RED, LVD and EMC Directives Explained for Electronics Sellers: the applicable rules depend on what your product actually does, not its marketing name. Radio equipment will usually fall under the Radio Equipment Directive (RED); non-radio electrical equipment may fall under the Low Voltage Directive (LVD) and the Electromagnetic Compatibility Directive (EMC). Before placing it on the EU market, the manufacturer must assess conformity, compile evidence, sign an EU declaration of conformity and affix CE marking where required.
Key takeaways
- Equipment that intentionally emits or receives radio waves for communication or radiodetermination will generally fall within Directive 2014/53/EU, known as RED.
- For radio equipment, RED includes the electrical-safety and electromagnetic-compatibility requirements it sets out; do not simply add LVD and EMC to RED for the same risks.
- Directive 2014/35/EU applies to electrical equipment designed for use between 50 and 1,000 V AC or between 75 and 1,500 V DC.
- A test report, technical documentation, EU declaration of conformity and supplier certificate are different documents with different functions and evidential value.
- CE marking follows a conformity-assessment process carried out by the manufacturer; it is not a universal certificate or a logo that can be purchased.
Does my product fall under RED, LVD or EMC?
The answer depends on the product’s design and intended use, rather than its product title. Start by identifying any intentional radio function, the operating voltage, supplied components and functions that may create or be affected by electromagnetic disturbance.
RED for radio equipment
The Radio Equipment Directive 2014/53/EU, or RED, covers equipment that intentionally emits and/or receives radio waves for radio communication or radiodetermination. Bluetooth headphones, Wi-Fi cameras, smart watches, radio remote controls, Zigbee sensors, trackers with radio communications and RFID readers may therefore fall within its scope.
For radio equipment, RED contains its own essential requirements covering, among other matters, health and safety, electromagnetic compatibility and efficient use of radio spectrum. In practice, do not assume that RED, LVD and EMC must be stacked for the same risks. Assess RED first, then consider other legislation that may apply to the complete product, its battery, charger or specific use.
Example: a wired speaker with no radio connectivity, powered from the mains, may need assessment under LVD and EMC. Add Bluetooth to that same speaker and it becomes radio equipment, so RED should be assessed first.
LVD and EMC for non-radio equipment
The Low Voltage Directive 2014/35/EU covers electrical equipment designed for use between 50 and 1,000 V alternating current and between 75 and 1,500 V direct current. It addresses electrical-safety risks such as electric shock, overheating, fire and hazards arising from reasonably foreseeable use.
The Electromagnetic Compatibility Directive 2014/30/EU requires equipment not to generate excessive electromagnetic disturbance and to have adequate immunity in its intended environment. EMC therefore concerns both what the device emits and whether it can operate without unacceptable interference.
A display, power supply, electrical kitchen appliance or mains charger may need this assessment. A 5 V USB device sits outside the LVD voltage range, but that does not remove every obligation: EMC, RED where it has a radio function, GPSR and battery rules may still matter.
If you are launching a range or selling into several countries, an EU market entry compliance assessment helps you map the CE, GPSR, customs, VAT and environmental checks to review. It flags matters to check; it does not replace the manufacturer’s technical assessment.
What must the manufacturer do before applying CE marking?
The manufacturer must demonstrate that the product meets the requirements of applicable legislation before it is first placed on the EU market. CE marking is the visible outcome of that work, not the starting point.
The European Commission’s CE marking guidance explains that the mark indicates conformity with applicable EU harmonisation legislation. A document labelled “CE certificate”, a supplier promise or a photograph of a logo does not, on its own, demonstrate conformity of the model you sell.
The conformity sequence to follow
For each product reference and variant, the manufacturer will generally need to:
- define the product, intended use, users and reasonably foreseeable use;
- identify applicable legislation and the corresponding essential requirements;
- select the conformity-assessment procedure required by that legislation;
- produce or obtain suitable technical evidence, including relevant testing;
- compile the technical documentation;
- draw up and sign the EU declaration of conformity;
- affix CE marking and provide the required information, warnings and instructions.
Harmonised standards can make it easier to demonstrate conformity where they cover the relevant requirements. They do not remove the need to assess the actual product. A change to the antenna, Wi-Fi module, power supply, battery, firmware or enclosure may affect whether existing evidence remains valid.
The European Commission’s 2022 Blue Guide is a useful reference for understanding placing on the market, economic-operator roles and the logic of CE marking. To organise the expected evidence, see this guide to CE technical documentation.
EU Seller Kit — If you are a non-EU manufacturer of a CE-marked product, the CE authorised representative service may be appropriate where the applicable CE legislation permits a written mandate. It becomes active only after acceptance, entity assignment, a signed mandate and active payment; it does not replace the manufacturer’s conformity assessment, testing, technical documentation or EU declaration of conformity.
Which documents should I request and keep?
You need to be able to link every item of evidence to the exact product placed on the market. A test report is technical evidence; technical documentation brings evidence together; an EU declaration of conformity is the manufacturer’s signed statement; and a supplier certificate may be no more than a commercial document with limited value.
Do not confuse the four key documents
| Document | Purpose | What it does not prove on its own |
|---|---|---|
| Test report | Results of tests on a defined sample and configuration | Overall conformity of every variant |
| Technical documentation | The evidence needed to assess conformity | Approval issued by an authority |
| EU declaration of conformity | The manufacturer’s signed declaration for the identified product and applicable legislation | Quality or safety of models not covered |
| Supplier “CE certificate” | May be commercial information or limited evidence | Regulatory conformity of the product sold |
Technical documentation may include a product description, drawings, bill of materials, risk assessment, applied standards, test reports, calculations, instructions, labels, photographs and the EU declaration of conformity. The exact content depends on the applicable legislation and the product.
Before ordering, ask the manufacturer for the exact model references covered, hardware and software versions, radio parameters where RED applies, labelling photographs and instructions. Also centralise the supplier’s identity, contact details and any inconsistencies using Supplier Check, particularly before a first order or factory change.
A common mistake is accepting a report issued for a similar model. A seemingly small difference, such as another mains adapter or a revised antenna, can change the tested configuration. Ask for a documented technical justification or fresh evidence where the coverage is unclear.
The EU declaration of conformity must match the legislation that actually applies and the identified product. This guide to the EU declaration of conformity: content, signature and supporting documents explains what to check before sale.
Who is responsible when I sell or import electronic equipment?
Your obligations vary depending on whether you are the manufacturer, importer, distributor or authorised representative. Your real role matters more than your commercial job title: selling under your own name or trade mark can make you the manufacturer for compliance purposes.
Decision No 768/2008/EC establishes a common framework for marketing products. The Blue Guide explains, in particular, that an EU-established importer placing a product from a third country on the Union market must verify that the manufacturer has followed the relevant conformity-assessment procedure.
Roles to keep separate
The manufacturer is the entity that makes a product, or has it designed or manufactured, and markets it under its own name or trade mark. It holds the primary responsibility for conformity assessment, technical documentation and the EU declaration of conformity.
The importer is the EU-established operator that places a product from a third country on the Union market. It must carry out the required checks, ensure required information is present and cooperate with competent authorities.
A distributor must act with due care. It cannot ignore missing CE marking where it is required, clearly unsuitable instructions, an unidentifiable model or missing operator details. An authorised representative, when appointed under the relevant conditions, acts within a written mandate; it does not take over the manufacturer’s design and conformity responsibilities.
Imagine a US manufacturer shipping Wi-Fi cameras to an Amazon FBA warehouse in Germany. The camera will probably fall under RED. The importer must be able to substantiate its checks, while the online offer must display the applicable safety and traceability information for distance sales.
For consumer products, Regulation (EU) 2023/988 on general product safety sets information obligations for distance sales. Check, in particular, product identification, manufacturer contact details and, where the manufacturer is not established in the EU, the details of the EU responsible person, together with relevant warnings and safety information.
Before publication, the Marketplace Product Compliance Scanner reviews a product listing and flags traceability, safety and compliance information to verify. It does not technically approve the device and does not replace the CE file.
How do I prepare electronic-product compliance step by step?
Treat every product and variant as a separate reference until you have evidence showing otherwise. This approach reduces gaps between the product ordered, the documents received, the labelling and the marketplace listing.
Practical procedure
- Freeze the configuration you will sell. Record the reference, brand, hardware version, firmware, power supply, accessories, ports, batteries and radio modules. A Wi-Fi camera supplied with a mains adapter is not simply a “camera”: several elements affect its assessment.
- Classify its functions. Identify intentional radio transmission or reception for RED. For a non-radio product, check the voltage range and EMC aspects. Add any sector-specific legislation, for example for toys or batteries.
- Collect source documents before ordering. Request reports, the EU declaration of conformity, cited standards, instructions and photographs of the final product. Do not rely on a generic file sent through a B2B marketplace.
- Check consistency. The manufacturer, model reference, voltage, radio functions and version should match across the product, reports and declaration. Every discrepancy needs an explanation and supporting record.
- Prepare labelling and languages. Check CE marking where required, product identification, necessary contact details, warnings and instructions in the languages required in your target countries.
- Prepare for distance selling. Put the required safety and traceability information on the product page. A listing does not substitute for product marking or technical documentation.
- Reassess changes. A new supplier, substituted component or software update can require a conformity review. Do not automatically reuse documents from an earlier version.
Checklist before shipment or listing
- The commercial reference, hardware version and accessories match the available documents.
- The radio function has been identified and relevant parameters reviewed where RED applies.
- LVD and EMC requirements have been assessed for relevant non-radio products.
- The EU declaration of conformity is signed, legible and consistent with the product sold.
- Test reports cover the relevant configuration, or an equivalence is documented.
- CE marking, product identification and required contact details have been checked.
- Instructions, warnings and safety information are available in the languages of the intended markets.
- The ecommerce listing contains the information required for distance sales.
- WEEE, batteries, packaging, import and VAT matters have been reviewed separately.
What else must I address: GPSR, WEEE, batteries, customs and VAT?
CE marking does not replace general-product-safety duties, import formalities or environmental schemes. A product can be technically compliant yet still be incomplete for online sale, import or placement on a particular national market.
GPSR and online-sales information
GPSR applies to many consumer products and complements sector-specific assessment. For a distance offer, required information must be available before purchase; an instruction leaflet placed in the parcel will not always be enough. The guide to Amazon GPSR compliance information for sellers helps you structure the information to publish on a listing.
Where a non-EU manufacturer has no other suitable EU-established economic operator, a GPSR responsible person may be needed for the consumer product. The EU GPSR Responsible Person service becomes active only after product review, entity assignment, a signed mandate and active payment; a SaaS subscription alone does not appoint a responsible person.
WEEE, cells and batteries
Electrical and electronic equipment may be subject to national schemes implementing the WEEE Directive 2012/19/EU. Cells and batteries also have their own framework, including Regulation (EU) 2023/1542 on batteries and waste batteries.
These duties do not replace CE compliance. Depending on the country and your role, they can involve registrations, reporting and contributions towards collection and treatment. Review the guide to WEEE and battery producer registration for selling electronics in Europe before starting cross-border sales.
Importing, EORI and tariff classification
If you ship from Shenzhen to an FBA warehouse in Germany, keep product compliance separate from the customs transaction. You must also consider tariff classification, customs value, duty, import VAT and who acts as importer. The European Commission describes EORI as the registration and identification number used in dealings with customs authorities.
The HS classification assistant generates candidate subheadings that you should confirm in the Combined Nomenclature or TARIC. To structure known shipment costs, use the customs cost simulator, which calculates duties only where a valid tariff rate is available. EORI file preparation is a one-off service unless included in a plan quota, and the number itself is issued by the competent customs authority.
EU Seller Kit — Before your first EU shipment, use the EU market entry compliance assessment to organise product, customs, VAT and environmental checks. For import costs and documents, combine the HS classification assistant with the customs cost simulator; see pricing and plans for available options without assuming that any service covers a particular regulatory obligation.
Which mistakes lead to listing blocks or authority requests?
Problems often arise because the actual product does not match the evidence presented for it. A platform may suspend a listing, a market-surveillance authority may request a file or require corrective action, and customs may hold goods for separate reasons.
Treating a Bluetooth device as an EMC-only product
A Bluetooth device is generally radio equipment. Your assessment should therefore start with RED. Conversely, an electronic product without intentional radio functionality does not fall under RED merely because it contains a circuit board.
Reusing documents for another model
A report for an earlier version, different power supply or different antenna may not cover the product being sold. This issue often emerges after an Amazon request or a market-surveillance inspection. Regulation (EU) 2019/1020 on market surveillance and compliance of products provides the framework for controls of products covered by EU harmonisation legislation.
Adding the CE logo afterwards
CE marking does not cure the absence of an assessment, evidence or EU declaration of conformity. Where required, it must reflect conformity that has genuinely been established. Adding a logo to the product or listing without a coherent file can lead to document requests, a sales suspension or corrective measures.
Omitting information from the product listing
An online listing should be prepared as a compliance item in its own right. Check traceability data, relevant contact details, warnings and safety information before publication. If your listing is already suspended, this guide to an Amazon listing blocked for compliance helps you structure the points to review.
Assuming a representative replaces the manufacturer
A CE authorised representative acts within the limits of its mandate. A GPSR responsible person has a separate role. Neither service turns an unassessed product into a compliant one, and neither replaces the manufacturer’s testing, technical documentation or EU declaration of conformity.
Tools and services to take action
- EU Market Entry Compliance Assessment: use it before a first shipment or new product range to identify CE, GPSR, customs, VAT, WEEE, battery and packaging checks to review.
- Marketplace Product Compliance Scanner: use it before publishing on Amazon, eBay, Etsy, Shopify or another marketplace to identify product-page information that needs checking.
- CE Authorised Representative: consider it if you are a non-EU manufacturer and a written mandate is appropriate under applicable CE legislation; activation requires acceptance, entity assignment, a signed mandate and active payment.
- GPSR Responsible Person (EU): use this service where a consumer product made outside the EU needs an EU-established responsible economic operator; a subscription alone does not appoint that person.
- EU compliance tools: access self-service tools for customs, VAT, HS classification, country requirements and supplier checks according to your trading flow.
Frequently asked questions
Does a Bluetooth product fall under EMC or RED?
A Bluetooth product is generally radio equipment and falls first under RED 2014/53/EU. RED includes electromagnetic-compatibility requirements for radio equipment. You must still check other rules that apply to the complete product, including its battery, charger or particular use.
Is a 5 V USB-powered device exempt from CE marking?
No. A device designed to operate at 5 V falls outside the LVD voltage range, but it may be covered by EMC, RED if it has a radio function, or other sector-specific rules. Whether CE marking is required depends on all applicable EU harmonisation legislation, not on supply voltage alone.
Do I need a notified body for every electronic device?
No. Whether a notified body is involved depends on the applicable legislation, the conformity-assessment procedure and the product’s characteristics. In many cases, internal assessment is possible where the legal conditions are met; check the relevant directive and seek competent advice where there is technical uncertainty.
Can I sell a CE-marked product made in China?
Yes, provided the product genuinely complies with applicable legislation and the relevant economic operator meets its obligations. The country of manufacture does not remove the manufacturer’s conformity-assessment duties or the importer’s verification duties. You must also consider GPSR, distance-selling, customs and environmental obligations that apply to your flow.
Must the EU declaration of conformity be supplied with every product?
The method of making it available depends on the legislation that applies. For some equipment, a full or simplified EU declaration of conformity may need to accompany the product, while technical documentation must be kept available for authorities. Check the RED, LVD or EMC requirements that apply to your product and market.
Do WEEE and battery obligations replace CE marking?
No. WEEE and battery rules concern, among other matters, end-of-life collection and financing, with national implementation arrangements. CE marking concerns prior conformity with applicable EU harmonisation legislation, so both sets of duties must be handled separately.
Official sources
- Directive 2014/53/EU — radio equipment (RED) — scope and essential requirements for radio equipment.
- Directive 2014/35/EU — low voltage electrical equipment (LVD) — safety requirements for equipment within the specified voltage ranges.
- Directive 2014/30/EU — electromagnetic compatibility (EMC) — electromagnetic-compatibility requirements for equipment.
- Regulation (EU) 2023/988 — General Product Safety Regulation (GPSR) — consumer-product safety and information requirements for distance sales.
- Regulation (EU) 2019/1020 — market surveillance and compliance of products — framework for market-surveillance controls of relevant products.
- Decision No 768/2008/EC — common framework for the marketing of products — economic-operator responsibilities in the harmonised framework.
- Commission Notice — The 'Blue Guide' on the implementation of EU product rules (2022) — practical interpretation of placing on the market, CE marking and economic-operator roles.
- Directive 2012/19/EU — waste electrical and electronic equipment (WEEE) — EU framework for waste electrical and electronic equipment.
- Regulation (EU) 2023/1542 — batteries and waste batteries — EU rules on batteries and their end of life.
- European Commission — Economic Operators Registration and Identification (EORI) — the role of an EORI number in customs operations.
This content provides general information and is not legal advice.