Last week, we received and reviewed a copy of the Lighting Industry Association’s (LIA) Market Surveillance Report 2018. The contents of this document are, frankly, shocking.
In summary, the LIA’s work has uncovered alarming issues around the quality of lighting products sold by some of Britain’s best-known retailers and electrical wholesalers.
The Report’s evidence shows that customers buying through a reputable wholesaler or retailer have a greater than 50:50 chance that the product they are purchasing does not even comply with basic safety requirements – let alone meet the (often outrageous) performance claims being made.
This is unacceptable. The LIA’s Survey results should send shockwaves around the lighting and electrical market.
The time has come for reputable manufacturers – such as ourselves – to work with the LIA to push this message out to the market. In doing so, we hope that it forces retailers and offending manufacturers to radically improve standards.
We are entirely supportive of the LIA’s decision to strike off any member company that refuses to supply technical files or to deal with non-compliances and after appeals to address problems. This is exactly why we need a strong and decisive trade association – and its surveillance programme is doing very, very important work.
LIA Verified certification scheme
The results of this LIA Survey underpin the need for the LIA Verified certification scheme. The LIA Verified scheme has been created to identify quality products, so members of the scheme can declare a trustworthy third-party verification of three key elements – Safety, Performance and Life capability. This is now the only way we can clean up our industry and restore customer confidence.
All products manufactured by Energys Group under our New Vision brand are LIA Verified.
Let’s look at the detail…
According to the LIA, one of the most common concerns it hears from members is the issue of non-compliant products entering the market. The LIA – which is our industry’s leading trade association – says that this “…creates an unfair trading environment in which members are bearing the considerable cost of compliance.” At Energys Group, we would agree.
The LIA conducts regular market surveillance which is broken down into three programs: Member Market Surveillance; the Retail and Wholesale Market Surveillance Program; and by Market Intelligence.
The 2018 results of the Member Market Surveillance are extremely concerning.
A total of 187 members were eligible for inspection. Over the course of the year, random selections of products were made from all 187 members and technical files were requested.
- 147 files were received.
- 40 members failed to supply technical files within the 10 day period.
- Of the 147 files the LIA received 110 passed the scrutiny and 37 failed.
The following lists the non-compliances found in the failed technical files
- No Safety Evidence – 14
- No RoHS evidence – 13
- No Risk assessment – 11
- No REACH evidence -11
- No EMC evidence – 10
- Referred to withdrawn standard – 7
- DoC not present / incorrect – 5
- Referred to wrong standard or part 2 – 4
- No high ambient temp (°C) evidence – 4
- No ERP evidence – 3
- No IPXX / IKXX evidence – 4
- CE+CE=CE approach – 2
- No tp(a) or tp(b) – 2
- No Fire Rating evidence – 1
The LIA’s observations from failures
The LIA is concerned – as are we – that in a number of cases, the person responsible for product compliance often lacks the knowledge of what a CE technical file should contain, or the requirements of the CE mark.
The following are concerns raised by the LIA:
- A number of Technical Files contained only product specifications and/or just a Declaration of Conformity without any supporting evidence. The remaining evidence was supplied only after further explanation of what a Technical File should contain.
- Companies that self-declare compliance to the LVD often apply standards that make it easier to affix the CE mark, rather than applying tougher standards to ensure product safety.
- Manufacturers/Distributors rely upon statements made by suppliers, risk assessments are not conducted to challenge product compliance. TRF reports are poor or inadequate. Wrong standards or withdrawn standards used, missing clauses.
- Applying the incorrect assumption that if you build a luminaire from CE marked components, the whole luminaire will be CE compliant.
- RoHS and REACH requirements are ignored.
- Risk Assessments are not performed, product design and/or product use is not risk assessed.
Actions taken on non-compliances
For each non-compliant technical file received, the LIA member was contacted and informed.
According to the LIA – a number of members either refused to supply technical files or to deal with non-compliances and after appeals to address these problems the LIA had no alternative but to exclude 5 companies from LIA membership.
At the time of writing this report there are still 15 corrective actions outstanding and 15 LIAQA members under review at their next audit.
A further 3 members have been sent final letters informing them that their membership will be rescinded should they not address the compliance issues.
Retail and wholesale market surveillance program
Of particular concern to us at Energys Group are the results of the LIA’s market surveillance of a range of trade and online outlets. A total of 42 sample products were purchased from across the outlets including domestic and commercial luminaires and lamps.
- At the end of 2018 21 samples had been assessed and a further 21 were still undergoing tests in the laboratory.
- Of the 21 assessed 9 passed and 12 failed.
Of the 12 failures, 7 were of a critical nature which, in the opinion of the LIA experts, posed a danger to end users.
We are pleased to learn that all 7 cases were reported to Trading Standards.
During 2018 the LIA received a large number of complaints about products which were of concern to LIA members or end users. These were investigated and 8 cases relating to safety were reported to Trading Standards with a further 30 compliance issues reported to the Office for Product Safety and Standards (ex- National Measurement Office).
Owing to confidentiality the LIA says it is “not always able to track the outcomes of these investigations by the authorities but we are assured that they are fully investigated.”
Conclusions from Energys Group
- The LIA’s surveillance work is vital for customer confidence and the reputation of the industry.
- The LIA must continue to apply pressure on the government and authorities to ensure only safe and compliant products are made available for sale.
- We need a strong and decisive trade association – and the LIA’s surveillance programme is doing very, very important work
- Purchasing or specifying products that carry the LIA Verified mark is now more important than ever.