Guidance on LED Tube Lights Testing According to QCVN 19:2019/BKHCN in Vietnam

Currently, many low-quality LED Tube products are still circulating on the market. This poses potential risks of electrical insecurity, energy waste, and actual lifespans much lower than declared. In this context, LED Tube Lights Testing according to QCVN 19:2019/BKHCN is not only a mandatory regulation but also an opportunity for enterprises to affirm quality, enhance brand reputation, and accompany the sustainable lighting orientation in Vietnam.

See more: Capacity Profile Of Phuc Gia Laboratory Corporation

Table of contents

I. LED TUBE LIGHTS USAGE IN VIETNAM

LED Tube Lights are widely applied in offices, schools, hospitals, commercial centers, and factories. Replacing fluorescent lamps with LED types, especially LED Tubes, helps reduce electricity consumption by 50–70%. This product is favored for use in home living and working spaces, especially in areas requiring continuous lighting such as kitchens, garages, or study rooms, thanks to its stable, flicker-free, and health-friendly lighting capabilities.

However, this rapid development also brings challenges regarding product quality. Not a few low-quality, originless LED Tube products are floating on the market. This poses risks regarding electrical safety, low efficiency, or lifespans much lower than declared. This is one of the reasons why state management agencies are tightening requirements for LED Tube Lights Testing, certification, declaration of conformity, and energy labeling for LED Tubes to ensure safety for consumers and ensure market transparency.

Along with the orientation of energy saving and emission reduction, the system of legal documents such as QCVN 19:2019/BKHCN, Decision No. 14/2023/QD-TTg, Decision 04/2017/QD-TTg, etc., has formed a clear legal framework, mandating that LED Tube products must undergo LED Tube Lights Testing for electrical safety, electromagnetic compatibility, and energy efficiency. This is both a challenge and an opportunity for enterprises to improve product quality and affirm their prestige in the Vietnamese lighting market.

II. CURRENT REGULATIONS APPLIED FOR TESTING – CERTIFICATION OF LED TUBE LIGHTS BY THE MINISTRY OF SCIENCE AND TECHNOLOGY

– Circular No. 08/2019/TT-BKHCN: Circular promulgating the “National Technical Regulation on LED Lighting Products” issued on September 25, 2019 (This Circular took effect from December 31, 2019);

– QCVN 19:2019/BKHCN: National Technical Regulation on LED Lighting Products (QCVN 19:2019/BKHCN issued with Circular No. 08/2019/TT-BKHCN);

– Decision No. 1383/QD-BKHCN: Correction of National Technical Regulation QCVN 19:2019/BKHCN regarding LED Lighting products;

– Decision No. 2711/QD-BKHCN: LED Lamps regarding the Announcement of Group 2 Products and Goods under the Management Responsibility of the Ministry of Science and Technology issued on December 30, 2022;

– Decision No. 367/QD-BKHCN: On Amending and Supplementing the Group of LED Lighting Products in Decision No. 2711/QD-BKHCN;

– Circular No. 28/2012/TT-BKHCN: Regulations on declaration of standard conformity, declaration of technical regulation conformity, and methods for assessing conformity with standards and technical regulations;

– Circular No. 02/2017/TT-BKHCN: Amending Circular No. 28/2012/TT-BKHCN regulating the declaration of standard conformity, declaration of technical regulation conformity, and methods for assessing conformity with standards and technical regulations;

– Circular No. 07/2018/TT-BKHCN: Amendment 1:2018 QCVN 9:2012/BKHCN National Technical Regulation on Electromagnetic Compatibility for household electrical and electronic equipment and similar purposes;

– Circular No. 06/2020/TT-BKHCN: Guiding and implementing measures for Decree No. 132/2008/ND-CP, 74/2018/ND-CP, 154/2018/ND-CP, and 119/2017/ND-CP issued by the Minister of Science and Technology;

– Circular No. 01/2022/TT-BKHCN: Amending Circular 07/2018/TT-BKHCN and 08/2019/TT-BKHCN;

– Technical requirements of QCVN 19:2019/BKHCN for LED Tube Lights: TCVN 11846:2017 (IEC 62776:2014) – Double-capped LED Lamps – Safety Specifications.

When exporting, importing, or manufacturing LED Tube Lights, enterprises must not only comply with mandatory technical regulations such as quality, energy efficiency, declaration of conformity, and state inspection of goods quality but also comply with regulations on taxes and fees according to current regulations.

III. GUIDANCE ON LED TUBE LIGHTS TESTING ACCORDING TO QCVN 19:2019/BKHCN IN VIETNAM

1. Which types of LED Tube Lights must perform testing and declaration of conformity according to QCVN 19:2019/BKHCN?

LED Tube Lights are mandatory for LED Tube Lights Testing and conformity certification according to QCVN 19:2019/BKHCN when they meet the following 3 conditions:

(1) Based on item 10 in the Appendix of Decision No. 367/QD-BKHCN on Amending and Supplementing the Group of LED Lighting Products in Decision No. 2711/QD-BKHCN, LED Tube Lights with HS code 8539.52.90 must undergo LED Tube Lights Testing and conformity certification according to QCVN 19:2019/BKHCN;

(2) Not falling under the cases specified in Clause 1, QCVN 19:2019/BKHCN:

LED lighting equipment on transport vehicles as regulated in QCVN 35:2017/BGTVT;

Lighting equipment in lighting projects as regulated in QCVN 07-7:2016/BXD;

Lighting equipment in outdoor advertising media as regulated in QCVN 17:2018/BXD.

(3) Based on TCVN 11846:2017 (IEC 62776:2014), double-capped LED lamps with G5 and G13 caps, designed to replace fluorescent lamps with the same caps, having a rated power up to 125 W and a rated voltage up to 250 V.

2. When is it mandatory for enterprises to perform LED Tube Lights Testing according to QCVN 19:2019/BKHCN?

“LED lighting products (LED Tube Lights, LED Bulbs, LED street lights, LED Floodlights, etc.) in the Appendix of this Technical Regulation must declare conformity with technical regulations, be affixed with the conformity mark (CR mark), and have goods labeling before being circulated on the market” (Article 3 – Management Requirements – Circular 08/2019/TT-BKHCN).

Accordingly, enterprises are mandatory to perform LED Tube Lights Testing according to QCVN 19:2019/BKHCN when wishing to bring products into circulation on the market. The application includes 2 stages (based on Decision No. 1383/QD-BKHCN) as follows:

Stage 1: From January 1, 2021, LED lamps must meet the requirements for safety and electromagnetic interference (EMI, ES) limits.
Stage 2: From January 1, 2022, LED lamps must additionally meet the requirements for photobiological safety and electromagnetic immunity (EMI, ES).

The LED Tube Lights Testing to serve the declaration of conformity and conformity certification for LED Tubes must be performed by testing organizations designated under the provisions of Decree No. 107/2016/ND-CP, Decree No. 154/2018/ND-CP, or recognized under the provisions of Circular No. 27/2007/TT-BKHCN (The testing scope of the testing organization must meet the requirements of this Technical Regulation.)

3. Technical Requirements for LED Tube Lights

QCVN 19:2019/BKHCN stipulates technical requirements for Electrical Safety (ES); Electromagnetic Interference (EMI); Electromagnetic Immunity (EMS), and Photobiological Safety (PBS). Accordingly, LED Tube Lights must undergo LED Tube Lights Testing in accordance with TCVN 11846:2017 (IEC 62776:2014).

(1) Labeling requirements for LED Tube Lights (See details here);

(2) Interchangeability requirements (Including the interchangeability of lamp caps, mass, dimensions, temperature, and lamp safety in cases of incorrect starter-lamp combinations);

(3) Safety requirements for pins during lamp insertion (Verification of compliance through tests such as Dielectric Strength, Insulation Resistance, Creepage distances, and Clearances);

(4) Protection against accidental contact with live parts (Testing to determine conductive parts that may cause electric shock during operation, Insulation Resistance, Dielectric Strength);

(5) Mechanical requirements for lamp caps (Including construction and assembly requirements, torque testing on unused lamps, torque testing after heat treatment, and after mechanical strength testing; samples must comply with accessibility requirements);

(6) Temperature rise requirements for lamp caps (Temperature rise of the lamp cap is checked using the test arrangement specified in Annex B of TCVN 5175 – IEC 61195);

(7) Heat resistance requirements (After testing, the indentation diameter and measured value must not exceed 2 mm. In the case of curved surfaces, measure the shorter axis if the indentation is elliptical);

(8) Resistance to fire and ignition (Parts of insulating material retaining live parts in position and external parts of insulating material providing protection against electric shock must undergo the glow-wire test according to TCVN 9900-2-10 (IEC 60695-2-10) and TCVN 9900-2-11 (IEC 60695-2-11));

(9) Fault condition requirements (Ensuring safety when operating under fault conditions that may occur in intended use, such as extreme electrode conditions, short-circuiting of luminaire control gear, etc.);

(10) Creepage distance and clearance requirements: Apply the requirements of IEC 61347-1 along with the following additional requirements: IEC 60061-4 (Minimum creepage distance between contact pins or contacts and the metal shell), IEC 61347-1 (other parts of the lamp), IEC 61347-1 (accessible conductive parts (excluding the cap) for double or reinforced insulation).

(11) Photobiological safety requirements (UV radiation, Blue light hazard, Infrared radiation);

(12) Protection against dust and moisture (Thermal endurance, IP Testing).

Strict compliance with technical requirements and conducting LED Tube Lights Testing according to the above standards is mandatory for manufacturing and importing enterprises to circulate LED Tube Lights on the market. To understand the testing and conformity certification process under current regulations, enterprises can contact Phuc Gia for detailed advice and professional support.

4. Cost and Time for LED Tube Lights Testing According to QCVN 19:2019/BKHCN

The costs and time required for Electrical Safety and Electromagnetic Compatibility testing for LED Tube Lights according to QCVN 19:2019/BKHCN are publicly listed by Phuc Gia. You can view the testing price list for telecommunications and information technology products at the Quotation for Testing and Certification Services or contact Phuc Gia for detailed advice.

5. Where to Perform Regulatory LED Tube Lights Testing According to QCVN 19:2019/BTTTT?

5.1. Regulations on Qualified Testing and Certification Units

Based on Article 5 of Consolidated Document 02/2020/VBHN-BTTTT, the testing units serving certification and declaration of conformity are regulated as follows:

The testing unit serving conformity certification activities must be a designated or recognized testing unit.

The testing unit serving conformity declaration activities must be a designated or recognized testing unit, or a unit that has registered testing activities according to Decree No. 107/2016/NĐ-CP dated July 1, 2016, of the Government stipulating the conditions for providing conformity assessment services.

Testing units must be responsible before the competent authorities for the accuracy of testing results. Testing results do not replace the Certificate of Conformity or the Declaration of Conformity.

Circular No. 02/2024/TT-BTTTT stipulates: “Measurement/testing results from domestic or foreign testing laboratories that have not been designated or recognized, or measurement/testing results from manufacturers, shall not be used to assess conformity with this technical regulation.”

Accordingly, the testing and conformity certification for Electrical Safety and Electromagnetic Compatibility for LED lighting technology products (LED Tube Lights, LED Bulbs, LED street lights, LED Floodlights, etc.) according to QCVN 19:2019/BKHCN must be performed by testing organizations Designated or Recognized by Ministries and sectors.

5.2. PHUC GIA – A Prestigious Testing and Certification Body in Vietnam

Phuc Gia Lab is a multi-disciplinary organization operating in the electrical and electronic fields, including technical criteria for electrical safety and electromagnetic compatibility (EMC) for LED lighting technology products in accordance with the national technical regulation QCVN 19:2019/BKHCN. Customers can view more details in the designation decisions and certificates of registration for operations below:

SUMMARY TABLE OF DECISIONS AND CERTIFICATES FROM THE MINISTRY OF SCIENCE AND TECHNOLOGY FOR PHUC GIA®

ORD	Certificate No.	Date of Issuance	Issuing Authority	Field of Operation
1	3084/TĐC-HCHQ	18/9/2020	Commission for the Standards, Metrology and Quality of Vietnam – Ministry of Science and Technology	Testing for multi-disciplinary integration in the electrical – electronic field
2	2483/QĐ-TĐC	25/12/2020	Commission for the Standards, Metrology and Quality of Vietnam – Ministry of Science and Technology	Testing of technical criteria for electrical safety and electromagnetic compatibility (EMC) for LED lighting technology products
3	2242/TĐC-HCHQ	16/7/2021	Ministry of Science and Technology	Testing for multi-disciplinary integration in the electrical – electronic field
4	1951/QĐ-TĐC	28/10/2021	Commission for the Standards, Metrology and Quality of Vietnam – Ministry of Science and Technology	Testing of technical criteria for electrical safety and electromagnetic compatibility (EMC) for LED lighting technology products
5	3206/TĐC-HCHQ	28/10/2021	Ministry of Science and Technology	Testing for multi-disciplinary integration in the electrical – electronic field
6	3851/TĐC-HCHQ	30/12/2022	Ministry of Science and Technology	Certification of products and goods in accordance with standards and national technical regulations under Method 1
7	2117/QĐ-TĐC	13/12/2022	Commission for the Standards, Metrology and Quality of Vietnam – Ministry of Science and Technology	Testing of technical criteria for electrical safety and electromagnetic compatibility (EMC) for LED lighting technology products, Electromagnetic Interference (EMI) for LED lamps/ self-ballasted lamps and lighting equipment
8	3617/TĐC-HCHQ	13/12/2022	Ministry of Science and Technology	Testing for multi-disciplinary integration in the electrical – electronic field

Specifically, Phuc Gia is a designated organization authorized to perform testing and certification in the electrical and electronic fields with a diverse scope, including:

Electrical Safety: Luminaires for general purposes (fixed – recessed), Luminaires for road and street lighting, Portable general-purpose luminaires, Floodlights, Self-ballasted LED lamps for general lighting services working at voltages > 50V, Double-capped LED lamps designed to replace linear fluorescent lamps;
Photobiological Safety: Lamps and lamp systems;
Electromagnetic Compatibility (EMC) for electrical and electronic household appliances and similar purposes using 1-phase input power, with a rated input current limit ≤ 32A: Electric motor-operated hand-held drills, Vacuum cleaners, Refrigerators, freezers, Air conditioners, Hair dryers, Blenders, meat grinders, juicers, egg beaters, Electric stoves (including induction hobs), Instantaneous water heaters, Washing machines/ Clothes dryers, Microwave ovens (including combination types);
Electromagnetic Interference (EMI): LED lamps/ Self-ballasted lamps and lighting equipment;
Electromagnetic Immunity (EMS): General lighting equipment.

IV. TESTING FACILITIES FOR LED TUBE LIGHTS AT PHUC GIA

Phòng Thử Nghiệm EMS - Trung Tâm Thử Nghiệm Kiểm Định Phúc Gia — EMS Testing Room – Phuc Gia®

Phòng Thử Nghiệm EMI - Trung Tâm Thử Nghiệm Kiểm Định Phúc Gia — EMI Testing Room – Phuc Gia®

Phòng Thử Nghiệm Hiệu Suất Năng Lượng - Trung Tâm Thử Nghiệm Kiểm Định Phúc Gia — Energy Efficiency Testing Room – Phuc Gia®

Phòng Thử Nghiệm An Toàn Quang Sinh Học – Trung Tâm Thử Nghiệm Kiểm Định Phúc Gia — Photobiological Safety Testing Room – Phuc Gia®

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Phòng Thử Nghiệm Quang Học - Trung Tâm Thử Nghiệm Kiểm Định Phúc Gia — Optics Testing Room – Phuc Gia®

Phòng Thử Nghiệm IP - Trung Tâm Thử Nghiệm Kiểm Định Phúc Gia — IP Testing Room –Phuc Gia®

Trung Tâm Chứng Nhận Phúc Gia — Phuc Gia Certification Center

In particular, to assist customers and partners in finding the address of the Phuc Gia® Inspection & Testing Center most easily, we invite our partners and customers to refer to the directions to Phuc Gia below!

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