Certification of LED Lamps in Brazil

LED lamps are required to undergo certification procedures established by INMETRO in order to be allowed to be commercialized in Brazil.

Usage of LED Lamps in Brazil and Development of Regulations

LED lamps were introduced in recent years to the mainstream Brazilian market, and are expected to become one of the most widely adopted technologies for illumination in the country in the near future. This is due to the fact that the Brazilian government is actively pushing for its wide adoption as a way to increase the energy efficiency of local households. Some of the measures employed by Brazilian authorities to this end include the banning of the commercialization of some categories of lamps that employ older technologies, such as incandescent lamps.

With the expected increase in the number of brands offering LED lamps in Brazil, the country’s regulatory agencies developed specific certification procedures to ensure their compliance to national standards for safety of usage and power efficiency. The National Institute of Metrology, Quality and Technology, or INMETRO, is the institution responsible for establishing the directives for the certification of LED lamps in Brazil, and suppliers of LED lamps must undergo their certification procedure in order to be legally allowed to commercialize these products.

Product suppliers should be informed that the INMETRO certification procedure for LED lamps, as detailed in this article, is only applicable to certain lamp types, which the institution refers to as “LED lamps with integrated control devices”. These include:

• Omnidirectional lamps
• Directional lamps
• Decorative lamps
• Tubular lamps

Some of the lamp types that are not required to undergo the current INMETRO certification procedure for LED lamps are:

• Coloured LED lamps
• RGB coloured lamps
• LED lamps with integrated control devices that intentionally emit coloured lights
• OLED lamps
• Public Luminaries

INMETRO Certification

INMETRO certification can be summarised as a multiple stage process that involves entities such as the product supplier, an OCP and accredited testing laboratories. The product supplier, according to INMETRO’s documentation, is defined as the local distributor of the product intended to be certified, which can be either the local manufacturer or importing company in the case of products manufactured abroad.

The OCP, or Product Certification Body, is an institution accredited by INMETRO that is responsible for conducting the legal and technical aspects of the certification process, while the accredited testing laboratories are the institutions responsible for conducting the actual tests of the products for certification. An example of OCP is Brazilian company Master Certifications, one of the institutions accredited by INMETRO for the certification of LED lamps and other product categories.

INMETRO certification is required for various types of products commercialised in Brazil, and product suppliers that distribute non-certified product lots can be applied punitive measures such as fines and removal of products from store shelves. Products required to undergo INMETRO certification must present a Conformity Identification Seal, or a label that displays its certification by the Institute. Some electric-powered products, as is the case of LED lamps, must also hold an ENCE label, which presents its compliance to Brazilian regulation for power efficiency. Both of these labels are provided at the end of the INMETRO certification process.

INMETRO certification for all types of products requires a list of procedures that must be employed by product suppliers. The first of which is contacting OCPs and presenting a list of documents and information to initiate the certification procedure, which include:

• List of the products or product families intended to be certified, along with their technical descriptions and list of all the brands under which they will be commercialised, as well as formal authorization to use said brands if necessary
• Photographs of all sides of the products interior and exterior, as well as its packaging
• Descriptive memorandum of the product, including details of its construction and functions and specifications, translated either to Portuguese, English or Spanish
• User manual with instructions translated to Portuguese
• Design of the product’s packaging
• Option for one of the Certification Models made available by INMETRO for the product category, such as certification by testing of product lot or by testing of product samples and inspection of manufacturing facilities
• Informations regarding the product supplier, including company name, address and CNPJ
• Contact information for a representative of the product supplier
• Identification of the product manufacturer, including address of the manufacturing facilities located inside or outside of Brazil
• Information of activities or processes that might interfere with the products certification
• Documentation that proves the supplier's compliance to INMETRO regulation regarding customer service and handling of complaints
• Certification of the manufacturing process compliance to ISO 9001 quality management standards, if applicable to the products category

The compliance to INMETRO regulations regarding customer service and handling of complaints, as mentioned in this list, refers to the establishment of communication methods that enable customers to contact the product suppliers effectively in cases such as product malfunctioning or failure to meet its detailed specifications. The OCPs are responsible for auditing the facilities where customer complaints are dealt with in order to assure their compliance to INMETRO regulations. Some of the aspects required for the customer complaint systems are:

• Providing an effective treatment of submitted inquiries
• Compliance to Brazilian regulations, especially the guidelines of the Customer Defence law
• Providing a critical analysis of the results of the inquiries, as well as effective action based on the ones received
• Definition of responsibilities for the treatment of complaints
• Commitment to answer to INMETRO inquiries within 15 days
• Commitment to answer to customers within established timeframes
• Establishment of a system to deal with customer complaints, that includes their registering, treatment and information of their current status
• Appointment of a person or a team able to deal with customer complaints
• Establishment of a telephone number or other communication methods for receiving complaints, as well as a registration form that informs customers of a code or a protocol number to follow the status of the requests

Certification Models for LED Lamps and Process

INMETRO regulations for LED lamps presents two certification models which can be chosen by the product supplier according to its needs. These are:

• Certification Model 5: Based on the approval of the manufacturer’s Management Systems, regular auditing of manufacturer, and laboratory testing based on samples collected at retailers
• Certification Model 7: Based on the testing of a product's lot provided by its supplier

The approval of the manufacturers Management Systems refers to the regular auditing conducted by OCPs at the products manufacturing facilities to ensure its compliance to management standards established by the ISO 9001 norm. Some of the aspects evaluated by the auditing include the monitoring of the products assembly process and the products traceability, as well as the control over manufacturing equipment.

Some of the main differences between these two certification models are that in the case of Model 5, the product manufacturing process is approved by INMETRO and, as long as product samples are tested regularly and there are no significant changes to their manufacturing, the products are legally allowed to be commercialised. Also in the case of Model 5, multiple products can be certified during a single process, as long as they belong to what INMETRO regulation describes as a product family. This refers to products that share specifications such as the LED technology, expected lifetime, shape and are produced at the same manufacturing facility.

In short, the certification process for Model 5 is comprised of the following steps:

• Request of certification to OCP by the product supplier in Brazil
• Auditing of manufacturing facilities, based on INMETRO’s standards for Quality Management Systems and ISO 9001 norms
• Random sampling and sealing of products intended for testing
• Auditing of the product suppliers customer service and complaints handling systems
• Product testing performed at laboratories accredited by INMETRO or part of international organizations such as ILAC, IAAC or EA
• Analysis of documentation, test results and technical aspects of products by the OCP and issuance of product certificates
• Renewal of certification

The laboratory tests that take part in the certification process can only be performed after the previous steps mentioned on this list. Tests performed prior to the auditing of manufacturing facilities and product sampling are not allowed. INMETRO’s regulation also does not allow for other brands or product suppliers to make use of existing certificates, or for product suppliers to use old test reports during certification.

In the case of Certification Model 7, only certain product lots are tested and approved for commercialisation, and new product lots must be submitted for certification. Approved product lots can be commercialised indefinitely, and it is not possible to submit product families for certification under this model. Certification under Model 7 is usually more expensive than through Model 5, due to the large number of samples required to be tested. Additionally, the criteria for rejection under Model 7 is more rigorous, as not a single failure is allowed. In case of failure in one product, the whole batch is disapproved.

The certification for LED lamps requires the submission of the following documents and information in the case of both Models 5 and 7:

• List of products to be certified
• Descriptive memorandum that includes information such as the products’ technical specifications, like rated power, luminous flux, colour temperature and operational voltage, as well as their dimensions, usage limitations, special cares and other relevant information
• Photographs of the products interior and exterior, along with photographs of the products packaging with a preliminar version of the ENCE label
• Report of LM 80 standard testing of the LEDs used in the lamps
• Specifications of the electrolytic capacitor used by the lamp
• DataSheet and Part Number of all electronic component

Some of the documents and information required specifically in the case of Certification Model 7 Include:

• Import License, in case of imported products
• Identification of the size of the product lots to be certified

After the necessary documents are presented and approved by the OCPs, the certification process is initiated. At this stage of the process the OCPs are responsible for detailing a plan for the testing of product samples and choosing an accredited laboratory to conduct these tests. In the case of Certification Model 5, the OCP also conducts the auditing of manufacturing facilities for the approval of their Management Systems. The OCP is also responsible for providing the accredited laboratories with the product samples used in the tests, which are either provided by the product supplier or collected from retailers depending on the chosen Certification Model.

During the laboratory testing, some of the aspects of safety of usage evaluated for LED lamps are:

• Dimensions
• Interchangeability of lamp base
• Protection against contact with electrified parts
• Dielectric strength
• Resistance to humidity, torsion, heat, flames and ignition
• Electromagnetic compatibility

Some of the aspects evaluated for energy efficiency and working conditions include:

• Power consumption
• Power factor and harmonic currents
• Luminous flow
• Light Peak intensity
• Light intensity, direction and angle
• Colour temperature
• Colour reproduction
• Maintenance of luminous flow over long periods
• Expected lifetime
• Resistance to temperature variation and power interruption cycles

The minimum duration for the expected lifetime tests mentioned above is set at 6000 hours, however it can be reduced to 3000h upon the presentation of an IES-LM80 test report of the lamp’s LED. The results of energy efficiency tests are used for the rating of the lamps according to the ENCE grades, which will be displayed on the products ENCE label after the completion of the certification process. During the testing procedure other aspects are evaluated, such as the display of technical specifications at the products body and packaging. In the case of LED lamps, some of the specifications required to be displayed are:

• Products original brand
• Working voltage, power, frequency and amperage
• Power factor
• Weight
• Luminous flow
• Expected Lifetime
• INMETRO Conformity Identification Seal
• Colour reproduction index
• Dimerisation compatibility
• EBTS SELV identification for lamps that operate under extra low tension for security
• Identification of appropriate waste location
• Equivalence of power and luminous flow to fluorescent lamps
• Date of manufacturing

After the testing procedures are conducted and results are approved by both the appointed laboratory and OCP, the certification procedure is carried out. If all requirements for the opted Certification Model are met, the suppliers are given a Certificate of Conformity and products receive an INMETRO Conformity Identification seal and ENCE seal, which allow for their commercialisation.

Certification Renewal and Repetition of Tests

When opting for Certification Model 5 the compliance of products to INMETRO specifications must be evaluated periodically, and OCPs are responsible for conducting some of the safety of usage and power efficiency tests on an yearly basis. In the cases of changes to the products manufacturing processes, specifications, or changes in product families, suppliers are required to contact OCPs to check if other tests and certifications are needed.

Both in the cases of Certification Model 5 and 7, OCPs are allowed to revoke the products Certificates of Conformity and require new tests if there are any indications of major differences between products offered at retail and the samples evaluated.