EU compliance for connected products CE marking starts with identifying every radio, electrical and digital function before the device is placed on the market. A Wi-Fi, Bluetooth or cellular product will often fall within the Radio Equipment Directive (RED), while also needing to meet GPSR safety, traceability and consumer-information requirements. CE marking must be supported by evidence, not simply added as a label.
Key takeaways
- A device that intentionally transmits or receives radio waves will generally fall within Directive 2014/53/EU (RED) and needs a conformity assessment before it is placed on the EU market.
- The manufacturer remains responsible for conformity assessment, the technical documentation and the EU declaration of conformity, even where it appoints an authorised representative.
- Regulation (EU) 2023/988 requires safety and traceability information; for distance sales, specified information must also appear in the online offer.
- Before publishing a listing, check that the actual product, its labelling, CE documentation and consumer-facing information all match.
Which connected products need CE marking and GPSR compliance?
A connected product is not defined solely by whether it has a mobile app. A radio, electrical or safety function may trigger specific requirements. The GPSR supplements this framework for consumer products where sector-specific legislation does not fully address the risk concerned.
A Bluetooth fitness tracker, Wi-Fi camera, smart plug, GPS tracker or LoRaWAN sensor is radio equipment. Directive 2014/53/EU on radio equipment (RED) is therefore usually the central CE instrument. It covers, among other things, health and safety, electromagnetic compatibility and efficient use of radio spectrum.
In practice, describe the product as it is actually sold: mains supply or battery, Bluetooth or Wi-Fi module, included charger, app, sensors, intended users and accessories. One enclosure can combine several functions that matter for regulatory purposes.
Example: a US brand sells a mains-powered Wi-Fi camera to French consumers through Shopify. The camera is radio equipment; its power supply and charger also need analysis. The brand must also prepare safety and traceability information for the European consumer.
The EU Market Entry Compliance Assessment helps you organise CE, GPSR, customs, VAT and environmental checks when you are planning a first shipment or have not yet established which obligations apply.
EU Seller Kit — Use the EU Market Entry Compliance Assessment before launching a connected-product range if you need to map requirements by product, trade flow and selling country.
How do you identify CE rules for a Wi-Fi or Bluetooth product?
For EU compliance for connected products CE marking, RED is often the starting point, but it does not remove the need to assess other legislation relevant to the product, its components and its intended use. Classification follows the actual design, not the marketing name.
RED, EMC and low voltage: avoid misunderstood overlap
RED includes essential requirements on safety and electromagnetic compatibility for radio equipment within its scope. Do not automatically list legislation without checking the precise scope. Directive 2014/30/EU on electromagnetic compatibility and Directive 2014/35/EU on low-voltage electrical equipment remain relevant for products outside RED, or when separately supplied products and components need assessment according to their configuration.
For a practical explanation, see RED, LVD and EMC requirements for electronics sellers. If your supplier provides a generic “CE certificate”, do not treat it as sufficient evidence. Ask for test reports, applied standards, the EU declaration of conformity and exact model references.
Check standards and whether a notified body is involved
Harmonised standards can help demonstrate conformity with essential requirements, but they do not replace product analysis or the manufacturer's responsibility. In some cases, the assessment procedure may require a notified body. Check its identity and scope in NANDO rather than relying on a logo on a document.
A common mistake is to reuse the declaration for a similar product. A new antenna, firmware that changes a radio function, a different battery or a substituted charger can make that approach unreliable. Use Supplier Check to centralise supplier identity details and the documents you need to review before placing an order.
What does GPSR require for connected electronics?
GPSR requires consumer products to be safe and requires economic operators to ensure traceability, cooperate with authorities and take corrective action where needed. Regulation (EU) 2023/988 on general product safety has applied since 13 December 2024.
GPSR does not replace RED. It addresses general safety aspects that are not fully covered by sector-specific legislation. For a home camera, for example, assess overheating, charging, child access, small parts, inadequate instructions and reasonably foreseeable use.
Traceability and information for consumers
The product or, where that is not possible, its packaging or accompanying document must allow identification, for example through a type, batch or serial number. The manufacturer must be identifiable with contact details. Where the manufacturer is not established in the EU, the EU-based responsible operator must be identified where the applicable rules require it.
Warnings and instructions must be understandable in the market concerned. For France, provide information in French. English-only instructions can lead to a blocked listing or a request from a market-surveillance authority.
For distance sales, the offer must show the information required by GPSR Article 19, including product identification, the manufacturer's contact details and, where applicable, those of the responsible person in the EU, together with relevant warnings and safety information. Review what an online GPSR product listing must show before publication.
If you sell consumer products from outside the EU, you may need an EU GPSR Responsible Person. This service becomes active only after product review, entity assignment, a signed mandate and active payment; a SaaS subscription does not automatically appoint a responsible person.
EU Seller Kit — For Amazon, eBay, Etsy or Shopify sales, use the Marketplace Product Compliance Scanner to flag traceability, safety and compliance information to check before publishing.
How do you prepare technical documentation and sign the EU declaration of conformity?
Technical documentation must show why the product conforms; the EU declaration of conformity is the manufacturer's formal statement. Both must be ready before the product is placed on the market and retained as required by the applicable rules.
The manufacturer starts with a risk assessment and identifies the essential requirements. It then compiles design information, operating descriptions, drawings, bills of materials, assessments, test reports, applied standards and instructions. The European Commission's 2022 Blue Guide explains that the manufacturer affixes CE marking after completing the appropriate conformity-assessment procedure.
The EU declaration of conformity must identify the product, manufacturer and applicable legislation unambiguously. A person authorised to act for the manufacturer must sign it. One declaration can cover several instruments if it identifies them correctly; see the guide to EU declaration of conformity content, signature and supporting documents to check its structure.
Checklist before sale
- Describe every function: radio, power supply, battery, charging, software and accessories.
- Identify the applicable CE legislation and corresponding essential requirements.
- Confirm that test reports cover the exact model, hardware version and software version being sold.
- Build technical documentation that matches the product and its labelling.
- Sign a complete EU declaration of conformity before affixing CE marking.
- Prepare instructions, warnings and contact details in the language of the target market.
- Review the online listing before publication and retain document versions.
The guide to CE technical documentation and supporting evidence explains the records to assemble. If the manufacturer is outside the EU, it may appoint a CE Authorised Representative by written mandate where the applicable legislation permits it. That representative does not replace testing, conformity assessment, technical documentation or the manufacturer's declaration.
Who is responsible: manufacturer, importer, CE authorised representative or GPSR responsible person?
These roles can coexist in one supply chain, but they are not interchangeable. The right allocation depends on where the manufacturer is based, which CE legislation applies and how the product enters the EU market.
| Role | Main function | Key point |
|---|---|---|
| Manufacturer | Designs or has a product made under its name; establishes conformity | It has primary responsibility for CE documentation and the EU declaration of conformity. |
| Importer | Places a product from a third country on the EU market | It must check, among other things, that applicable requirements have been met before placing the product on the market. |
| CE authorised representative | Represents the manufacturer under a written mandate | Its mandate is limited; it does not become the manufacturer. |
| GPSR responsible person | EU-established operator for products concerned | Its GPSR role does not automatically create a CE mandate. |
Regulation (EU) 2019/1020 on market surveillance and product compliance includes requirements concerning an EU-established economic operator for certain products subject to Union harmonisation legislation. Do not assume that a fulfilment warehouse, marketplace or freight forwarder takes on this role. Check the contracts and the specific obligations.
Imagine a Shenzhen manufacturer sending stock to an Amazon FBA warehouse in Germany. Amazon may request compliance information, but the manufacturer, importer and EU-established operator need to be identified according to the route by which the product is placed on the market. The guide to CE importer obligations and pre-sale document checks helps you clarify what to verify.
What additional data should you plan for: WEEE, batteries and online sales?
CE marking does not complete the project. Electrical and electronic equipment, batteries, packaging and product data can create additional requirements depending on where you sell or hold stock.
Directive 2012/19/EU on waste electrical and electronic equipment (WEEE) provides for the collection and treatment of waste electrical and electronic equipment. Practical duties, including producer registrations, are implemented nationally. A smart watch with an integrated battery may also fall under Regulation (EU) 2023/1542 on batteries and waste batteries, whose obligations apply progressively by battery type and timetable.
A digital product passport is not an immediate general requirement for every connected product. Regulation (EU) 2024/1781 establishing the ESPR framework creates a framework that will be specified through product-category measures. It is still sensible to organise model, component, conformity and traceability data now.
Use Country Compliance to organise checks for your countries of origin, storage and destination. If you import from China into the EU, also check customs classification, duty and VAT. Those matters are separate from product compliance.
Tools and services to take action
- EU Market Entry Compliance Assessment — Use this before a first launch to build a plan for CE, GPSR, customs, VAT, WEEE, batteries and product-data checks based on your trade flows.
- CE Authorised Representative — Consider this where a non-EU manufacturer needs to appoint an authorised representative by written mandate, where the applicable CE legislation permits it.
- GPSR Responsible Person (EU) — Use this where a non-EU seller or manufacturer needs an EU-established responsible economic operator for consumer products, subject to formal service activation.
- Marketplace Product Compliance Scanner — Check an Amazon, Shopify, eBay or Etsy listing before publication to identify safety and traceability information that may need completing.
- Country Compliance — Use this when you store or sell in several countries and need to organise the country-specific checks to review.
Frequently asked questions
Does a USB charger sold with a connected product need to be covered by the compliance assessment?
Yes. A charger supplied with the connected product forms part of the offer and should be included in your conformity analysis. Its exact legal treatment depends on its characteristics and how it is marketed. Do not rely on generic paperwork: check the model identification, testing and matching instructions.
Does a mobile app make a product subject to RED?
No. RED applies to radio equipment: apparatus that intentionally emits or receives radio waves for communication or radiodetermination. An app by itself is not radio equipment, although the device it controls may be if it includes Bluetooth, Wi-Fi, cellular connectivity or another radio technology.
Can I rely on CE marking already applied by my Chinese supplier?
You can use evidence supplied by the manufacturer, but you must check that it relates to the product you actually import and sell. A CE logo alone does not demonstrate conformity. Obtain relevant technical documentation, test reports, the EU declaration of conformity and traceability information.
Is a CE authorised representative also the GPSR responsible person?
Not automatically. A CE authorised representative acts within the limits of a written mandate under applicable CE legislation, while a GPSR responsible person has a product-safety role. The same entity may sometimes carry out more than one function if legal and contractual conditions are met, but each role must be formally established.
What can happen if a marketplace product listing is incomplete?
The platform may ask for documents, suspend the listing or block the product under its procedures. A market-surveillance authority may also request information or require corrective measures where the product or sales information does not meet applicable requirements. Prepare documents before publication rather than trying to rebuild them under pressure.
Official sources
- Regulation (EU) 2023/988 — General Product Safety Regulation (GPSR) — safety, traceability and consumer information for consumer products, including distance sales.
- Directive 2014/53/EU — radio equipment (RED) — requirements for Wi-Fi, Bluetooth and other radio equipment.
- Directive 2014/30/EU — electromagnetic compatibility (EMC) — electromagnetic-compatibility requirements for equipment within its scope.
- Directive 2014/35/EU — low-voltage electrical equipment (LVD) — safety requirements for electrical equipment within its scope.
- Regulation (EU) 2019/1020 — market surveillance and compliance of products — market surveillance and the EU-established economic operator requirement for products concerned.
- Commission Notice — The 'Blue Guide' on the implementation of EU product rules (2022) — principles for applying EU product rules and CE marking.
- Directive 2012/19/EU — waste electrical and electronic equipment (WEEE) — waste electrical and electronic equipment requirements.
- Regulation (EU) 2023/1542 — batteries and waste batteries — requirements and timetable for batteries and waste batteries.
- Regulation (EU) 2024/1781 — Ecodesign for Sustainable Products (ESPR) — the framework for ecodesign and digital product passports.
This content provides general information and is not legal advice.