- Directive 2014/35/EU — Low Voltage
- Directive 2014/30/EU — EMC
- Regulation (EU) 2017/1369 — energy labelling
- Directive 2014/53/EU where connected
- Regulation (EU) 2016/679 — GDPR for mapping robots
- Directive 2012/19/EU — WEEE
Who has to appoint one
Manufacturers and sellers outside the Union placing cleaning appliances on the EU market. Robot vacuums with cameras or lidar that upload maps of homes to a cloud service also process personal data of EU users, which triggers a separate representative obligation.
Thresholds and exemptions
None for the electrical rules. Connectivity brings the Radio Equipment Directive and, from 2027, the Cyber Resilience Act.
What must appear on the label
CE marking, manufacturer and EU representative details, model and batch identification, rated voltage and power, the WEEE symbol, and for connected models the frequency bands and transmitted power in the instructions. In the app, the identity of the Article 27 representative.
Marketplace fields
Marketplaces require the EU responsible person and a WEEE number per country. Robot vacuums have attracted attention over camera streams and cloud storage of home maps, and several models have been criticised publicly after researchers accessed feeds.
Documentation you must hold
EU declaration of conformity covering LVD, EMC, RoHS and RED where applicable. Technical file with thermal, insulation and abnormal operation test reports, battery documentation, and cybersecurity documentation under EN 18031 for connected models. WEEE, battery and packaging registrations. On the data side, the Article 30 record, the Article 27 designation, the retention policy for maps and images, and the transfer mechanism.
Standards and testing
EN 60335-2-2 for vacuum cleaners, EN 55014 for EMC, IEC 62133 for lithium packs, and for connected products the radio standards and EN 18031. Steam cleaners additionally require pressure-related safety assessment under the appliance standard.
Language requirements
Instructions and warnings in the language of each member state of sale, and privacy information in the language of the user.
When it applies
Product documentation before placing on the market. WEEE, battery and packaging registration before the first shipment into each country. The GDPR representative before EU users' data is processed.
How long records are kept
Ten years for the technical documentation. Home maps and camera images must not be kept longer than necessary, and indefinite cloud retention is an infringement in itself.
What happens if you do not comply
Withdrawal and Safety Gate alerts for electrical and battery hazards, marketplace suspension for missing WEEE numbers, and data protection fines up to €20 million or 4% of turnover where images or maps of homes are processed without a proper basis or kept indefinitely.
Who enforces it
Market surveillance authorities, WEEE registers, radio regulators, and data protection authorities for the mapping and camera functions.
Where the boundary lies
A corded vacuum is a straightforward electrical product. A connected robot with a camera is simultaneously radio equipment, a battery producer obligation, a CRA product from 2027 and a GDPR controller processing images inside people's homes. Sellers routinely handle the first and miss the rest.
Questions we are asked
- Does a robot vacuum really need a GDPR representative?
- If it maps or films homes of EU users and that data reaches your servers, yes. Interior maps and images of a dwelling are personal data of the people who live there.
- Do we need a battery registration for a cordless vacuum?
- Yes, in every member state you ship to, in addition to WEEE and packaging.
Who signs for you
EU representative Europe Services, SE — Na Čečeličce 425/4, Smíchov, 150 00 Praha 5, Czech Republic
UK representative REP27 LTD — Unit 82a James Carter Road, Mildenhall, Suffolk IP28 7DE, United Kingdom