Buyers often ask: do your lights have CE. The question needs unpacking first.
CE is not a certificate issued by a body. It is a declaration of conformity made by the manufacturer. Putting the mark on a luminaire means you are declaring the product meets the applicable EU legislation, and that you hold technical documentation to prove it on request. Most CE certificates circulating in the market are test reports from third-party labs. They can form part of the technical file, but they are not CE itself.
An LED luminaire entering the EU usually has to satisfy four instruments at once.
The Low Voltage Directive, 2014/35/EU, for equipment operating between 50 and 1,000 V AC, with testing typically following EN 60598-1 and the EN 60598-2 series.
EMC, 2014/30/EU, with EN 55015 and EN 61547 covering emissions and immunity.
RoHS, 2011/65/EU, plus the four phthalates added by 2015/863. This one looks at materials, not performance.
ErP, the ecodesign regulation (EU) 2019/2020. This is the one most often missed and most often failed.
ErP 2019/2020 took effect in September 2021, replacing 874/2012 and 1194/2012. It sets minimum efficacy for light sources, a 0.5 W standby ceiling, and the A-to-G energy label that replaced A+++. The old A+++ label is no longer legal in the EU.
Two failures come up more than any others in practice. Standby power, because luminaires with remote controls, sensors or smart modules drift above 0.5 W easily and the limit is hard. And flicker, because the regulation sets explicit limits on SVM and Pst LM, so flicker you cannot see by eye still fails on an instrument.
Two further items get skipped: WEEE registration for electronic waste, and the packaging directive. Neither is a performance issue, but customs and marketplaces do check.
The practical advice is short. Ask the factory for a complete technical file: test reports, the declaration of conformity, and the calculation behind the energy label. A single test report does not demonstrate CE compliance.
One forward-looking note: the EU is rolling out ESPR, the sustainable products regulation, with digital product passports following. Getting the technical file organised now saves a rebuild when the rules move.