Background
LED (Light Emitting Diode) is a two-terminal Light source for most of the modern Lighting products. It works on the principle of Electro-luminescence. LED`s are fabricated using Direct bandgap semiconductor materials only. It has basically two terminals Anode (+Ve) and Cathode (-Ve). It operates as a light source only in Forward bias and emits light when recombination of electron takes place at junction. LED Lighting is also known as solid-state lighting (SSL).
LED Module & Luminaires
Independent LED modules are unit supplied as light source which can be mounted or placed separately from a luminaire. It will be covered under CRS scheme of BIS as per IS 16103-1 the international standard of the same is (IEC / EN 62031). Whereas LED luminaires is a combination of LED module (as a Light source), Mechanical, electrical, optical accessories and control-gear. Sometimes LED module and drivers are integrated with Luminaire. In such case luminaire is tested as per applicable standard to that luminaire. In some cases, LED ballast/driver circuit are integrated with LED module and such modules are classified as class 1 or class 2 type. And other type of LED module operating at SELV voltage are classified as class 3 type.
LED luminaires are already covered in CRS scheme of BIS are-
o IS 10322-5-1(Fixed General-Purpose LED Luminaire)
o IS 10322-5-2(Recessed LED Luminaire)
o IS 10322-5-3(LED Luminaires for Road and Street Light)
o IS 10322-5-5(LED Flood Lights)
o IS 10322-5-6(LED Hand Lamps)
o IS 10322-5-7(LED Lighting Chain)
o IS 10322-5-8(Emergency LED Luminaire)
o IS 10322-5-9(LED Rope Lights)
o IS 16103-1(LED Module)
o IS 16102-1(LED Bulb)
Note: Under IS 10322-5-1 there are two types of luminaires covered, the manufacturer needs to take separate Registration number for both types (Fancy & Non-Fancy)
(a) Non- Fancy Type: i.e., Bay lights, Well glass, Bulkhead, Batten etc.
(b) Fancy Type: Chandeliers and similar Decorative LED Luminaires etc.
According to IS 16103-1 LED module are categorised into 3 parts as per method of installation-
- Independent LED module: Those are sold in market as product or replacement part of luminaire.
2. Built-In LED module: Replaceable part of luminaire
3. Integral LED module: Non-Replaceable part of the luminaire which is defined in IS 10322-1. Will be treated as part of Luminaire.
In the market we may find a variety of LED module like Ambient LED module for indoor luminaires, Downlight LED modules for spotlights and downlights, outdoor LED modules they come with some IP protection and some provision of heat dissipation, Industrial LED modules usually come with higher Luminous efficacy and operating voltage. Depending upon availability, LED modules manufacturers to make their luminaires. A LED module may have a single LED package in the form of a COB LED to multiple LED packages depending upon the desired rating and LED technology.
IS 16103-1 mostly refers to IS 15885-1, IS 15885-2-13 & IS 10322-1 for the requirements of safety testing.
Impacted Products due to LED module.
The LED module can transform itself into a luminaire rapidly with lesser R&D and manufacturing time. Many standards LED products like Modular Lighting, Liner light, Cleanroom, spotlight, Downlight fittings etc. uses LED module which is normally being imported as a complete product. So, mandating LED module under CRO Phase 4 will impact such products.
The proliferation of LED fixtures with LED module is very easy and time saving for the manufacturer. They need to take care of only series-parallel connections of modules, Heat management, enclosure design, assuring suitable power to LED module by means of control gear & using suitable lens/diffuser for the desired optical requirement as per application. So, the module becomes important to regulate to ensure a quality product.
As of now most of the LED manufacturers are importing LED Package integrated with MCPCB (i.e., as LED module) by which they are saving import duty on PCB as importing LED is duty-free. The government was losing revenue at one hand and cheap quality goods are being imported without any regulatory requirement at other hand. So, mandating this product (LED Module) certainly will improve product quality and government revenue.
On 1st April 2020 MEITY has released notification for CRS scheme (CRO Phase 4) in which “Standalone LED Module for General Lighting” which is changed to “Independent LED Module for General Lighting” later and date of implementation of the order is 1st April 2021.
The meaning of Standalone (the products being imported /sold/manufactured as independent product) is already clarified by MEITY through FAQ at official website. This gazette will not have any additional meaning specific to this product (LED Module).
DGFT’s Import Policy
With the approval of Ministry of Commerce & Industry Directorate General of Foreign Trade (DGFT) has released a notification dated 17th Sep 2020 which added new import policy condition in ITC(HS) 2017 Schedule-1 for import of LED Products and DC, or AC supplied electronic control gear for LED module.
- LED Products and DC, or AC supplied electronic control gear for LED module Notified under CRS scheme of BIS will be picked up on random basis from randomly selected consignments and will be sent to BIS recognized Labs for limited non-destruction safety parameter testing as per applicable IS of that product.
- Clearance of such consignment would be given only if product complied to respective IS.
- If product fails in non-destructive testing for defined parameters consignment will be sent back or destroyed at the cost of importer.
Under this provision BIS recognized lab may do short duration compliance test which are normally related to classification of Luminaire, marking label durability testing, construction, external and internal wiring & Stability, Provision of earthing, Input test (ratings measurement) & photometry (if applicable) etc.
LED Products which NOT covered in CRS-BIS
It is evident that at present no Indian Standard is available for the Ground Recessed LED Luminaires (IEC 60598-2-13) & Swimming Pool Luminaires (IEC 60598-2-18). Many of the overseas brand has market of those products in India. Such importers/stakeholders find themselves difficult while importing such products at customs if all relevant technical document including IEC reports are not available to justify it as an Exempted product. There are many instances where such consignments are held at customs, seeking BIS certificate. But on other hand as per BIS officials “the subject is under consideration with concerned technical committee and in future standards may be available on the subject”. To end this deadlock, this became the onus of BIS/MeitY that for the time being they must clarify it through official public notification.
MeitY, kept a provision for applying an exemption certificates for any product covered in CRS order, where importer must provide technical details of product with model numbers, and other legal documents. after evaluation of it MeitY may provide exemption for a particular period for selected models.
Further certain other product categories like Stage Luminaire, Photo and film Luminaires, Hospital Luminaires etc. are special purpose LED luminaire which are not covered in CRS-BIS.
BIS has already clarified in official FAQ regarding Portable Luminaire, Luminaires under IS 10322 with battery (except Emergency Luminaire) that they are exempted from the order. However there is no clarity on LED Lamp(Bulb) with battery as it is not under IS 10322, OEM’s of LED Emergency bulb can approach BIS for technical clarity on the subject.
During COVID 19 many types of UV LED based Luminaires were launched in market and most common type was hybrid luminaires (with Normal LED and UV-C LED which can function as a normal luminaire as well as an upper room UV luminaire. so far, a standard test methodology is not available in India, so such products are not covered by BIS. Though use of UV light as disinfectant is not new but use of LED in this segment is at nascent stage. Low efficacy is most common issue with such products. Since this is a new and dynamic technology, so there is a requirement of standard for LED products. Further Lighting product with Non-LED technology (Halogen lamp, Fluorescent lamp, candescent lamp etc.) are also not covered in CRS.
There are solar based LED products available in market i.e., solar streetlight. The integral parts of such luminaires are SPV module (IS/IEC 61730-1, IS 61730-2), Charge controller (IEC 62093), Battery (IS 16270/IS 16046), LED Module (IS 16103-1) etc. certification required in BIS as per their respective standards. However, a Solar LED luminaire with integrated SPV module is not covered.
Further certain modular lighting products with abnormal shape and size and rating may be exempted due to test fiscality limitation or HSE criteria defined by MeitY.