Introduction

Starting June 1, 2026, the EU will officially implement mandatory EN 62471:2026 photobiological safety certification requirements for exported infrared sensor products. This policy directly affects Chinese exporters of industrial equipment involving infrared thermal imagers, infrared temperature sensing sensors, and integrated infrared sensor modules. The core change lies in the newly added irradiance limit values and measurement specifications for near-infrared pulsed light sources, which will significantly reshape product compliance pathways and delivery schedules.

Event Overview

The Official Journal of the European Union (OJEU) issued a confirmation notice on May 20, 2026, clearly stating that the new version of EN 62471:2026, "Photobiological safety of lamps and lamp systems," will take effect from June 1, 2026, requiring mandatory conformity assessment within the EU for all end products containing infrared light sources (especially those operating in the 780–1400 nm wavelength range). Applicable products include, but are not limited to, infrared thermal imagers, infrared temperature sensing sensors, as well as industrial automation equipment, security systems, and medical auxiliary devices integrating infrared sensor modules. Products that fail to complete certification will be denied customs clearance by EU member state customs authorities, or be subject to mandatory recall by market surveillance authorities after being placed on the market.

Which Sub-Sectors Will Be Affected

Direct Trading Enterprises

Foreign trade companies and overseas-oriented brands engaged in exporting infrared sensing equipment to Europe will directly face a higher compliance entry threshold. The impact is reflected in the following: EN 62471:2026 declarations of conformity and third-party test reports must be submitted simultaneously during export customs declaration; orders already signed for delivery after June may face performance delays due to certification lag; some SME customers have not yet defined the allocation of photobiological safety responsibilities in their procurement terms, creating a risk of contract disputes.

Raw Material Procurement Enterprises

Procurement parties supplying key components such as LED/VCSEL light sources, optical filters, and driver ICs for infrared modules need to reassess whether upstream suppliers can provide material-level spectral data and pulse parameter documentation supporting the new standard. The impact is reflected in the following: some domestic near-infrared emitters lack pulse peak irradiance calibration capability, making it difficult to support complete EN 62471 testing for complete equipment manufacturers; procurement cycles may be extended due to supplementary technical documentation or replacement of qualified suppliers.

Processing and Manufacturing Enterprises

OEM/ODM manufacturers and system integrators are the key execution layer for implementing this certification. The impact is reflected in the following: existing production lines are not equipped with near-infrared pulsed light source measurement equipment (such as integrating spheres + fast-response spectrometers), making independent pre-testing impossible; some products adopt multi-light-source composite designs (such as visible light + near-infrared collaborative imaging), requiring renewed system-level photobiological safety assessment rather than testing the infrared unit alone; longer certification cycles will compress mass production schedules and intensify peak-season delivery pressure.

Supply Chain Service Enterprises

Third-party service providers offering CE certification consulting, testing agency services, and technical regulatory consulting will face short-term demand for building dedicated EN 62471:2026 capabilities. The impact is reflected in the following: fewer than 10 domestic laboratories have IEC 62471 pulsed light source testing qualifications, and testing queue times have already extended to 6–8 weeks; some institutions still lack calibration capability for pulsed light sources in the 780–1400 nm band, requiring reliance on overseas laboratories for report issuance, thereby increasing compliance costs and time uncertainty.

Key Focus Areas and Response Measures for Relevant Enterprises or Practitioners

Immediately Verify Whether Products Fall Within the Mandatory Scope

Not all infrared sensors are subject to these requirements——only when a product contains an active emitting near-infrared light source (such as VCSEL arrays, pulsed LEDs) and the radiation direction faces areas accessible to the human body will the applicable provisions of EN 62471:2026 be triggered. Enterprises need to determine the light source category (Exempt/Group 1/Group 2/Group 3) according to Annex A of the standard to avoid over-investing certification resources.

Prioritize Pre-Testing and Corrective Action Closed Loop for Key Models

It is recommended to select 3–5 main models accounting for more than 30% of export volume and commission a CNAS-accredited laboratory to conduct irradiance distribution scanning and pulse peak measurement, so as to identify whether the product exceeds the RG2 (moderate-risk group) limit. If the limit is exceeded, compliance can be achieved by adjusting driver current duty cycle, adding a mechanical shutter, or optimizing the optical diffusion structure, which is more timely and cost-effective than replacing the light source solution.

Simultaneously Update Technical Documentation and Supply Chain Declarations

Manufacturers need to clearly indicate the applicable EN 62471 version number in product manuals, technical specifications, and the EC Declaration of Conformity, and request from key component suppliers a light source safety data sheet (SDoC) compliant with EN 62471:2026. This is both a necessary part of the CE conformity evidence chain and a way to reduce the risk of downstream customer audit concerns.

Editorial Viewpoint / Industry Observation

Observably, this enforcement marks a structural shift from ‘electrical safety + EMC’-centric CE compliance to ‘human-centric photobiological risk management’ in optoelectronic exports. Analysis shows the new pulse-source requirements are not merely incremental updates—they reflect EU’s broader regulatory intent to anticipate AI-integrated sensing systems where dynamic illumination patterns (e.g., structured light scanning, time-of-flight gating) increase retinal exposure unpredictability. From industry perspective, the bottleneck is less about technical feasibility and more about fragmented testing capacity and inconsistent interpretation of ‘intended use’ scenarios across labs—especially for industrial sensors deployed in controlled environments.

Conclusion

The mandatory implementation of EN 62471:2026 is essentially an institutional confirmation of the stage in which infrared sensing technology evolves from ‘functional realization’ to ‘human-factor safety’. It not only constitutes a trade barrier, but also drives the upstream material selection, midstream module design, and downstream system integration across the industry chain to form a unified safety language. Rationally speaking, enterprises that complete certification first are expected to establish a differentiated label of ‘safe and trustworthy’ in the EU market, while passive responders may face a redistribution of order share. What deserves further attention at present is whether this regulatory logic will extend to other regional markets (such as UKCA, ANATEL) or emerging technology scenarios (such as in-cabin monitoring, AR eye tracking).

Source Information

Official Journal of the European Union (OJEU) 2026/C 185/01, publication date: May 20, 2026; EN 62471:2026 "Photobiological safety of lamps and lamp systems," CENELEC published version, officially effective in March 2026. Matters requiring continued observation: the specific enforcement scale adopted by market surveillance authorities (MSAs) in EU member states regarding ‘industrial use exemption scenarios’; whether the European Committee for Standardization (CEN/CENELEC) will issue unified technical guidance (CWA) on pulsed light source testing methods.