Why the CE mark isn’t enough to ensure you stay safe…

A badly designed or manufactured LED product can be dangerous. Robert Bain considers the measures in place to protect us.

Nearly half a million people have watched a YouTube video posted last year by electronics blogger Julian Ilett, titled Dangerous GU10 LED spot light is cheap and bright but could kill you – seriously.

In the video (which you can watch at bit.ly/gu100214)  takes apart a GU10 lamp that he bought on eBay for £3 – including postage, naturally. He shows that, depending on which way round the two pins of the lamp are inserted, there’s a 50:50 chance of getting live mains electricity on the front face of the lamp. From there, there’s very little preventing the current reaching the heatsink as well – posing a pretty serious risk to anyone touching it.
‘It’s a bit like Russian roulette,’ Ilett says. He’s not wrong. And that lamp is not alone. 

Old lighting technologies had their own safety issues (mercury, for starters), but LED products introduce a new set of problems. Whereas making a fluorescent or incandescent lamp required some serious industrial equipment, pretty much anyone can cobble together an LED product in their garage – or try to. The market has opened up to those with less experience (or scruples). Plus, the electronics required to make LED lights work introduces the risk of parts becoming live.

Mark Salt of the LIA Labs says: ‘As we move into LED technology from traditional technologies, the skillsets required to drive these technologies, particularly electronics, is something that the industry doesn’t have a great deal of knowledge about. So the quality of the product being procured is not always what it should be.’

Safety first

That’s putting it mildly. Last year the EU banned 41 LED products because of a risk of electric shock or fire, including lamps, torches, light strips and novelty lights. Several more have been taken off the shelves already this year. The vast majority were made in China.

The detail gets even more interesting. Amazingly, 19 of the products banned in 2013 – nearly half – were spotted in Finland. Does Finland really have such a problem with dodgy lighting products that it gets half of all the European total, despite being home to barely one per cent of Europe’s population? It hardly seems likely. Much more believable is that the Finnish market surveillance guys are well resourced and on the ball. So if the Finns can find 19 dodgy products in a year, how many more are being missed across the rest of the European Union? Thousands? Tens of thousands?

David Scott-Maxwell of UK-based LED specialist Forge Europa says that the products being spotted are only ‘a tiny fraction of what’s out there’. The European Union’s long-established rules on electrical safety ‘are being blatantly ignored by a very large number of people,’ he believes.

Market surveillance in the UK, Scott-Maxwell says, is ‘extremely weak’, because it’s only policed on the basis of complaints, and the regional Trading Standards offices that deal with electrical safety also have to deal with food hygiene, financial scams and a hundred other things, so they’re not experts.

With a large number of low-cost imported products flooding the market, this is a dangerous situation to be in.

And for a company like Forge Europa that prides itself on quality, this is a frustrating state of affairs. ‘It’s unfair competition,’ says Scott-Maxwell, ‘because testing comes at a cost. You quite literally have to include cost to make things safe and EMC compliant. There’s no two ways about it.’

However, he remains optimistic. ‘The good thing is, there’s greater awareness, and the other thing is that testing is gradually catching up. One of the big issues up until now has been that the standards have been either ambiguous or just absent. That’s improving slowly.’

I firmly believe that self declaration for this kind of technology will drive down quality of product that hits the marketplace,’

Mark Salt of the LIA Labs

Jeremy Turner of Fab Controls messes about with lamps and transformers for a living. The biggest safety issue in the LED world, he says, is poor quality GU10s. ‘In the good quality ones, the big names like Megaman, Bell and so on, the electronics are fully enclosed, so you can’t get to any live parts. But there are some lamps  where, if you grabbed hold of it while it was on, you’d get electrocuted. If you’re buying an LED from a reputable supplier in the UK then that’s not common, but if you buy something on eBay, it can happen.’

But low-voltage MR16s can be hazardous too. ‘The lamp is intrinsically safe but you connect it to a transformer which is expecting a halogen load, some will go band and some will pump out current until the lamp goes bang.’
So what are our lines of defence against dangerous lighting products? Well, first is the CE mark. Standing for Communauté Européenne, the CE mark is the symbol that must be stamped on lighting products (and other goods) for them to be sold legally in the European Economic Area. It’s how manufacturers declare that their products comply with all relevant EU legislation, including the Low-Voltage Directive, the Restriction of Hazardous Substances (RoHS) Directive and the Electromagnetic Compatibility (EMC) Directive.

Clearly, opening the door to the EU is a must for many manufacturers, so getting a CE mark is a crucial step. Unfortunately, the responsibility for carrying out the conformity assessment lies with the manufacturer themselves. CE marking your products is a bit like pleading not guilty to a crime – an important part of the process, but hardly enough to get you off the hook.

And since CE marks are not rigorously policed, the system gets abused. Some manufacturers say it might as well stand for ‘Chinese Export’. Mark Salt of the LIA Labs is sceptical too. ‘I firmly believe that self declaration for this kind of technology will drive down quality of product that hits the marketplace,’ he says.

‘The manufacturer declares their products meet the required standard for safety, but I don’t think there’s a thorough understanding in the industry of what’s required in terms of testing and completing technical files. So declarations may be being made inadvertently on product that haven’t been properly assessed.

‘The only way they can be taken to task is people checking on the declarations that are made. Without any of that, the less scrupulous businessman can do what he likes. To me that’s amazing.’
There are other schemes such as ENEC, which goes above and beyond what is required by the CE mark, requiring third-party testing by an accredited lab. But the ENEC scheme is only voluntary.

For buyers, then, it’s very difficult to tell which products are dodgy and which ones are OK.

Jeremy Turner says CE marking isn’t very helpful for buyers. ‘It’s my belief that even the products that have got CE marks aren’t always compliant,’ he says, because of the lax rules about things are tested and certified. Turner prefers to put his trust in reputable manufacturers – the ones with an established name and ‘something to lose’ if their products aren’t up to scratch.

Hope for the future

It’s not all bad news, though. To take a more proactive approach to the safety of lighting products, the Lighting Industry Association has been helping the National Measurement Office to test a sample of LED lamps – firstly to see if they perform as well as the manufacturers boast, and secondly to see if they’re safe.

Testing for safety issues on samples of between 50 and 60 products showed ‘a significant number’ of safety issues. This information has now been passed by the National Measurement Office to Trading Standards authorities, who are conducting risk assessments and deciding where to take further action.

Lighting professionals need to continue to be vigilant. Even if those dodgy GU10s don’t electrocute you, they could do some serious damage to the industry in which you make your living.