IS 10322 (Part 1): 2026 — 12 Changes Affecting Every LED Luminaire in India

IS 10322 (Part 1): 2026 — 12 Changes Affecting Every LED Luminaire in India

ARTICLE 3: IS 10322 (Part 1): 2026 — The Foundation Standard Every LED Luminaire Manufacturer Must Understand

Standard: IS 10322 (Part 1): 2026 | Luminaires — General Requirements Replaces: IS 10322 (Part 1): 2014 (aligned with IEC 60598-1:2024) Notified: February 3, 2026 (Gazette), Implementation: March 20, 2026 Deadline: August 2, 2026 HOT Status: Scope approval in progress ---

The Standard That Governs Everything Else

IS 10322 (Part 1): 2026 is not a product standard. It does not describe a specific type of luminaire. Instead, it is the base safety standard that defines the general requirements applicable to all luminaires — and every product-specific standard in the IS 10322 Part 5 series is written as an addition to, and extension of, Part 1.

This means that when IS 10322 (Part 1) changes, those changes flow through to every luminaire category — fixed luminaires, recessed luminaires, street lights, floodlights, emergency lights, lighting chains, hand lamps, and swimming pool luminaires.

Understanding IS 10322 (Part 1): 2026 is therefore the foundation for understanding all luminaire compliance changes in 2026.

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What IS 10322 (Part 1) Covers

IS 10322 (Part 1) specifies general safety requirements and test methods for luminaires used with light sources operating at voltages up to 1000V. It defines:

  • Construction requirements (materials, insulation, live parts access)
  • Electrical safety requirements (creepage, clearance, dielectric strength, earth continuity)
  • Thermal requirements (temperature rise limits on windings, surfaces, terminals)
  • Mechanical requirements (strength, stability, cord anchorage)
  • Ingress protection requirements (for rated IP luminaires)
  • Photobiological safety assessment requirements
  • Marking requirements (what information must appear on the luminaire)
  • When combined with the applicable Part 5 product-specific section, these general requirements plus the product-specific additional requirements constitute the complete certification standard for each luminaire type.

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    The 12 Technical Changes in IS 10322 (Part 1): 2026

    Confirmed from the official BIS implementation guidelines issued by BIS Registration Department (Ref: Reg./IS 10322 Series/Guidelines/01, dated March 20, 2026):

    1. Introduction of IPX9 Testing

    IPX9 is the ingress protection rating for resistance to high-pressure, high-temperature water jets — typically used in industrial facilities, commercial kitchens, vehicle wash bays, and food processing environments where luminaires are regularly cleaned with high-pressure washdown systems.

    The previous version of the standard (IS 10322 Part 1: 2014) included IP testing up to IPX8 (continuous immersion). The 2026 revision adds IPX9 as a testable parameter. Luminaires that claim IPX9 protection must now have this claim validated through testing.

    Test conditions for IPX9: 80°C water temperature, 8–10 MPa pressure, 14–16 L/min flow rate, at a distance of 0.1–0.15m, with the luminaire rotated through all angles during testing. This is a very demanding test that requires specific test equipment.

    2. EMF Safety Requirements — First Inclusion in IS 10322

    The 2026 version is the first edition of IS 10322 (Part 1) to include Electromagnetic Field (EMF) safety requirements. This addresses the potential health effects of electromagnetic fields emitted by luminaire control gear — particularly relevant for luminaires with high-power drivers where the magnetic components (inductors, transformers) generate fields that users in close proximity may be exposed to for extended periods.

    The requirements specify maximum EMF levels at specified distances from the luminaire, ensuring that continuous occupational or domestic exposure to luminaire EMF remains within safe limits.

    This is a new test for which most existing luminaire certifications have no data. All luminaire products seeking certification after August 2, 2026 must include EMF measurement in their test evidence.

    3. Marking Requirements — Modified and Expanded

    Marking requirements have been comprehensively updated. Changes include:

  • Updated mandatory symbols
  • Revised requirements for energy labelling information
  • Modified format requirements for rating plate data
  • New requirements for specific product types (see below)
  • 4. New Sub-Clause — Marking of Mains Socket Outlet

    Some luminaires incorporate a mains socket outlet — allowing a secondary electrical device to be plugged in through the luminaire (common in desk lamps and some commercial luminaires). The 2026 standard elevates this from a general information requirement to a specific normative marking requirement. Luminaires with built-in socket outlets must carry specific markings indicating the socket's rated current and intended use.

    5. New Clause — Protection Against Fast-Rotating Parts

    This new clause addresses luminaires containing fast-rotating parts — most commonly cooling fans used in high-power LED luminaires (high-bay lights, high-power commercial downlights, some stadium lights). The clause specifies:

  • Guard requirements to prevent user contact with rotating parts
  • Minimum guard opening sizes to prevent finger access to fans
  • Testing for mechanical strength of guards under specified forces
  • Manufacturers of fan-cooled luminaires must verify their guard design meets the new requirements. Luminaires where the fan is accessible during normal operation or maintenance — without tools — need particular attention.

    6. Introduction of PELV System Requirements

    Protective Extra-Low Voltage (PELV) operates at voltages below 50V AC or 120V DC, using protective earthing. This distinguishes it from SELV (Safety Extra-Low Voltage) which is unearthed. PELV is used in some architectural lighting systems, dimmer-controlled installations, and specific luminaire types where low-voltage operation is desired but earth bonding provides additional protection.

    The 2026 standard introduces specific requirements for luminaires designed to operate on PELV systems, covering the interaction between the luminaire and PELV supply, insulation requirements, and marking.

    7. Additional Requirements for SELV Output Luminaires

    Luminaires with controllable control gear providing SELV outputs — increasingly common in smart lighting systems (DMX, DALI, 0-10V, ZigBee-controlled luminaires) — now have specific requirements addressing the control gear-luminaire interface and the safety of the SELV output circuit.

    8. Touch Voltage and Touch Current Limits — New Electrical Shock Test

    The existing test for whether a conductive part can cause electric shock has been significantly updated. The 2026 version introduces explicit numerical limits for:

    Touch voltage: The maximum voltage measurable on accessible conductive parts under specified conditions. Previously, the standard required that conductive parts not be at hazardous voltage — but "hazardous" was not numerically defined. The 2026 version defines specific voltage limits. Touch current: The current that flows when a person contacts an accessible part. Touch current limits are specified to ensure that even at lower voltages, the current is not physiologically harmful.

    This makes the test more objective and consistent across laboratories, and may identify products that passed the previous more subjective test but would not pass the new numerically-defined limits.

    9. Informative Annexure — Power over Ethernet (PoE) Luminaires

    A new informative (non-normative) annexure addresses luminaires powered through IT communication cabling — specifically Power over Ethernet (PoE) luminaires. PoE luminaires receive both data (for control) and power (up to 71.3W in PoE++ standard) through a standard Ethernet cable. The annexure provides guidance on how the power sourcing equipment interacts with the luminaire and what the luminaire designer must consider for safe operation.

    10. Informative Annexure — Higher Impulse Withstand Category

    A new informative annexure covers luminaires requiring Overvoltage Category III (OVC III) impulse withstand — relevant for luminaires connected directly to distribution infrastructure (large industrial facilities, commercial buildings with main distribution board connections). OVC III represents exposure to higher transient overvoltages than OVC II (standard household) equipment. The annexure provides guidance for luminaire designers specifying luminaires for these applications.

    11. Normative Annexure — Battery/EDLC-Operated Luminaires

    This is a normative (mandatory) annexure — meaning it is part of the compliance requirements, not just guidance. It covers luminaires powered by batteries or Electric Double Layer Capacitors (EDLCs, or supercapacitors):

  • Battery-operated luminaires (non-mains-connected)
  • Luminaires with battery backup (mains-powered with emergency battery)
  • EDLC-operated luminaires (supercapacitor energy storage)
  • The annexure specifies safety requirements for the energy storage system, charging circuits, and operation in battery/EDLC mode. This is particularly relevant for emergency luminaires using lithium batteries — a growing product category.

    12. Extended Photobiological Safety Requirements

    Photobiological safety requirements have been extended in the 2026 version — meaning more luminaire types are now subject to photobiological assessment than under the 2014 standard. Additionally, the assessment methodology has been updated.

    Every luminaire certification after August 2, 2026 must include photobiological safety assessment confirming the luminaire's risk group classification.

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    Why These Changes Matter to Every Luminaire Manufacturer

    Here is the key point that many manufacturers miss: IS 10322 (Part 1): 2026 applies to ALL luminaires covered under the IS 10322 Part 5 series — simultaneously.

    When you test your recessed luminaire against IS 10322 (Part 5/Sec 2): 2026, the test report must also demonstrate compliance with IS 10322 (Part 1): 2026. The Part 5/Sec 2 report alone is not sufficient. Both documents are required.

    This means the 12 changes in Part 1 listed above apply to:

  • Fixed general purpose luminaires (Sec 1)
  • Recessed luminaires (Sec 2)
  • Street and road lighting (Sec 3)
  • Floodlights (Sec 5)
  • Hand lamps (Sec 6)
  • Lighting chains (Sec 7)
  • Emergency luminaires (Sec 8)
  • Swimming pool luminaires (Part 18)
  • Every luminaire product that needs BIS recertification under the 2026 standards must address ALL applicable Part 1 changes in addition to the product-specific Part 5 changes.

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    10 Frequently Asked Questions

    FAQ 1: My luminaire has a BIS licence under IS 10322 (Part 5/Sec 1): 2012. Does the Part 1: 2026 update affect me even though Part 1 is a separate standard?

    Yes. Every Part 5 product standard references Part 1 as the base document. When Part 1 is revised, compliance with the revised version is required as part of your product certification — your Part 5 compliance is incomplete without Part 1 compliance.

    When you re-test under IS 10322 (Part 5/Sec 1): 2026 for the August 2 deadline, your test report must include all Part 1: 2026 requirements alongside the Part 5/Sec 1: 2026 specific requirements. You cannot test only against Part 5 and ignore Part 1.

    FAQ 2: My luminaires do not have cooling fans, EMF-generating large inductors, or PELV systems. Do all 12 changes in Part 1: 2026 apply to my products?

    Not all changes will require new testing for all products. Some changes are specifically triggered by product features:

  • IPX9 testing: Only if your luminaire claims IPX9 rating
  • EMF requirements: Applies to all luminaires but the measurement and limit check applies regardless of whether a large inductor is present — even small LED drivers generate fields
  • Fast-rotating parts: Only if your luminaire has fans or other rotating parts
  • PELV requirements: Only if your luminaire is designed for PELV systems
  • SELV output requirements: Only if your luminaire has controllable control gear with SELV output
  • PoE annexure: Informative only — applies if relevant to your design
  • Battery/EDLC annexure: Only if your luminaire has battery or EDLC backup
  • The changes that apply universally to ALL luminaires regardless of features:

  • Updated marking requirements
  • Touch voltage and touch current limits (updated electrical shock test)
  • Extended photobiological safety assessment
  • FAQ 3: What is EMF testing for luminaires and what does it involve?

    EMF (Electromagnetic Field) testing for luminaires measures the strength of the electromagnetic fields generated by the luminaire's electrical components — primarily the LED driver, transformers, and inductors — at specified distances from the luminaire.

    The test is conducted using calibrated EMF measurement probes at specified distances. The measured field strengths are compared against the limits specified in the standard, which are derived from established exposure guidelines for the general public and workers.

    For most residential and commercial LED luminaires with compact LED drivers, EMF levels are typically very low — well within limits. High-risk cases include:

  • Large inductive ballast systems (increasingly rare with LED)
  • High-power luminaires with large transformer-based drivers
  • Some specific driver topologies with high magnetic component content
  • A pre-assessment of your luminaire's driver specification will indicate whether there is any risk of EMF non-compliance before formal testing.

    FAQ 4: My luminaire is currently certified under IS 10322 (Part 5/Sec 1): 2012 and the certificate is valid until 2028. Do I still need to re-test before August 2, 2026?

    Yes. BIS has stated that licences will not remain operative after August 2, 2026 where compliance with the revised standard has not been ensured. The nominal validity date of your 2012-standard licence does not exempt you from this requirement.

    The implementation guideline is explicit: you have until August 2, 2026 to complete the transition regardless of your licence validity date.

    FAQ 5: The photobiological safety requirement is new in Part 1: 2026. What exactly needs to be measured and what are the pass criteria?

    Photobiological safety for luminaires is assessed per IEC 62471 (Photobiological Safety of Lamps and Lamp Systems). The measurement involves:

  • Spectral measurement: The luminaire's spectral power distribution is measured using a calibrated spectroradiometer
  • Hazard calculations: Multiple hazard parameters are calculated from the spectral data, including blue light hazard weighted radiance (LB), retinal thermal hazard, and UV hazard
  • Risk group determination: Based on the calculated hazard values, the luminaire is assigned a Risk Group (RG0, RG1, RG2, or RG3)
  • For BIS certification, RG0, RG1, and RG2 classifications are all potentially acceptable. RG3 is not appropriate for general lighting applications.

    Products classified as RG2 require specific safety markings and may have restrictions on use in certain applications (particularly close-proximity applications where a person's eyes are consistently within 20cm of the light source).

    For most diffused commercial LED luminaires (panel lights, ceiling lights, batten lights), RG0 or RG1 is the expected classification. High-intensity directional luminaires (narrow-beam spotlights, some track lights) carry higher risk of RG2 classification.

    FAQ 6: What is the touch voltage and touch current test, and is it different from existing electrical shock tests?

    The existing electrical shock test in IS 10322 (Part 1): 2014 required that conductive parts accessible without tools not be "at a hazardous potential." This was inherently subjective — "hazardous" was assessed by judgement rather than a numerical threshold.

    The 2026 update introduces specific numerical limits:

    Touch voltage: A maximum voltage value is specified that accessible conductive parts must not exceed under the test conditions. The exact value is specified in the standard (typically in the range of 25–50V for different product categories and conditions). Touch current: A maximum current value is specified for current that flows through a specified body impedance simulation when contact is made with accessible parts.

    The advantage of the new approach is that it is unambiguous and laboratory-reproducible. The disadvantage is that some products that previously passed the subjective test may not pass the new numerical-limit-based test — particularly products with certain driver topologies that allow small capacitively-coupled voltages on accessible metal parts.

    FAQ 7: I manufacture downlights that use a 12V DC SELV output driver with a separate power supply. Does the SELV requirement in Part 1: 2026 affect me?

    If your luminaire uses a SELV driver (output voltage ≤ 50V AC or ≤ 120V DC) and the luminaire body connects to this SELV output, you are likely using a SELV system. The 2026 standard has requirements for luminaires using controllable control gear providing SELV output — covering how the control gear interacts with the luminaire and ensuring safety of the SELV circuit.

    For standard fixed-output SELV luminaires (constant voltage SELV with no remote control), the requirements are relatively straightforward. For luminaires where the SELV driver is controllable (dimming, colour temperature tuning, on/off control through a network), the requirements are more comprehensive.

    Review your driver specification carefully with our engineers before testing to determine whether the new SELV requirements introduce any compliance gaps.

    FAQ 8: My high-bay LED luminaire has a cooling fan. The fan is inside the housing and cannot be accessed during normal use without opening the housing with tools. Does the fast-rotating parts clause apply?

    The key question is whether the fan is accessible during normal use or normal maintenance — defined as activities that can occur without special tools.

    If accessing the fan requires removing screws or disassembling the luminaire using tools — and this is clearly not a user-serviceable operation — the fan protection requirements may not apply in the same way as for a fan that is exposed or accessible through ventilation openings.

    However, if your luminaire has ventilation slots or openings through which a finger could reach a fan blade — even if this is not the intended purpose of the slot — the protection requirements apply.

    The specific requirement is that openings must not allow the standard test finger (as defined in the standard) to contact moving fan blades. This is a physical test conducted with a standard probe.

    Have your luminaire housings reviewed by our engineers — we can quickly assess whether your ventilation opening geometry requires modification before formal testing.

    FAQ 9: How does IS 10322 (Part 1): 2026 interact with energy efficiency standards? Is there any overlap with BEE Star Rating requirements?

    IS 10322 (Part 1): 2026 is a safety standard — it does not specify energy efficiency requirements. Energy efficiency for luminaires is addressed through separate BEE (Bureau of Energy Efficiency) regulations.

    The two frameworks are independent:

  • IS 10322 (BIS CRS): Mandatory safety certification — you cannot sell the product without it
  • BEE Star Rating: Energy efficiency label — mandatory for certain product categories, covers energy consumption
  • For luminaires, BEE Star Rating is currently mandatory for a more limited range of products than BIS CRS. Check whether your specific luminaire type requires BEE Star Rating separately from BIS certification.

    Testing for BIS IS 10322 and BEE Star Rating involves different laboratories and different tests — photometric measurement for BEE, safety testing for BIS. House of Testing conducts IS 10322 safety testing; for BEE-specific testing requirements, our team can guide you to the appropriate empanelled laboratory.

    FAQ 10: If I submit my luminaire samples for testing now (May 2026), can I still submit under the old IS 10322 (Part 1): 2014?

    Yes — but with conditions. The implementation guidelines permit processing of applications under the old standard where samples have already been submitted to the laboratory. However, you must provide a declaration committing to implement the revised standard by August 2, 2026.

    From a practical standpoint: testing under the 2014 standard now and then retesting under the 2026 standard before August 2 is inefficient and wasteful. You would pay for testing twice.

    The strongly recommended approach is to test under IS 10322 (Part 1): 2026 and the applicable Part 5: 2026 section from the start — a single test, compliant with the new standard, valid beyond August 2.

    Contact House of Testing now to register your luminaire products for testing under the 2026 standards.