Guidance on Testing for Fixed Recessed LED Luminaires According to QCVN 19:2019/BKHCN

Fixed Recessed LED Luminaires are popular lighting fixtures used in civil and commercial projects, meeting the demand for efficient and energy-saving lighting. Due to the specific nature of being fixedly installed and connected directly to the power source, adherence to safety regulations, Electromagnetic Compatibility (EMC), and other management requirements is critically important before introducing the product to the market.

According to Decision No. 367/QĐ-BKHCN of 2024, enterprises manufacturing and importing Fixed Recessed LED Luminaires must perform electrical safety and EMC Testing for Fixed Recessed LED Luminaires in accordance with QCVN 19:2019/BKHCN. Below is the key information that Phuc Gia® has compiled regarding Testing for Fixed Recessed LED Luminaires according to QCVN 19:2019/BKHCN, aimed at helping enterprises clearly understand the technical requirements and prepare the appropriate documentation during the process of manufacturing, importing, and circulating the product.

See more: Capacity Profile Of Phuc Gia Laboratory Corporation

I. Market Overview: Fixed Recessed LED Luminaires in Vietnam

Fixed Recessed LED Luminaires are rapidly gaining traction across various sectors in Vietnam, including residential, commercial complexes, offices, and public facilities like schools and hospitals. Their appeal lies in their energy efficiency, long service life, and aesthetic value, particularly for seamless integration into false ceilings.

The Vietnamese market offers a diverse range of these luminaires, featuring various styles, power outputs, and color temperatures, sourced from both domestic and international manufacturers. This proliferation directly benefits consumers through energy savings and enhanced lighting stability and safety. Consequently, the government has imposed stringent requirements for electrical safety, Electromagnetic Compatibility (EMC), and mandatory Testing for Fixed Recessed LED Luminaires to ensure strict regulatory compliance prior to manufacturing, import, or market circulation.

II. Guidance on Testing for Fixed Recessed LED Luminaires According to QCVN 19:2019/BKHCN

1. Scope of Application

Fixed Recessed LED Luminaires must obtain mandatory conformity certification (hợp quy) according to QCVN 19:2019/BKHCN when meeting both of the following two conditions:

(1) Based on Decision 367/QĐ-BKHCN of 2024 (amending the group of LED lighting products in Decision 2711/QĐ-BKHCN), Fixed Recessed LED Luminaires must undergo testing and conformity certification according to QCVN 19:2019/BKHCN when falling under one of the following three HS codes:

• 9405.11.91
• 9405.11.99
• 9405.21.90

(2) The product must not fall under the specific exemptions stipulated in Clause 1 of QCVN 19:2019/BKHCN:

• LED lighting equipment on transport vehicles (regulated by QCVN 35:2017/BGTVT);
• Lighting equipment in construction works (regulated by QCVN 07-7:2016/BXD);
• Lighting equipment in outdoor advertising means (regulated by QCVN 17:2018/BXD).

2. Technical Requirements for Fixed Recessed LED Luminaires

QCVN 19:2019/BKHCN stipulates technical requirements covering Electrical Safety (ES); Electromagnetic Interference (EMI); Electromagnetic Susceptibility (EMS); and Photobiological Safety (PBS). Accordingly, Fixed Recessed LED Luminaires must undergo testing according to the following standards:

• TCVN 7722-1:2017 (IEC 60598-1:2014): General requirements and testing for luminaires;
• TCVN 7722-2-2:2007 (IEC 60598-2-2:2002): General requirements and testing for recessed luminaires (Part 2-2);
• TCVN 7722-2-13:2013 (IEC 60598-2-13:2012): Specific requirements for luminaires recessed into the ground (Part 2-13);
• TCVN 4255:2008 (IEC 60529:2001): Regulations on Degrees of protection provided by enclosures (IP Code).

Note: These standards specify requirements for Fixed Recessed LED Luminaires intended for use with incandescent lamps, tubular fluorescent lamps, and other discharge lamps with a supply voltage not exceeding 1000 V.

See more: Electrical Safety (ES) Test Report for Fixed Recessed LED Luminaires – QCVN 19:2019/BKHCN

Strict compliance with the technical requirements and conducting testing according to the above standards is a mandatory requirement for enterprises manufacturing and importing Fixed Recessed LED Luminaires to circulate their products in the market.

3. When is Enterprise Testing Mandatory According to QCVN 19:2019/BTTTT?

(Note: The technical regulation is QCVN 19:2019/BKHCN)

Based on Article 3 (Management Requirements) of Circular No. 08/2019/TT-BKHCN, “LED lighting products listed in the Appendix of this Technical Regulation must declare conformity, affix the conformity mark (CR mark), and label the goods before circulation in the market.” Accordingly, enterprises are mandatorily required to perform Testing for Fixed Recessed LED Luminaires according to QCVN 19:2019/BKHCN when intending to circulate the product in the market.

The mandatory application was implemented in two phases:

• Phase 1: From January 1, 2021, LED Luminaires must meet requirements for safety and electromagnetic interference limits (ES, EMI).
• Phase 2: From January 1, 2023, LED Luminaires must additionally meet requirements for photobiological safety and electromagnetic susceptibility (PBS, EMS).

Testing to serve the Declaration of Conformity and Conformity Certification for LED Luminaires must be performed by testing organizations that are designated according to Decree No. 107/2016/NĐ-CP, Decree No. 154/2018/NĐ-CP, or recognized according to Circular No. 27/2007/TT-BKHCN (the testing scope of the organization must satisfy the requirements stipulated in this Technical Regulation.)

4. Cost and Time for Testing for Fixed Recessed LED Luminaires According to QCVN 19:2019/BKHCN

The cost and time for Electrical Safety and Electromagnetic Compatibility Testing for Fixed Recessed LED Luminaires according to QCVN 19:2019/BKHCN are publicly listed by Phuc Gia. Customers can view the quotation for testing household, office, lighting, telecommunications, and IT products on the Quotation for Testing/Certification Services page or contact Phuc Gia for detailed consultation.

5. Where to Perform Testing for Fixed Recessed LED Luminaires According to QCVN 19:2019/BKHCN?

5.1. Regulations on Qualified Testing and Certification Units

The testing and conformity certification for Electrical Safety and Electromagnetic Compatibility for LED lighting products (such as Fixed Recessed LED Luminaires, LED Bulbs, LED Tubes, LED Street Lights, LED Flood Lights, etc.) according to QCVN 19:2019/BKHCN must be performed by testing organizations designated or recognized by relevant Ministries.

Circular No. 06/2020/TT-BKHCN guides the implementation and measures for Decree No. 132/2008/NĐ-CP, Decree No. 74/2018/NĐ-CP, Decree 154/2018/NĐ-CP, and Decree No. 119/2017/NĐ-CP, which stipulate:

Certification, inspection, and testing organizations performing certification, inspection, and Testing for Fixed Recessed LED Luminaires (Group 2 products) are those that have registered or been recognized under legal provisions, or those that are designated according to Decree No. 132/2008/NĐ-CP, as amended and supplemented by Decree No. 74/2018/NĐ-CP and Decree No. 154/2018/NĐ-CP.

5.2. Phuc Gia® – Reputable Testing and Certification Organization in Vietnam

Phuc Gia Laboratory Corporation has been designated by the Ministry of Science and Technology (MOST) as an organization authorized to conduct testing in the electrical and electronic sector, covering technical requirements for electrical safety and electromagnetic compatibility (EMC) for LED lighting products in compliance with the national technical regulation QCVN 19:2019/BKHCN under Decision No. 2899/QĐ-BKHCN.

Concurrently, Phuc Gia® has been granted Certificate of Registration for Certification Activities No. 3995/GCN-SKHCN by the Department of Science and Technology. Accordingly, Phuc Gia® is permitted to perform certification activities for electrical and electronic household products, office equipment, and lighting devices, including Fixed Recessed LED Luminaires according to QCVN 19:2019/BKHCN.

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

• Electrical Safety (ES): Common fixed luminaires (surface-mounted – recessed-mounted), street lighting luminaires, portable common luminaires, floodlights, self-ballasted LED lamps for general lighting operating at voltages greater than 50 V, and double-capped LED lamps designed to replace straight linear fluorescent lamps;
• Photobiological Safety (PBS): Lamps and lamp systems;
• Electromagnetic Compatibility (EMC): For household and similar electrical and electronic equipment using a single-phase supply with a rated input current 32 A;
• Electromagnetic Interference (EMI): LED Luminaires/Self-ballasted lamps and lighting equipment;
• Electromagnetic Susceptibility (EMS): General lighting equipment.

Furthermore, Phuc Gia Laboratory Corporation is the first unit to be accredited by all three major Vietnamese accreditation bodies (BoA, AOSC, VACI) as compliant with ISO/IEC 17025:2017. Phuc Gia® currently operates a testing facility spanning nearly 5,000 m², equipped with advanced measuring and inspection systems that fully meet the requirements for electrical safety, EMC, energy efficiency, RF, and other tests according to Vietnamese technical regulations. This is supported by over 100 highly trained engineers and technical experts, ensuring accuracy in every test result.

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III. Current Applicable Regulations for Fixed Recessed LED Luminaires

Regulations from the Ministry of Science and Technology (MOST):

– Decision No. 367/QĐ-BKHCN – On Amending and Supplementing the Group of LED Lighting Products in Decision No. 2711/QĐ-BKHCN, issued on December 30, 2024.

– Decision No. 2711/QĐ-BKHCN – On the Announcement of Group 2 Products and Goods under the Management Responsibility of the Ministry of Science and Technology (LED Luminaires), issued on December 30, 2022.

– Decision No. 1383/QĐ-BKHCN – Rectification of the National Technical Regulation QCVN 19:2019/BKHCN on LED lighting products, issued by MOST on May 22, 2020.

– Circular No. 08/2019/TT-BKHCN – Circular Promulgating the “National Technical Regulation on LED Lighting Products” (QCVN 19:2019/BKHCN), issued on September 25, 2019.

– Decision No. 1383/QĐ-BKHCN – Rectification of the National Technical Regulation QCVN 19:2019/BKHCN on LED lighting products, issued on May 22, 2019.

– Decision No. 3810/QĐ-BKHCN – Stipulating the announcement of Group 2 products and goods under the management responsibility of the Ministry of Science and Technology, issued on December 18, 2019.

– Circular No. 01/2022/TT-BKHCN – Amending Circulars 07/2018/TT-BKHCN and 08/2019/TT-BKHCN, issued on February 16, 2022.

– Circular No. 02/2017/TT-BKHCN – Amending Circular 28/2012/TT-BKHCN stipulating the declaration of conformity and methods for assessing conformity with technical standards and regulations.

– Decision No. 04/2017/QĐ-TTg – Stipulating the list of means and equipment required to affix energy labels, apply minimum energy performance levels, and the implementation roadmap, issued by the Prime Minister on March 9, 2017.

– Circular No. 28/2012/TT-BKHCN – On the Regulation of standard conformity declaration, technical regulation conformity declaration, and methods for assessing conformity with technical standards and regulations, issued on December 12, 2012.

– Technical Requirements of QCVN 19:2019/BKHCN for Fixed Recessed LED Luminaires: TCVN 7722-1:2017 (IEC 60598-1:2014/AMD1:2017) – Luminaires – Part 1: General requirements and tests) and TCVN 7722-2-2:2007 (IEC 60598-2) – Luminaires – Part 2-2: Particular requirements – Recessed luminaires.

Regulations from the Ministry of Industry and Trade (MOIT):

In addition to electrical safety (ES) and electromagnetic compatibility (EMC) testing according to QCVN 19:2019/BKHCN, enterprises manufacturing and importing LED lighting devices must comply with energy efficiency requirements according to TCVN 11844:2017. Furthermore, enterprises must regularly update the following legal documents:

– Decision No. 14/2023/QĐ-TTg – List and Roadmap for Equipment Using Energy That Must Be Phased Out, issued by the Prime Minister on May 24, 2023.

– Decision No. 1182/QĐ-BCT – Promulgating the list of imported goods (accompanied by HS codes) subject to specialized inspection under the management responsibility of the Ministry of Industry and Trade, issued on April 6, 2021.

– Decision No. 4889/QĐ-BCT – Announcing Technical Standards and Issuing Guidance on Energy Performance Declaration and Energy Labeling Applicable to the Energy Labeling Program for LED Lighting Products, issued by MOIT on December 27, 2018.

– Circular No. 36/2016/TT-BCT – Stipulating Energy Labeling, issued by MOIT on December 28, 2016.

When importing Fixed Recessed LED Luminaires, enterprises must not only comply with mandatory technical regulations such as quality, performance, conformity declaration, and state inspection of goods quality, but also adhere to regulations regarding taxes and fees under current law.

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