• Electronic Product Regulations in the European Union: An Overview

    Posted on 14 Comments

    Are you planning to import and sell electronic products in the European Union? In this article, we explain to you the main applicable regulations and safety standards, according to your product.

    Mentioned Products

    • Laptops
    • TVs
    • Washing machines
    • Electronic toys
    • Electric razors
    • Household appliances
    • AC adapters
    • Battery-powered devices
    • Speakers

    RoHS

    RoHS is an EU Directive restricting the use of hazardous substances (e.g heavy metals) in electrical and electronic equipment. No matter what kind of electronic products you are importing, you must ensure that your products do not contain an excessive amount of restricted substances.

    Here are some examples of the restricted substances under RoHS:

    • Lead (Pb)
    • Mercury (Hg)
    • Cadmium (Cd)
    • Hexavalent chromium (Cr6+)
    • Polybrominated biphenyls (PBB)
    • Polybrominated diphenyl ether (PBDE)
    • Bis(2-Ethylhexyl) phthalate (DEHP)
    • Butyl benzyl phthalate (BBP)
    • Dibutyl phthalate (DBP)
    • Diisobutyl phthalate (DIBP)

    Some restricted substances can be easily found in solder, batteries and metallic parts. Therefore, importers should consider all parts of electronic products for RoHS compliance.

    RoHS Components

    It is essential to ensure RoHS compliance for each electronic component before mass production. Otherwise, if a single component is not compliant, the whole electronic product will be considered as non-compliant. Importers are responsible for informing and instructing their suppliers about RoHS requirements at an early stage.

    RoHS Lab Testing

    Not all electronic products’ suppliers can provide RoHS test reports. In that case, you might consider third-party lab testing for RoHS compliance. RoHS testing is a relatively inexpensive test as it’s on a per-component basis ( often starting from $10 per component).

    Here are some companies offering RoHS testing service:

    • QIMA
    • Bureau Veritas
    • SGS
    • Intertek
    • TUV

    Click here to find more RoHS lab testing companies for options.

    RoHS Symbol

    The RoHS Directive does not require any RoHS symbol, and RoHS symbols you might have seen on the market have no legal meaning by itself. However, many manufacturers attach a RoHS symbol to the box artwork, indicating that the component is RoHS compliant.

    Risks

    Electronic components are not exclusively manufactured as RoHS compliant. In other words, the ‘same’ electronic device can be assembled using either RoHS or non-RoHS compliant components. Further, mixing RoHS and non-RoHS components is also a risk as the final product must be compliant as a whole.

    Here are some methods that can help you reduce the risk of non-RoHS components being used to produce your electronic devices:

    1. Procure RoHS compliant components directly from component suppliers and arrange delivery to the device manufacturer

    2. Instruct your supplier to only procure RoHS compliant components

    3. Inform your supplier of upcoming RoHS component testing before shipment

    4. Send an inspector to collect components and submit to a testing company before assembly

    Electronics Products Standards in the EU

    Low Voltage Directive (LVD)

    The LVD covers electrical safety of electrical equipment operating with an input or output voltage between:

    • 50 and 1000 V for alternating current
    • 75 and 1500 V for direct current

    The LVD covers many consumer and industrial electrical equipment such as household appliances, cabless, AC adapters, and others. As such, most consumer electronics fall within the scope of the LVD. This is the case even if the device input voltage is less than 75 V, as the charger is therefore within the LVD scope.

    LVD Test Reports

    Most importers are not capable to verify LVD compliance (e.g. compliance with relevant EN and IEC electrical safety standards). Therefore, importers must either request an LVD test report from suppliers or book third party LVD lab testing.

    Third-party lab testing is a better option because it is specifically issued under your products and company. Reputable testing companies such as SGS and Intertek can provide comprehensive LVD services including certification, lab testing, conformity assessment, and others.

    LVD Testing Costs

    An LVD test cost can vary widely depending on the types of electronic equipment and testing required. In general, the cost starts at $300 and it can be increased accordingly. We suggest that you should request a free quotation based on your product type via testing companies.

    Risks

    The importation of unsafe electronics is a big problem in all EU member states – a problem that is only set to grow with the rise of international cross-border e-commerce. Far from all electronic devices, including phone chargers and other AC adapters, are designed to comply with the Low Voltage Directive. Electronics intended for sales in countries outside the EU are rarely designed to comply with the Low Voltage Directive.

    In other words, importers and Amazon sellers should not take LVD compliance for granted when sourcing products in China and other countries. Further, LVD compliance is not “accidental”, but requires that the product design adheres to the technical safety aspects outlined in the relevant EN and IEC standards.

    EMC Directive

    Electrical devices might interfere when they are placed close to each other. In this aspect, the EMC Directive ensures that such side effects are kept under reasonable control.

    More in detail, the EMC Directive limits electromagnetic emissions to ensure that electrical equipment doesn’t affect the functionality of nearby equipment.

    Covered products under the EMC directive include:

    • TV sets
    • GSM handsets
    • Radio featured products
    • Washing machines
    • Products that emit electromagnetically disturbances

    EMC Test Reports

    EMC certification is mandatory when importing products covered by the Directive. Importers must be able to provide test reports and certification for compliance requirements. Not many manufacturers can provide EMC test reports, therefore, third-party lab testing would be the only way to verify your products.

    Click here to find more EMC testing services companies.

    EMC Directive Testing Costs

    A full EMC compliance test cost might cost up to thousands of dollars. It depends on the device and also the number of EU countries to be covered.

    Radio Equipment Directive (RED)

    The RED provides a regulatory framework for placing radio equipment on the EU market. The RED provides a list of requirements regarding:

    • Safety and health
    • Electromagnetic compatibility
    • Efficient use of radio spectrum
    • Protection of privacy
    • Use of personal data
    • Fraud protection

    In particular, the RED covers products that feature Wi-Fi, Bluetooth or similar wireless functionalities. This includes electronic devices such as:

    • Wi-Fi enabled TV box
    • Bluetooth enabled speaker
    • 3G/4G/LTE/5G enable smartphone
    • RFID devices

    RED Test Reports

    Importers must request a RED test report from their supplier, even though only a few manufacturers can provide it. In the case your supplier can’t help you with test reports, RED testing companies can assist with the pre-compliance test, technical documents, performance tests, and other relevant services.

    Click here to find more RED testing companies for your wireless-enabled products.

    RED Testing Costs

    RED testing costs start at a few hundred dollars. Similar to other electronic product lab testing, the cost depends on the complexity of your product, and it can increase to a couple of thousand dollars.

    Equipment for Explosive Atmospheres (ATEX)

    The ATEX Directive applies to electronic and electrical equipment that are potentially used in explosive atmospheres. Products with a potential ignition source fall into the scope of ATEX. For example, diesel engines, compressors, and electric motors.

    ATEX Test Reports

    ATEX testing is mandatory in order to protect users from explosion risks. Therefore, importers shall book third-party lab testing before placing the product in the EU market.

    Leading testing companies such as Eurofins, TUV, and Intertek provide ATEX services for full compliance assistance. Importers should instruct their suppliers and book third-lab testing if needed.

    ATEX Testing Costs

    In general, the cost ranges from a few hundred to a few thousand.

    Electronic Toys: Toy Safety Directive

    Product safety shall be the first priority when you are importing electronic toys to the European Union. The Toy Safety Directive lays down the safety requirements that importers must ensure before placing the product to the market.

    EN 62115

    The electrical safety standard for toys is EN 62155 as it has been harmonized under the Toy Safety Directive. EN 62155 requires that the product design must not jeopardize the health and safety of users in any foreseeable way. Here are some guideline provided by the standard EN 62115:

    • Specific markings for toys with buttons
    • Testing method for electric toys used in water
    • Mechanical resistance requirements
    • Specific requirements for radio-controlled ride-on toys
    • Screws and connections requirements

    EN 62115 serves as a great reference point for product safety, and it is beneficial especially for the importers at the product design stage.

    EN 71

    On top of EN 62115, electronic toys also need to comply with the requirements of EN71. EN71 is a set of standards that applies to all toys sold in the EU, and electronic toys shall meet certain minimum safety standards as follows:

    • EN 71-1: Mechanical and physical properties
    • EN 71-2: Flammability
    • EN 71-3: Specification for migration of certain elements
    • EN 71-4: Experimental sets for chemistry and related activities
    • EN 71-5: Chemical toys (sets) other than experimental sets
    • EN 71-6: Graphical symbols for age warning labeling

    Lab Testing

    Third-party lab testing is mandatory in most cases. Importers shall reach out to testing companies before mass production. Testing companies can help importers access to applicable EN standards, and perform necessary lab testing based on your products.

    Note: When your electronic toys enter the EU market, market surveillance authorities often request test reports to check compliance.

    Click here to find a list of testing companies for your electronic toys.

    Ecodesign Directive

    Ecodesign is an ecologic directive that encourages energy-efficient products imported in the European market. The directive applies to a wide range of products including air conditioners, washing machines, television, and many other electrical products.

    Test Report

    The Ecodesign Directive set limits to energy-saving, energy efficiency, and other ecological requirements. Testing companies such as TUV and Intertek, provide services including:

    • Energy-saving testing report
    • Factory inspection
    • Certipedia management systems
    • Product life cycle analysis
    • Energy efficiency labeling

    We suggest that you shall use a third-party company service as the directive is mandatory for all energy-using and energy-related products imported to the European Union.

    Energy Labeling

    EU energy label

    Under the directive, importers shall include energy labels on the product and its packaging. The label shall also include information such as energy savings information, ecodesign requirement, and the ranking of energy consumption.

    For example, the rank of energy consumption shall present in ten classes from A+++ to G (from the best to the worst consumption classification).

    CE Marking

    CE Mark

    As mentioned, importers must carry the CE mark if the electronic product is covered by any CE directives (e.g. LVD, RED, EMC). The CE mark indicates conformity with requirements when importing and selling in the EU market.

    The CE mark must be permanently affixed to the product and its packaging. Note that the CE mark requires more than just a sticker, importers must ensure conformity with all applicable requirements via lab testing and different assessments.

    CE label file

    Your suppliers have no responsibility to create the CE label file for your electronic product. Instead, you shall provide the CE mark label, and communicated all relevant information to the supplier, such as:

    • Dimensions
    • Position
    • Color
    • Print type

    Product Traceability

    Additionally, importers also need to attach a permanent traceability code to the products, showing the information such as:

    • SKU
    • Manufacturing date
    • Production facility
    • Country code

    Example: SKU-2020-01-CN

    CE Documentation

    For CE compliance, importers will also need to provide compliance documents such as the Declaration of Conformity (DoC), User Manual and Technical Files.

    Declaration of Conformity (DoC)

    The Declaration of Conformity shall include information such as:

    • Produce identification/SKU (e.g. Dishwasher Model Y)
    • Product features
    • Name and address of the manufacturer/importer
    • List of EN standards or directives
    • Manufacturing location
    • Responsible individual

    The DoC is often requested by the market surveillance organization, retailers, and even end-consumers.

    User Manual

    Importers must also provide a user manual for their electronics products. The user manual shall include information such as:

    1. Instructions on how to install the product

    2. An overview of the relevant parts and part names of the product

    3. Safety instructions

    4. Instructions on how to use the product

    5. Instructions on how to recharge and/or refill the product and

    6. Instructions on how to dispose of the product in an environmentally friendly manner

    In some cases, there might not be enough space for the CE mark on the products. Commonly, manufacturers or importers would include the CE mark in the user manual instead.

    Technical File

    The technical file is also required under the CE compliance requirements. It is a set of documents that describes a product to prove that it was designed according to the applicable requirements. Technical files include:

    • Bill of materials
    • Design drawings
    • Label files
    • Packaging files
    • List of applied standards and directives (e.g. RoHS, LVD or EMC)
    • Test reports
    • QC reports
    • Risk assessment

    Test Report

    Technical files should include all relevant test reports for supporting the compliance statement on the Declaration of Conformity (DoC).

    WEEE Symbol

    WEEE Mark

    WEEE is the acronym for “Waste of Electrical and Electronic Equipment”. All electronic products must be labeled with the WEEE symbol. The WEEE symbol shall be permanently printed on the product and its packaging.

    WEEE label file

    Similar to the CE mark label, importers shall provide the label file and provide information to suppliers such as:

    • Dimensions
    • Position
    • Color
    • Print type

    Other Regulations

    General Product Safety Directive (GPSD)

    The GPSD applies to all products placed in the EU market. GSPD ensure that product must be safe in order to protect consumers’ health and safety. GSPD requires a self-issue risk assessment to prevent accidents and health issues. Click here to learn more about the General Product Safety Directive (GPSD).

    REACH

    REACH restricts chemicals and heavy metals in all consumer products sold in the EU, including electronics. Unlike RoHS, REACH is not applicable specifically to electronic components, but all materials – such as the plastic casing.

    Note that some plastic materials, hardware parts, coatings, paints, and print inks used in the electronics industry don’t comply with REACH.

    Directive 94/62/EC: Packaging Regulations

    When selling products in the EU market, it is also essential to comply with the packaging regulations. For example, the packaging material shall not contain excessive amounts of heavy metal or any other hazardous substances. Note that Directive 94/62/EC is not exclusively applicable to electronic product packaging, but all packaging materials placed on the market in the EU.

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    Disclaimer: The content on this website is provided for general information only. The content includes summaries written by our team members based on publicly available information about product safety standards, labeling, documentation, testing, processes, and other product compliance related topics. However, we don’t guarantee that we cover every single relevant regulation/standard/requirement, or that the information is free from errors, or covering every single scenario and exemption. We do make mistakes from time to time. We never provide legal advice of any sort.

    Changes/Updates: Product standards and substance restrictions are subject to frequent updates and changes. In addition, new regulations, standards, and/or requirements may also become effective at any time. We don’t update our articles whenever new standards/regulations/rules are added or changed. We recommend that you consult a lab testing company or other professional to get the latest information about mandatory standards/regulations in your market, country, or state. Lab testing companies generally stay up to date on new and updated standards and regulations.

    National/State-Level Standards/Regulations: Many articles don't cover all European national and US state standards, regulations, and requirements. We recommend that you consult a testing company or other professional to confirm all relevant (and current) national/state level standards and regulations.
  • 14 Responses to “Electronic Product Regulations in the European Union: An Overview

    1. Natalie at 5:32 pm

      Hello, I work for a company that has just discovered they do not have EcoDesign for product that’s been on the market for 7 years. The work has started to correct newly manufactured product, but is there a penalty to the existing stock being out on the market and the company knowingly selling it without the EcoDesign?

      1. Fredrik Gronkvist at 2:16 pm

        Yes, I don’t think this will make your products exempt in any way. You should probably seek legal advice on how to manage this situation.

    2. Chan Do at 3:50 pm

      Hi,
      We have car chargers will be sold in EU. we are now processing
      – CE mark (safety, EMC, RED directive);
      – RoHS
      – REACH
      – WEEE
      Could you help to advise any other regulation else applied for car chargers?

    3. maria at 5:40 pm

      Hello, thank you for the info! Do you know whether it is mandatory to provide a hard-copy manual in the packaging or can that be offered online?

      1. Fredrik Gronkvist at 12:21 pm

        Hi Maria,

        I am not sure if that is addressed in the directives but I would still provide a hard copy manual.

    4. Joe Phelps at 5:35 am

      Dear Sir Madam,
      I work for a company that build custom industrial computers. This is to say (in this instance) we integrate the industrial computer and build a computer using other CE parts, i.e. a PSU, motherboard, hard drive etc etc.

      I have a customer that is selling in to Europe on boats. Although he does not need marine certification, he has requested something with a CE mark on the box. What is the quickest way to achieve this? What is the rough cost?

      1. Fredrik Gronkvist at 10:02 am

        Hi Joe,

        The first step would be to contact a lab like Intertek or SGS and ask them for a quote.

        You will also need to issue the DoC, technical file, and user manual.

    5. josh at 9:28 am

      Very helpful guide, and a good overview of necessary compliance requirements. What compliance would cover non-toy products, if any?

      1. Fredrik Gronkvist at 1:18 pm

        I would need to know more specifically what kind of product you have in mind. Non-toy product is a very broad description.

    6. josh at 9:25 am

      Very helpful guide, and a good overview of necessary compliance requirements

      1. josh at 9:31 am

        Is there any compliance/directive for low voltage devices (non-toys), less than 50V? Such as a phone power bank.

        1. Fredrik Gronkvist at 1:18 pm

          Yes, many, as you can see in the guide.

    7. Vipashi Trivedi-Sheth at 5:23 am

      Hello,
      This does not include the requirements to register and report with each Member states for WEEE.

      1. Fredrik Gronkvist at 2:22 pm

        We are planning to cover that in a separate guide

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