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Regulation (EU) 2023/988 · Article 16
Electronics carry four obligations that sellers keep mistaking for one.
A power bank entering the Union touches product safety, electromagnetic compatibility, restricted substances and waste registration. Each has its own paperwork, and only one of them is satisfied by a factory certificate.
Four rules, one product
CE marking covers conformity, RoHS covers restricted substances, WEEE covers end-of-life registration in each member state, and the General Product Safety Regulation covers the residual safety obligations and the responsible person.
WEEE in particular is national rather than European, which surprises sellers who assume one registration covers the Union.
Batteries change the picture
Products with lithium cells attract more attention at the border and in the alert system, and they bring transport rules of their own. The documentation expected is correspondingly heavier.
If your catalogue includes cells, assume the file will be requested at some point rather than hoping it will not.
Chargers, adapters and the plug
Mains-connected accessories are checked frequently and fail often, usually on insulation distances or on markings that do not match the tested sample.
A certificate that refers to a slightly different model is worse than no certificate, because it invites a closer look at everything else.
The four things you receive
Mandate, label block, live verification code and a staffed contact address inside the Union, all issued the same working day.
Every one of them is meant to be checked by someone who has no reason to believe you.
Built to be verified by a sceptic
We assumed from the start that the person reading your label would rather not take your word for it.
Everything in the service is shaped around that assumption, which is why it holds up when it is tested.
Questions we are asked
Does the responsible person handle my WEEE registration?
Not as part of the Article 16 role. WEEE registration is national and separate; we tell you where you stand but the registrations are made in each member state where you sell.
Is CE self-declaration enough for consumer electronics?
For many categories yes, provided the tests behind it are real and the file supports them. The declaration is a statement of responsibility, not a formality.
What if my supplier's certificate names a different model?
Then it does not cover the product you are selling. Mismatched certificates are one of the most common findings, and correcting them is far cheaper before a shipment than after a hold.
With electronics the obligations do not stack neatly, and the only workable approach is to treat each one as separate until it is proven satisfied.
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