76% of Lighting Products Sold Online in the EU Are Non-Compliant. What This Means if You Manufacture Lighting Equipment
In April 2026, LightingEurope published the results of its 2025 Online Mystery Shopper Exercise, a structured compliance verification covering seven EU countries and seven online marketplaces. The findings are difficult to read if you are a manufacturer who invests seriously in compliance.
Of 442 product offers analysed, 76% failed basic online information requirements. Of the 84 products physically inspected, 95% were non-compliant. Of the 9 products sent to an accredited laboratory for safety testing, all 9 failed. Every single one.
The full report is available directly from LightingEurope. This article provides the regulatory context behind those numbers, explains what the exercise measured and what it did not, and sets out what compliant manufacturers and importers need to have in place.
What the Exercise Actually Measured
The mystery shopper methodology was built around what can be verified without opening a technical file. Trained volunteers searched seven platforms across France, Germany, Italy, the Netherlands, Poland, Romania, and Sweden, checking product listings and, for a subset of products, physical packaging and documentation.
Two product categories were assessed: R7s lamps and self-contained emergency luminaires. The online inspection checked for the presence of mandatory information including the CE mark, the energy label, the product identifier, the manufacturer’s name and address, and WEEE registration in the countries where national registries are public. Physical inspection checked the same requirements on packaging and product markings. Safety testing was conducted by an independent accredited laboratory under EN 60598-2-22, the harmonised standard for emergency lighting under the Low Voltage Directive.
Understanding the scope of the exercise matters, because it defines the boundaries of what the numbers actually tell us.
The Real Picture Is Probably Worse: RoHS Was Not in Scope
The LightingEurope exercise did not assess compliance with the RoHS Directive (2011/65/EU), which restricts the use of hazardous substances in electrical and electronic equipment. RoHS applies to virtually all lighting products with electronic components — including LED lamps, electronic drivers, and luminaires with control circuits and batteries.
RoHS was not excluded because products comply with it. It was simply outside the scope of the exercise, which focused on information and labelling requirements and safety performance under LVD. Verifying RoHS compliance requires access to the technical documentation and supply chain substance declarations, not a product listing or a packaging check.
The implication is straightforward: the non-compliance rates reported by LightingEurope reflect only what was measured. The overall compliance picture for products sold through online marketplaces in the EU is likely considerably worse than the published numbers suggest.
What Regulations Are Being Broken — and What Each Requires
The exercise identified non-compliance across multiple regulatory frameworks simultaneously. For manufacturers and importers selling lighting products in the EU, these are the obligations that must be met:
Low Voltage Directive (LVD) 2014/35/EU. Applies to electrical equipment operating within specified voltage ranges. Requires conformity assessment, a technical documentation file, an EU Declaration of Conformity, and CE marking. The safety testing in the LightingEurope exercise was conducted under this directive. All tested products failed.
Ecodesign Regulation (EU) 2019/2020. Sets minimum energy efficiency requirements for light sources. LED-based R7s lamps within scope must meet performance thresholds. Halogen R7s lamps above 2700 lumen are no longer permitted on the market except under specific exemptions. The exercise found products that did not meet these requirements on the market regardless.
Energy Labelling Regulation (EU) 2017/1369 and Regulation (EU) 2019/2015. Requires registration in the EPREL database and display of the correct energy label in online offers and on packaging. Of the R7s lamp offers analysed, 77% carried an energy label online, but 53% of those labels did not match any existing EPREL entry. At physical inspection, 93% of R7s lamps had no energy label at all. Several emergency luminaire offers, which are exempt from energy labelling, carried fake energy labels with QR codes that led nowhere or linked to entirely different products such as refrigerators.
WEEE Directive (EU) 2012/19. Requires manufacturers to register with national WEEE schemes and contribute to end-of-life collection and recycling costs. For 47% of the emergency luminaire offers checked, no registration could be found in the national WEEE register of the targeted country, despite registration being mandatory there.
General Product Safety Regulation (EU) 2023/988. Requires manufacturers to ensure products are safe, to provide safety information, and to designate an EU Responsible Person for non-EU manufacturers. The exercise checked for the presence of seller and manufacturer information as mandated by GPSR. Many products failed to provide the required details.
RoHS Directive 2011/65/EU. Restricts the use of lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs, and four additional phthalates in electrical and electronic equipment. Compliance must be demonstrated through supplier declarations and technical documentation. As noted above, this was not assessed in the exercise.
Why Emergency Lighting Is a Special Case
Self-contained emergency luminaires are not a commodity product category. They are safety-critical equipment installed in buildings across the EU to guide occupants to exits during fires and emergencies. Compliance with the Workplace Directive (89/654/EEC) and the Signs Directive (92/58/EEC) depends in part on these products functioning as specified under the relevant standards.
The two most critical tests in the laboratory assessment were the glow-wire test and the photometric test. The glow-wire test verifies fire resistance: the product must not ignite when exposed to a heated wire simulating electrical fault conditions. Any flame must extinguish within 30 seconds of the wire being withdrawn. A luminaire that fails this test may itself become a source of ignition in the very emergency it is meant to address.
The photometric test verifies that the luminance and colour contrast of exit signs meet the thresholds required for visibility under degraded conditions, including smoke-filled environments. A product that passes visual inspection but fails photometric testing may be indistinguishable from a compliant product in normal conditions and invisible precisely when it matters most.
All 9 products tested failed both categories. These were products available for purchase on mainstream European online marketplaces, some of them promoted by the platforms themselves.
The Competitive Damage to Compliant Manufacturers
LightingEurope reports that some of its members invest up to 25% of annual turnover in compliance. This investment covers testing, technical documentation, EPREL registration, WEEE scheme membership, and ongoing monitoring of regulatory requirements.
A manufacturer that meets all of these obligations competes in the same online marketplace against sellers whose products carry none of these costs. The price difference is not a reflection of product quality or efficiency, it is the financial benefit of non-compliance. At scale, across thousands of product offers and multiple platforms, this creates a structural distortion in the market that disadvantages every manufacturer who follows the rules.
The problem is not limited to small or obscure sellers. The exercise found 37 non-compliant products across two different marketplaces that were actively sponsored by the platforms themselves.
A Compliance Checklist for Lighting Products
For manufacturers and importers placing lighting products on the EU market, the following obligations apply cumulatively. Each must be addressed independently — compliance with one does not substitute for compliance with another.
LVD compliance: conformity assessment, technical documentation file, EU Declaration of Conformity, CE marking
Ecodesign compliance: product meets minimum performance requirements under EU 2019/2020; halogen lamps above thresholds verified against applicable exemptions
Energy labelling: product registered in EPREL; correct energy label displayed in online listings and on packaging; label matches EPREL entry
WEEE registration: manufacturer or importer registered with the national WEEE scheme in each EU member state where the product is sold
GPSR compliance: EU Responsible Person designated and identified on product or packaging; safety information provided; incident reporting process in place
RoHS compliance: substance restrictions verified for all restricted substances; supplier declarations obtained for components and materials; documented in technical file
For CE marking under LVD specifically, the applicable harmonised standards for the product category must be identified and applied. For emergency luminaires, this means EN 60598-2-22 and EN 1838. For R7s lamps, the applicable standards depend on the lamp type and intended use.
The CE Marking section of this site provides structured information on the main regulatory frameworks applicable to electrical and electronic products in the EU.
How GetReady Compliance Can Help
Lighting products sit at the intersection of multiple EU regulatory frameworks — LVD, Ecodesign, Energy Labelling, WEEE, GPSR, and RoHS — each with its own conformity assessment requirements, documentation obligations, and registration processes. Managing all of these from outside the EU, without prior experience of the European regulatory system, is a process where gaps are easy to create and costly to correct.
GetReady Compliance supports manufacturers at every stage of the compliance process for lighting products, from regulatory scoping and harmonised standard identification through to technical documentation, EU Responsible Person services, and WEEE registration coordination.
For laboratory testing, we work with a trusted Spanish partner laboratory that has specialised in lighting products for many years. This partnership means we can manage the full compliance process — from documentation to physical testing — through a single coordinated engagement, without manufacturers having to identify and qualify a testing laboratory independently.
If you are assessing your compliance obligations for lighting products sold in the EU, request a quote for a product-specific discussion.
