: the issuing lab's accreditation (look for ILAC-MRA signatory marks, or CNAS for Chinese labs with mutual recognition), the product model number against your actual product, the test date, and the standards versions referenced. Standards references in the report should match the harmonised standards list for the directive in force at the time of testing.

Pre-compliance bench testing during sampling: Before committing to accredited lab testing, pre-compliance testing on your sample can identify failure risks at low cost. Pre-compliance is done with less-precise (but much faster and cheaper) EMC scanners. A typical pre-compliance EMC check for a LED driver can be done in China for $200–$500 per sample. It catches gross failures — the ones that would otherwise appear as expensive surprises during formal testing — before you're locked into a production run.

Verify the factory's own test setup: Ask whether the factory has in-house testing capabilities. A factory with an in-house AOI line, burn-in room, and basic electrical safety tester is not the same as a factory with accredited EMC and photobiological safety testing. For full CE compliance, testing must be done at accredited labs. In-house testing is useful for production-stage QC; it does not substitute for accredited certification testing.

How our sourcing process handles compliance

When we manage a CE-bound LED or solar product for a European buyer, compliance runs in parallel with supplier qualification — not as an afterthought after production. The sequence:

Step 1 — Document audit at supplier shortlisting: For each shortlisted factory, we request their existing CE documentation and test reports for the product category. We check accreditation status of cited labs, verify standard versions against the current harmonised standards list, and flag expired or mismatched certificates. Factories that cannot produce third-party test reports are deprioritised.

Step 2 — Pre-compliance testing during sample evaluation: Once we receive samples from 2–3 candidate factories, we use pre-compliance testing to screen for EMC failures before committing to accredited lab costs. This catches the factories that are producing non-compliant designs and claiming otherwise. In the screening we run, roughly 30–40% of samples from Chinese LED and solar factories fail pre-compliance EMC screening on the first round.

Step 3 — Accredited lab testing: We coordinate test submissions to SGS, Intertek, TÜV Rheinland, or Bureau Veritas depending on the product category and the buyer's market requirements. We handle sample shipping logistics, lab liaison, and translate technical queries between the buyer's engineering team and the lab. Test results go to us first — we review for anomalies before forwarding to the buyer.

Step 4 — Declaration of Conformity review: The DoC is a legal document. We review the factory-issued DoC against the test reports to verify that the standards cited are the ones actually tested, the product model number matches, and the responsible person's EU address is present if required. Factories frequently issue DoCs with errors — outdated standard references, incorrect directive numbers, missing product identifiers — that would invalidate the document.

Step 5 — Production traceability: After production begins, we verify through inspection that the units being built match the tested configuration. Substituted components — a different LED driver IC, a different cable supplier — can invalidate CE marking on products that were otherwise compliant. This is a real risk in high-volume LED manufacturing where component availability fluctuates.

Common failure patterns

Expired test reports: CE test reports don't have a mandatory expiry date, but they lose relevance when the product changes or when the harmonised standards are updated. Many factories present test reports that are 3–5 years old and reference withdrawn standard versions. A report citing EN 55022 (withdrawn in 2017, superseded by EN 55032) is not current evidence of compliance.

Self-declared CE for products requiring notified body involvement: Most LED and solar products can use the manufacturer's self-declaration route. But if your product is assessed as Risk Group 2 or above under EN 62471, or if your RED product requires notified body involvement for specific radio frequency bands, self-declaration is not sufficient. Factories sometimes self-declare regardless.

CE mark used as a China Export mark: There is a separate "China Export" mark that resembles the CE conformity mark closely enough to cause confusion in print. Always request the actual DoC and test reports — never accept the mark on the product as proof of compliance.

RoHS declarations without substance test reports: A signed RoHS declaration without underlying substance analysis is an unsupported claim. It is not evidence of compliance. This is one of the most widespread gaps in Chinese LED and solar product documentation.

Test report model mismatch: The test report covers the model tested — not every variant the factory sells. A factory may have CE test reports for a 60W LED fixture but ship you a 100W version that was never tested. Always verify that the test report model number matches your exact product specification, including power rating and any wireless module variant.

Component substitution after certification: Chinese LED factories routinely substitute components — particularly LED drivers and wireless modules — based on availability and price. A product that passed CE testing with IC Brand A in the wireless module may be produced with IC Brand B during your production run. Unless you audit the BOM against the tested configuration, you may receive products that are not compliant with the certified configuration.

Costs and timelines

A realistic CE compliance budget for an LED or solar product sourced from China:

These figures are for accredited labs in China (SGS, Intertek, TÜV Rheinland China). European labs are more expensive and slower due to shipping time. For most buyers, using China-based accredited labs is the practical choice — the certificates carry the same legal weight.

The most important time-management point: submit samples to the lab at the same time you confirm your production order. Testing takes 4–8 weeks regardless of what the factory is doing. If you wait for production to complete before submitting samples, you add the full testing cycle to your delivery timeline. If you run testing in parallel with production, certification and goods arrive at roughly the same time.

Factor in one round of retesting. In our experience sourcing LED and solar products from China, initial CE test failures requiring design or component changes occur in approximately 25–35% of engagements. Budget for one retest cycle and adjust your timeline accordingly.

Getting compliance right from the start

CE and RoHS compliance is not a box to check at the end of a sourcing project. It is a constraint that shapes which factories you can use, which designs are viable, and how your production timeline is structured. The buyers who get into trouble are those who treat compliance as something the factory handles independently — when in fact the factory's obligation ends at the Chinese border. The legal exposure from customs rejection, market surveillance action, or a downstream retailer's liability claim falls on the importer.

Working with a sourcing partner who understands the directive structure, can read test reports, and coordinates directly with accredited labs eliminates most of the common failure modes. It also compresses the timeline — because pre-compliance screening, document audits, and lab coordination can run in parallel, rather than being sequential surprises.

If you're planning to import solar or smart LED products into the EU and want to understand what a compliance-aware sourcing engagement looks like for your specific product, contact us with the details. We scope each project individually based on product category, target EU markets, and timeline.

Or if you're earlier in the process and want to understand how our end-to-end sourcing workflow handles quality and compliance, see how we work.