Two document sets, not one
Buyers read CE marking as one thing. It is two. Safety and interference sit under the CE-marking directives, and the maker signs for them. Energy labelling sits under Regulation (EU) 2019/2015 and ecodesign under Regulation (EU) 2019/2020, both applying from 1 September 2021, and those bring a database entry with them. A quotation that answers only the first half leaves the second half open.
The rescaled EU energy label runs A to G and must carry a QR code linking to EPREL, and the supplier enters the product parameters and the technical documentation into EPREL. That entry is made by the supplier, not sent to you by the factory as a test report.
Which rules reach your string
| String type | Where it sits | What to ask for |
|---|---|---|
| 230 V mains festoon, plug-connected | Inside the Low Voltage Directive's 50 to 1000 V AC band. Ecodesign and energy labelling reach it as well if the chain meets the light-source test below. | The EU Declaration of Conformity for the exact factory code, the test reports behind it, plus the label artwork and the EPREL data where the chain is the light source. |
| Mains input driving a low-voltage chain | Two halves. The star fairy and curtain strings, ILT-SOL-011 to ILT-SOL-016, print 100~240V / 27V: the input side is inside the 50 to 1000 V AC band and the light chain is below it. | Ask which half of the assembly each document covers, and ask for the power supply's own documents by name. |
| Solar string on a panel | The panel-powered strings, ILT-SOL-001 to ILT-SOL-010 and ILT-SOL-017 to ILT-SOL-020, run off a panel and print no mains voltage, so the Low Voltage Directive's band is not reached. | Ask for the EMC and RoHS test reports, name the destination market on your enquiry, and take the answer on your quotation. |
A declaration that cites the Low Voltage Directive for a product with no mains input is the wrong document for that product. Reading which directive a declaration names, and against which factory code, is worth more than counting logos on a carton.
When the string is itself a light source
Light strips, strings and chains, decorative and Christmas ones included, are not exempted as such from EU ecodesign; they are in scope where they meet Article 2(1) of Regulation (EU) 2019/2020. If the relevant length gives more than 60 lumen, the product is a light source in scope. Market-surveillance verification tests a 50 cm length and scales it to the full product, so the marketed chain is what is judged.
Then the removability test. Products containing light sources that cannot be removed for verification without damaging one or more of them are tested as light sources. Where that is so, the whole product is the light source and needs an EU energy label and an EPREL registration. A containing product instead has to give information on the light source it contains from 1 March 2022, and explain removal on request from 1 September 2021.
The category name settles nothing. The EU energy label for luminaires has been discontinued since 25 December 2019 under Article 9 of Commission Delegated Regulation (EU) 2019/2015, and an item that meets the light-source definition still carries a label and an EPREL entry.
Running the test on a real model
The specification line to read is the socket or LED count. The factory prints one or the other for every string. ILT-STR-013 prints 15pcs Suspension sockets on a 48FT / 14.6M length; ILT-STR-001 prints 25 pcs Suspension on 50FT / 15M. ILT-SOL-011 prints an LED quantity of 100pcs on a 12M length instead. Each of these figures is confirmed on your quotation.
A bulb that unscrews from a socket comes out without damage. LEDs fixed along the wire do not. That is the distinction the removability test turns on, and it is decided by how the string is built rather than by what it is called. Put the question to the factory against the exact factory code and take the answer on your quotation before you commission label artwork.
Great Britain
Great Britain recognises the CE marking indefinitely across 21 product regulations, and a business may use either UKCA or CE. A party placing a product on the GB market from outside the United Kingdom carries importer responsibilities, and a supplier outside Great Britain appoints an authorised representative or an importer. Settle who that party is before the first shipment: the label artwork, the retained technical file and the enquiries from the market surveillance authority all land on them, not on the factory in Bao'an District, Shenzhen.
Great Britain governs these products through the Electrical Equipment (Safety) Regulations 2016/1101, the Electromagnetic Compatibility Regulations 2016/1091, the Radio Equipment Regulations 2017/1206, the RoHS Regulations 2012 and the Ecodesign for Energy-Related Products Regulations. Those are the instrument names a GB compliance form asks you to declare against, so quote them back when you request documents.
The label is where Great Britain and the EU part company. There is no GB equivalent to EPREL. A GB supplier keeps the technical documentation itself, makes it available to OPSS on request and retains it for 15 years after manufacture stops. GB energy labels carry the UK flag and English text, plus a QR code where applicable, and a service for generating the label is provided. So a UK buyer asking for an energy label wants artwork and a retained file, not a database registration number.
What changes the answer
- Where the LEDs sit. Screw-in bulbs in sockets, or LEDs fixed to the wire. This decides whether the chain is the light source or a containing product.
- The output of the chain. The 60 lumen threshold applies to the relevant length, and verification scales a 50 cm section to the full marketed product.
- Whether it plugs into mains. The Low Voltage Directive band starts at 50 V AC and 75 V DC; a string running off a panel sits below it.
- Whether the model carries a radio. A WiFi or RF-remote string has its own document set; in Great Britain that is the Radio Equipment Regulations 2017/1206. Ask for the radio documents by name.
- The destination market. The EU wants an EPREL entry behind the QR code on the label. Great Britain wants a retained technical file and UK-flag artwork.
Which models this applies to
The 230 V European and British plug S14 strings on outdoor string lights run from ILT-STR-013 to ILT-STR-018: ILT-STR-013 to ILT-STR-015 print an EU 2 Round F plug and ILT-STR-016 to ILT-STR-018 a GB 3 G plug. The ST38 strings on the same page carry a dual rating: ILT-STR-001 and ILT-STR-002 print 120/240V and ILT-STR-003 prints 120/230V. In the smart WiFi and RGBW string lights range, ILT-SMT-002 prints an EU 2 Round F plug and ILT-SMT-003 a GB 3 G plug, both with Remote Control as the control method, which brings the radio documents into the ask. Panel-powered and low-voltage strings sit on solar string lights, and the bulbs that go into a socketed string on LED filament bulbs.
What to check on your sample
- Unscrew one bulb. Confirm it comes out of the socket intact and that a replacement of the same shape and base seats correctly.
- Read the declaration against the factory code printed on the carton and on the product label, not against a family name.
- Check which directives and standards the declaration names, and whether the configuration it describes is the one you ordered: length, plug, socket count and cable.
- Where a label is required, check that the QR code resolves to the EPREL entry for that model and that the class on the artwork matches the entry.
- For a radio model, check that the declaration covers the radio module fitted to your sample.
What to ask for with your quotation
- The EU Declaration of Conformity for the exact factory code and configuration, and the test reports behind it.
- The energy label artwork and the EPREL data sheet, where the removability test makes the chain the light source.
- For Great Britain, the technical documentation the supplier has to retain, and UK-flag label artwork.
- Confirmation in writing of who the GB importer or authorised representative will be, before the first shipment.
- For a WiFi or RF-remote model, the radio documents named against the module in your sample.
The factory states its string lights carry an ETL listing and CE and RoHS markings; the listing card, the declaration of conformity and the test reports are requested and will be published here when received. Until then, ask for them with your quotation and treat the marks as the factory's statement. The register of what exists per family and market is on documents and certification, and the United States equivalent of this question is answered in seasonal versus all-year string lights under UL 588.