IS 16614 (Part 1): 2026 — LED Tube Lights T8 and T5 Safety Requirements

IS 16614 (Part 1): 2026 — LED Tube Lights T8 and T5 Safety Requirements

ARTICLE 12: IS 16103 (Part 1): 2025 — LED Modules — The Deadline Has Already Passed

Standard: IS 16103 (Part 1): 2025 / IEC 62031:2018 | LED Modules for General Lighting — Safety Requirements Replaces: IS 16103 (Part 1): 2012 Implementation Deadline: January 21, 2026 — ALREADY PASSED HOT Status: Scope approval in progress ---

The Deadline That Has Already Gone — Act Immediately

Every other standard in this series has a deadline of August 2, 2026 — three months from the time of writing. IS 16103 (Part 1): 2025 is different. Its transition deadline was January 21, 2026 — over three months ago.

If you hold a BIS CRS licence for LED modules under IS 16103 (Part 1): 2012, and you have not yet transitioned to IS 16103 (Part 1): 2025, your licence is at risk of being cancelled or your models at risk of deletion from scope right now.

This is not a warning about a future deadline. This is a statement about your current compliance status.

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What IS 16103 (Part 1) Covers

IS 16103 (Part 1) specifies safety requirements for LED modules for general lighting — the LED engines, components, and assemblies that are integrated into luminaires. Unlike self-ballasted LED lamps (which include an integrated driver and connect directly to mains supply), LED modules require a separate external driver (LED control gear) to operate.

Products in scope include:

  • LED COB (Chip-on-Board) arrays
  • LED SMD arrays on boards (without integrated driver)
  • LED modules for downlights and track lights (supplied without driver)
  • LED strips and linear modules (where supplied separately from the driver)
  • Integrated LED arrays for panel lights (the LED board without driver)
  • LED filament arrays (without integrated driver)
  • LED modules for street lighting luminaires
  • High-power LED modules for floodlights and industrial luminaires
  • Not in scope:
  • Self-ballasted LED lamps (with integrated driver) — these are covered under IS 16102
  • LED luminaire assemblies (complete fittings) — covered under IS 10322
  • LED drivers and control gear — covered under IS 15885
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    What Changed in IS 16103 (Part 1): 2025

    Confirmed from multiple sources including the official BIS notification and implementation guidelines:

    Change 1: New Definitions — Replaceable, Non-Replaceable, Non-User-Replaceable

    This is one of the most practically significant changes. The 2012 standard treated LED modules as a monolithic category without addressing whether they can be replaced by end users. The 2025 version introduces three distinct module categories:

    Replaceable LED module: Can be replaced by a non-specialist user (the lamp owner or general handyman) without special tools. Like a replaceable lamp — when it fails, it can be swapped out. Non-replaceable LED module: Requires a skilled person (electrician or specialist technician) for replacement, or requires special tools. The module can be replaced, but not by a non-specialist. Non-user-replaceable LED module: Cannot be replaced by end users and is designed for manufacturer-level or specialist service centre replacement. The module is essentially permanent from the user's perspective.

    These categories matter because they determine marking requirements, construction requirements, and what information luminaire designers need. A luminaire incorporating a non-user-replaceable module must clearly indicate this to the specifier and end user.

    Change 2: Restructured Marking Requirements

    Marking requirements have been completely restructured with a new overview table that clearly specifies what information must appear on different module types. The 2012 version had marking requirements scattered through the standard — the 2025 version consolidates them into a clear reference table.

    Key marking changes:

  • Modules must be marked with their category (replaceable, non-replaceable, non-user-replaceable)
  • Built-in module markings have been modified
  • Working voltage marking entry has been updated
  • New information requirements for water contact compatibility
  • Change 3: Abnormal Temperature Testing — New Test

    A new abnormal temperature test has been added — assessing module safety when operated at temperatures above the maximum specified junction temperature. This test addresses scenarios where a module is installed in a luminaire with inadequate thermal management, causing it to run hotter than designed.

    The test simulates this condition and verifies that the module does not create hazardous conditions (fire, toxic gas emission, electrical failure creating shock risk) when overtemperature.

    This test directly addresses real-world failure modes — LED modules that overheat due to poor thermal interface or inadequate heatsinking in the luminaire.

    Change 4: Photobiological Safety Testing — New Requirement

    Photobiological safety testing per IEC 62471 has been added for LED modules. This involves measuring the spectral emission of the module and classifying it by photobiological risk group.

    For LED modules, this is particularly relevant because:

  • Modules are often used in close-proximity applications (task lighting, under-shelf lighting)
  • Module-level testing provides luminaire designers with the data they need to assess luminaire-level photobiological safety
  • The IEC TR 62778 method allows extrapolation from module-level test data to luminaire-level assessment under certain conditions
  • Change 5: Information for Luminaire Designers — Working Voltage and Water Contact

    New guidance has been added for luminaire designers specifying:

  • Working voltage information — what voltage the LED module operates at, which luminaire designers need to specify appropriate control gear
  • Water contact information — whether the module can be used in applications where water contact is possible (relevant for IP-rated luminaire designs)
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    10 Frequently Asked Questions

    FAQ 1: My BIS CRS licence for LED modules is still showing as "valid" on the Manakonline portal even though the January 21 deadline has passed. Does that mean I am still compliant?

    Not necessarily. The Manakonline portal's "valid" status reflects the nominal validity period of your licence — not whether your products comply with the current standard.

    BIS may not have taken action to suspend or cancel your licence on January 21 automatically — enforcement and administrative action takes time. However, the BIS guidelines state clearly that after January 21, 2026, licences under IS 16103 (Part 1): 2012 are not operative if compliance with the revised standard has not been ensured.

    "Valid until date" on the portal and "compliant with current requirements" are two different things. If you have not transitioned to IS 16103 (Part 1): 2025, your products may be technically non-compliant even if the portal shows "valid."

    Act immediately — contact our team to arrange testing under IS 16103 (Part 1): 2025.

    FAQ 2: We had LED module samples submitted to a laboratory in December 2025 for testing under IS 16103 (Part 1): 2012. The test report came in January 2026. Can we use this report?

    Yes — the BIS guidelines permitted processing of applications where samples were already submitted to the laboratory before the transition deadline, even if the test report is issued afterward.

    If your samples were submitted to a BIS-recognized laboratory before January 21, 2026, and the test report was subsequently issued, you may be able to proceed with an application or licence amendment under IS 16103 (Part 1): 2012.

    However, you should still plan to transition to IS 16103 (Part 1): 2025 before your licence's next renewal date. Discuss your specific situation with our team — the transition rules have nuances that depend on your specific circumstances.

    FAQ 3: What is the IEC 62031:2018 reference in the new standard title? Is this a completely different standard from IS 16103 (Part 1): 2012?

    IS 16103 (Part 1): 2025 is published as IS 16103 (Part 1): 2025 / IEC 62031:2018 — indicating that the Indian Standard is harmonised with IEC 62031:2018.

    The previous version (IS 16103 Part 1: 2012) was based on an earlier version of IEC 62031. The 2025 revision aligns IS 16103 with the 2018 update to IEC 62031.

    This is not a completely different standard — it is an update to the same base standard. The core safety requirements are consistent between versions, but the 2025 version includes the changes enumerated in this article (new definitions, updated marking, new tests).

    If your LED modules already comply with IEC 62031:2018 — which is the basis for CE marking LED module certification in Europe — the technical content is substantially equivalent to IS 16103 (Part 1): 2025. You still need testing at a BIS-recognized laboratory for BIS registration, but the likelihood of pass is high.

    FAQ 4: My LED module has been tested at a CNAS-accredited laboratory in China against IEC 62031:2018. Can this data be used for BIS?

    No — not directly. BIS accepts test reports only from BIS-recognized laboratories.

    However, the technical content of a CNAS-accredited test against IEC 62031:2018 (the same standard basis) is potentially useful:

  • If the Chinese laboratory is also BIS-recognized for IS 16103 (Part 1): 2025, the report is directly acceptable
  • If the Chinese laboratory is not BIS-recognized, the technical data may be reviewed by a BIS-recognized laboratory but cannot substitute for BIS-recognized testing
  • Contact House of Testing to discuss your specific situation. If your module has recent and comprehensive IEC 62031:2018 test data from a reputable laboratory, our engineers will advise on the most efficient path to IS 16103 (Part 1): 2025 compliance.

    FAQ 5: I manufacture LED strips — long flexible PCBs with SMD LEDs soldered onto them, sold in rolls. Are these covered under IS 16103 (Part 1): 2025?

    LED strips fall into a regulatory grey area. The classification depends on:

  • Whether the strip includes an integrated driver (if yes → may be classified as a lamp system under IS 16102)
  • Whether the strip is sold with or without a driver (if sold without → likely classified as a module under IS 16103)
  • The intended use and marketing of the product
  • LED strips sold as raw LED tape (by the metre, requiring an external 12V or 24V driver) are most commonly classified as LED modules and covered under IS 16103. LED strips sold as complete systems with an integrated driver and plug → more likely classified as a lamp or luminaire product.

    The BIS classification also depends on how the product is presented in marketing — if you market it as a complete lighting system, BIS may classify it differently from a component sold to luminaire manufacturers.

    Contact our team for a specific classification assessment for your LED strip product. This is an area where getting the classification right at the outset avoids costly re-testing under a different standard later.

    FAQ 6: What does "non-user-replaceable" mean in practice for luminaire manufacturers and designers?

    For luminaire manufacturers and designers specifying LED modules:

    If the module is non-user-replaceable: The luminaire's expected life (from the consumer's perspective) is the module's expected life. When the module fails, the consumer either replaces the entire luminaire or has it serviced by a specialist. The luminaire must be clearly marked indicating the module is not user-replaceable. Design implications:
  • The luminaire design does not need to facilitate module replacement by end users (no accessible module compartment)
  • But the luminaire should ideally be designed for specialist service replacement — reducing waste
  • If the luminaire is categorised as a "non-serviceable" product (module cannot be replaced at all), the luminaire's rated life is the total product life
  • Marking implications:
  • The luminaire must indicate that the LED source is not user-replaceable
  • Installation and disposal instructions must reflect this
  • Energy label provisions may differ for luminaires with non-replaceable light sources
  • The 2025 standard provides luminaire designers with clear, standardised terminology to specify modules and design luminaires appropriately around the module's replaceability category.

    FAQ 7: My LED modules include a temperature sensor for protection. Does this additional component require any specific assessment under IS 16103 (Part 1): 2025?

    Temperature sensors integrated into LED modules are typically thermistors or thermal cutouts that protect the module from overtemperature. They are passive protection components — not active electronic control circuits.

    Under IS 16103 (Part 1): 2025, the presence of a temperature sensor affects:

  • The abnormal temperature test methodology: the test should verify that the protection operates correctly and disconnects or reduces current before unsafe temperatures are reached
  • Marking: if the module has thermal cutout protection, this should be indicated in the module documentation for luminaire designers
  • The sensor itself does not require separate certification — it is a component of the LED module and is assessed as part of the complete module testing under IS 16103.

    FAQ 8: Our LED modules are used in luminaires that are later filled with potting compound (silicone or epoxy encapsulant) for IP protection. Does the potting affect the IS 16103 certification?

    Testing under IS 16103 (Part 1): 2025 is typically conducted on the module as supplied — before potting. The certified product is the un-potted module.

    If the module is potted after installation in a luminaire, the potted module-in-luminaire is a different configuration from what was certified. The luminaire (with potted module) would then need to be certified as a complete luminaire under the appropriate IS 10322 standard.

    This is an important distinction: IS 16103 certifies the LED module component. IS 10322 certifies the complete luminaire assembly. If your manufacturing process involves potting LED modules into luminaire housings, the final product requires luminaire certification — not just module certification.

    Contact our team if you have questions about where the module certification ends and the luminaire certification begins for your specific product and manufacturing process.

    FAQ 9: What documentation does the module manufacturer need to provide to luminaire designers who use their modules?

    IS 16103 (Part 1): 2025 requires specific technical information from the LED module manufacturer that enables luminaire designers to design compliant and safe luminaires. This documentation (sometimes called the "module datasheet for luminaire designers") must include:

  • Rated wattage and forward voltage / current
  • Maximum junction temperature (Tj max)
  • Thermal resistance (junction to board, Rθj-b)
  • Photobiological safety risk group (newly required in 2025)
  • Module category (replaceable, non-replaceable, non-user-replaceable)
  • Working voltage (for control gear selection)
  • Water contact compatibility information
  • Maximum board temperature for warranty compliance
  • Luminous flux and efficacy at rated current and reference temperature
  • This documentation enables luminaire designers to:

  • Select appropriate LED drivers
  • Design adequate thermal management
  • Specify appropriate installation conditions
  • Complete luminaire-level photobiological safety assessment
  • If your LED modules don't have complete documentation covering all these parameters, now is the time to compile it — both for IS 16103 compliance and for your downstream customers' benefit.

    FAQ 10: We have just received our BIS test report under IS 16103 (Part 1): 2025, and BIS has raised queries about our photobiological safety test data. What are the common issues with photobiological safety reports?

    Common issues with LED module photobiological safety reports that trigger BIS queries:

  • Wrong measurement distance: IEC 62471 specifies measurement distances depending on the luminance of the source. For LED modules (which are typically high-luminance sources), the standard 200mm measurement distance is used. Reports using different distances are not directly comparable.
  • Module-level vs luminaire-level confusion: The photobiological safety classification for a module is at the module level — not at the luminaire level. BIS may query if the report appears to present luminaire-level data rather than module-level data.
  • Incomplete hazard assessment: IEC 62471 requires assessment of multiple hazard types (UV hazard, blue light hazard, retinal thermal hazard, infrared hazard). Reports that assess only blue light hazard (BLH) without confirming the absence of other hazards are incomplete.
  • Wrong standard version: The photobiological safety requirement in IS 16103 (Part 1): 2025 references current IEC 62471 methodology. Reports based on older versions of IEC 62471 may use different measurement methods or calculation procedures.
  • Missing risk group statement: The report must clearly state the risk group (RG0, RG1, RG2, or RG3) — not just the measured LB value. Some reports present measured data without the risk group conclusion.
  • House of Testing's photobiological safety measurement generates reports in the format expected by BIS — including all required hazard assessments and the clear risk group conclusion. If you have existing photobiological reports with these issues, contact our team for a review.