Electrical and electronic equipment

• Directive 2014/35/EU — Low Voltage
• Directive 2014/30/EU — Electromagnetic Compatibility
• Directive 2011/65/EU — RoHS
• Directive 2012/19/EU — WEEE
• Regulation (EU) 2019/1020 — Article 4
• Regulation (EU) 2023/1542 — Batteries, where fitted

Who has to appoint one

Manufacturers outside the Union placing electrical products on the EU market directly, through distributors or through marketplaces. Importers who put the product on the market under their own name become the manufacturer. Distance sellers shipping to EU consumers without an importer, fulfilment provider or authorised representative established in the Union are prohibited from placing the product on the market at all under Article 4 of Regulation 2019/1020.

Thresholds and exemptions

The Low Voltage Directive applies from 50 to 1000 V AC or 75 to 1500 V DC; below that, EMC and GPSR still apply, so a USB-powered device is not unregulated. RoHS applies to all EEE in scope regardless of voltage. WEEE, battery and packaging producer registration thresholds are set nationally and are effectively zero for distance sellers in most member states.

What must appear on the label

CE marking. Manufacturer's name, registered trade name or trade mark and postal address. Name and EU address of the importer or authorised representative. Type, batch or serial number. Rated voltage, current or power, and any safety-relevant markings. The crossed-out wheelie bin symbol for WEEE. Where a battery is fitted, the battery markings including capacity and, for certain categories, the carbon footprint declaration phased in from 2026.

Marketplace fields

Amazon requires the EU responsible person, a WEEE registration number for every country you ship to, and a battery producer number where applicable, and blocks listings without them. Germany's LUCID packaging number and EAR WEEE number are checked automatically, as is France's UIN. Several marketplaces request the declaration of conformity when a listing is challenged, and refuse reinstatement without it.

Documentation you must hold

EU declaration of conformity covering every applicable directive in a single document. Technical file with design drawings, circuit diagrams, component lists and the risk analysis. Test reports against the harmonised standards. RoHS material declarations from suppliers, ideally with analytical evidence for high-risk components. Registration certificates for WEEE, batteries and packaging in each member state of sale, with the annual quantity declarations. Traceability records for ten years.

Standards and testing

EN 62368-1 for audio, video and information technology equipment, or EN 60335 series for household appliances. EN 55032 and EN 55035 for electromagnetic emissions and immunity. IEC 62133 for lithium cells. RoHS testing on homogeneous materials for the ten restricted substances, including the four phthalates. Where a wireless function exists, the Radio Equipment Directive applies instead of the Low Voltage Directive and brings its own tests.

Language requirements

Instructions, safety information and warnings in the official language of each member state where the product is made available. The declaration of conformity must be translated into the language required by the state where the product is placed on the market. Take-back information under WEEE must be in the national language.

When it applies

Conformity documentation before the first unit is placed on the market. WEEE, battery and packaging registrations before the first shipment into each individual country — not before the first sale in the Union, because these are national obligations and shipping into Germany without an EAR number is unlawful from the first parcel.

How long records are kept

Technical documentation and the declaration of conformity for ten years after the last unit was placed on the market. WEEE and packaging declarations per national law, generally five to ten years. Registration numbers must remain valid: an expired registration is treated as no registration.

What happens if you do not comply

Customs refusal at the border, which for electrical goods is common because the CE marking and the EU address are easy to check. Withdrawal and recall orders. Marketplace suspension for a missing WEEE or packaging number, which happens automatically. Separate national fines for each missing environmental registration, charged per country and often with retroactive recycling fees for volumes already sold. Germany and France are the most active enforcers.

Who enforces it

National market surveillance authorities, national WEEE and battery registers, packaging compliance schemes, and customs. Notified bodies are rarely involved, since most electrical products are self-declared.

Where the boundary lies

The most expensive misunderstanding in this category is assuming an EU authorised representative covers everything. It does not: WEEE, batteries and packaging are national extended-producer-responsibility obligations requiring registration and, for non-established sellers, an authorised representative in each member state. A Prague-based Article 4 operator satisfies the CE-marking side and nothing else. Second edge: adding Bluetooth or Wi-Fi moves the product to the Radio Equipment Directive, which since August 2025 also carries cybersecurity requirements.

Questions we are asked

Is one WEEE registration enough for the EU?

No. WEEE is national by design: Germany, France, Spain, Italy and every other member state maintain their own register, fee structure and reporting cycle.

Our product runs on 5 V USB — do we still need CE marking?

The Low Voltage Directive does not apply below 50 V, but EMC and RoHS do, and so does GPSR. The product still carries CE marking on the basis of the directives that apply, and still needs an EU economic operator.

Can we use our supplier's declaration of conformity?

Only if the supplier is the manufacturer and the product is placed on the market under its name. If you sell under your own brand you are the manufacturer in law and the declaration must be issued in your name, on your technical file.

What does a Safety Gate alert actually cost us?

Beyond the recall, the alert is public and permanent, names the brand and the country of origin, and is consulted by every other member state's authority and by marketplaces when assessing future listings.