Certification documentation for lighting imports is arranged per order, not carried as a standard feature on every product. Different markets ask for different marks — CE for the EU, UKCA for the UK, UL or ETL for the US, CCC for China, RCM for Australia and New Zealand, KC for Korea, PSE for Japan — and the exact set you need depends on the destination market, the product configuration and the local importer’s filing obligations. The supplier’s role is to support the documentation process and to confirm what is available for the specific order; the buyer’s role is to identify the destination requirement, decide which documentation path is needed, and own the registration or filing in the destination market. This page explains the common certification paths for lighting, what “arranged per order” means in practice, and what to confirm before placing an order.
Why certification is a per-order decision
There are two layers to lighting certification, and they belong to different parties. The first layer is product-level compliance: the test reports that cover a specific fixture’s electrical safety, electromagnetic compatibility, photobiological safety and RoHS substance restrictions. Those reports are tied to a specific product configuration — a 110–130V driver is tested differently from a 220–240V driver, a 30W LED is tested differently from a 60W LED, an IP65 rated fitting is tested differently from an IP20. The reports are usually issued by an accredited third-party laboratory and remain valid for a defined period or as long as the product configuration is unchanged.
The second layer is market-level compliance: the marks that depend on the destination country’s regulatory regime. CE is the EU’s declaration that a product meets the relevant directives; UKCA is the UK equivalent; UL or ETL is the US listing; CCC is the Chinese mark; RCM covers Australia and New Zealand; KC is Korea’s safety and EMC mark. A fixture may have a perfectly good CE test report and still need separate documentation to enter the US, the UK or Australia.
What makes lighting certification a per-order decision is that the two layers only line up when the destination, the product configuration and the importer’s filing obligations are all known. None of these is constant across orders, so neither is the documentation path.
Common certification paths for lighting projects
The list below covers the marks most often asked about. It is not exhaustive — some buyers, especially distributors, have their own checklist — but it covers the standard set for an EU, UK, US, Canada, Australia, Korea or Japan destination.
- CE (EU) — covers the Low Voltage Directive (LVD), the Electromagnetic Compatibility Directive (EMC), the RoHS substance restriction, and the ErP eco-design regulation for lighting. The declaration of conformity is signed by the manufacturer or the authorised representative; the technical file is held on the manufacturer’s premises.
- UKCA (UK) — covers the same scope as CE, but the mark is the UK Conformity Assessed mark, applicable since 1 January 2021 for products placed on the Great Britain market. A UK responsible person is required for non-UK manufacturers.
- UL or ETL (US) — UL 1598 covers luminaires; UL 8750 covers LED equipment; UL 153 covers portable luminaires. ETL is an equivalent mark issued by a Nationally Recognized Testing Laboratory. The mark is printed on the product label after the listing is granted.
- FCC (US) — electromagnetic compatibility for electronic products, including LED drivers. The supplier’s test report covers the FCC part 15 limits.
- cUL or cULus (Canada) — the Canadian equivalent of the UL listing, often bundled with the US listing as a cULus mark.
- CCC (China) — compulsory certification for products sold inside the Chinese market. Not required for goods exported from China to other destinations.
- RCM (Australia and New Zealand) — covers electrical safety, EMC and radio compliance under a single mark. A local responsible person is required for overseas manufacturers.
- KC (Korea) — safety and EMC combined. The mark is issued by Korean authorities on the basis of test reports and a local registration.
- PSE (Japan) — electrical safety for specific product categories. The mark is required for lighting products sold in Japan.
In addition, performance and energy programmes — Energy Star in the US, the EU energy label, California Title 24 and similar — sit on top of the safety marks. They are not strictly required to import the product, but they are often required by the buyer’s retailer or specification.
What “arranged per order” means in practice
For a typical order, the per-order process has four steps. They are predictable, but the time and cost vary by configuration.
- Review the destination and the product specification. The supplier confirms which marks are applicable for the destination, the voltage, the wattage, the IP rating, the dimming type and the finish. If the order matches an existing test report, the path is short. If it does not, new testing is needed.
- Confirm which documents can be issued from existing reports. The supplier lists the test reports and declarations that already cover the configuration, the documents that need a small update (for example, a new variant on an existing certificate), and the documents that require a fresh test.
- Quote the documentation cost, if any. Documentation that falls under an existing test report is usually quoted at zero or low cost. A fresh test on a new configuration is a per-test fee, plus the testing lead time.
- Issue the documentation with the order. The test report, the declaration of conformity, the technical file and the certificate are bundled with the shipment or sent ahead by email, depending on the document type.
The key benefit of this flow is that the buyer knows the cost and the lead time before the order is confirmed, not after. A quotation that says “CE documentation on request” is not the same as a quotation that says “CE declaration of conformity is included from the existing test report; CB test report on request; UL listing to be arranged at USD X per variant with a Y-week lead time.”
Who provides what — supplier versus buyer
Most of the confusion in lighting certification comes from unclear ownership. The split is straightforward, but it varies by market.
What the supplier provides: existing accredited test reports for the product family; declarations of conformity signed by the manufacturer; factory inspection reports; the technical file (TDS, BOM, circuit diagram, label artwork, key component list); the certificate of compliance for any market where a certificate is required and the supplier is the certificate holder.
What the buyer or importer provides: the destination market and the applicable marks; the product configuration; any local registration (for example, the UKCA responsible person, the RCM responsible person, the local agent for KC); the local importer’s file with the relevant authority; and the import license where one is required.
What is shared: the project specification, the agreed product configuration, the order documentation, and the technical file. The buyer’s brand, label artwork and country-of-origin marking need to be agreed in writing, because they are part of the technical file.
For an OEM project, the documentation path usually needs a re-issue under the buyer’s brand. The lead time and the cost of the re-issue should be confirmed before the sample is signed off, not at the bulk order stage.
How the documents are issued
There are three families of document, and they are issued by different parties.
Test reports are issued by the accredited laboratory that performed the test. The supplier holds the report and shares it with the buyer on request. The report names the product, the configuration, the standard, the test results and the validity period. A test report is the evidence; a declaration or a certificate is built on top of it.
Declarations of conformity (DoC) are signed by the manufacturer (or, in the EU, an authorised representative) and state that the product meets the applicable directives. The DoC references the test reports, the standards and the product configuration. The DoC travels with the shipment or is held available for inspection.
Certificates are issued by a certification body or a notified body — UL, TÜV, SGS, Intertek, and so on. A CE mark is a self-declaration and does not require a third-party certificate for most lighting products, but UL, ETL, KC and a number of others do. The certificate is held by the certificate holder (often the manufacturer) and a copy is shared with the buyer.
For OEM or private-label projects, the certificate may need to be re-issued in the buyer’s brand. The lead time is usually a few weeks and the cost is a per-certificate re-issue fee. The buyer’s brand and the label artwork must be finalised before the re-issue is requested.
What to confirm before you order
Before you place an order, ask the supplier to confirm the following six points in writing. Each is a question with a real answer, not a “we’ll see” answer.
- Destination country and the applicable marks. Name the market and the standards that the documentation needs to cover.
- Whether the product configuration falls under an existing test report. Voltage, wattage, IP rating, dimming type and finish all affect the test scope.
- Whether any new testing is needed, the cost and the lead time. The cost is a per-test fee; the lead time is usually two to six weeks for a standard test.
- Whether the documentation is in your brand or the supplier’s brand. For OEM, the brand change usually triggers a re-issue.
- The validity period of the test report and the certificate. Reports do not last forever, and some markets require re-testing on a cycle.
- A sample of the documentation, sent before the order is placed. A redacted test report or a sample DoC tells you more than any quotation line.
A supplier that can answer those six points clearly is a supplier that has done the work before. A supplier that cannot is one to treat with caution on certification claims.
How certification interacts with the product price
The product price and the certification documentation are kept separate on a Staylighting quotation. The product price covers the fixture, factory quality control, export-grade packing and delivery to your designated China port. Documentation that falls under an existing test report is usually quoted at zero or low cost and is included in the quotation. Documentation that requires a fresh test, a certificate re-issue, or a new variant on an existing certificate is quoted as a separate line, with the cost and the lead time visible before the order is confirmed.
This separation is deliberate. It lets the buyer see the product cost without the documentation line, compare it across suppliers, and then add the documentation cost on top. A quote that bundles documentation into the product price without showing the split makes supplier comparison harder than it needs to be.
For a worked example of how a product price and a documentation cost appear on the same quotation, see the transparent pricing page. The full Buying Guide runs through the wider order workflow, the certifications page sets out the common marks and their scope, and the shipping policy explains what travels with the shipment. For OEM projects with a buyer brand, the product page example shows how a single product configuration flows through the order, including the documentation that comes with it.
Because documentation is arranged per order, the same fixture can ship with different paperwork to different markets. A crystal bubble chandelier, an alabaster cube pendant and a half-bowl alabaster sconce all leave the factory with the test reports and declarations relevant to the destination named on the order.
Frequently asked questions
Does the product price include CE, UL and RoHS documentation?
Where the documentation falls under an existing test report for the product configuration, yes — there is no extra charge. Where a fresh test, a certificate re-issue or a new variant is needed, the cost is quoted as a separate line before the order is confirmed. The split between product price and documentation is shown on the quotation so you can compare the product cost across suppliers independently.
How long does it take to get CE or UL documentation for a new configuration?
A standard test at an accredited lab typically takes two to six weeks, depending on the standard, the lab’s queue and the number of variants. A CE declaration of conformity built on an existing test report is much faster — often a few working days. A UL listing for a new fixture is the longest path, usually six to twelve weeks, because it includes factory follow-up inspection.
Can I use a CE declaration of conformity from a previous order?
Only if the product configuration on this order is the same as the configuration on the report, and the report is still within its validity period. A new variant — different voltage, wattage, IP rating, dimming type or finish — needs a new test or a written addendum to the existing report. Sharing the previous declaration with your customs broker for context is reasonable, but the current order needs its own documentation.
Do I need CCC documentation if the goods are only sold outside China?
No. CCC is required for products placed on the Chinese market. Lighting goods exported from China to other destinations are not subject to CCC, and the shipment is not held by China Customs for CCC reasons. The applicable documentation for the destination market still applies.
Who is the “responsible person” for UKCA and RCM, and is it me?
For UKCA (UK) and RCM (Australia and New Zealand), the responsible person is a local entity that takes responsibility for the product’s compliance on behalf of an overseas manufacturer. It is usually the importer or a third-party compliance service. If you do not have a local entity in the UK or Australia, a third-party responsible person can be appointed, and the cost is a small annual fee. The supplier does not act as the responsible person for either scheme.
To put a real cost and lead time against the certification path for your product, send the product specification, the destination country and the order quantity to our contact page. We will return a per-order confirmation of the applicable documentation, the cost and the lead time before you commit.