CE marking, RoHS, RED cybersecurity, FCC Part 15, WEEE, and APAC certifications - electronics compliance is the most directive-dense discipline in global product regulation. TGC delivers the technical documentation, conformity assessment support, and multi-market expertise to get your products to market legally and keep them there.
RED cybersecurity
requirements mandatory
for all EU
radio equipment
Source: EU Delegated Reg. 2022/30
No other product category sits under as many simultaneous regulatory frameworks as electrical and electronic equipment (EEE). A single connected consumer device sold in the EU may require conformity under RoHS, the EMC Directive, the Low Voltage Directive, the Radio Equipment Directive (including its mandatory 2025 cybersecurity requirements), and WEEE producer obligations - each with separate conformity assessment procedures, technical documentation, and a Declaration of Conformity.
EU and US compliance are entirely separate frameworks with no mutual recognition. EU market entry requires CE marking under multiple directives and an EU Authorised Representative for non-EU manufacturers. US market entry requires FCC authorisation under 47 CFR Part 15 - a fundamentally different process with no overlap with the CE framework. TGC delivers end-to-end electronics compliance support: directive mapping, technical documentation, conformity assessment coordination, EU and UK Authorised Representative services, FCC authorisation guidance, and ongoing RoHS exemption monitoring.
2025 and 2026 bring a concentrated set of changes across EU, UK, US, and APAC β from mandatory RED cybersecurity to RoHS exemption expiries and new USB-C mandates.
All radio equipment newly placed on the EU market must comply with cybersecurity requirements under RED 2014/53/EU, demonstrated via EN 18031-1/2/3. Affected products include IoT devices, wearables, connected toys, and smart home equipment.
The UK has indefinitely extended CE mark recognition with no announced end date. UK PSTI Act product cybersecurity requirements β no default passwords, vulnerability disclosure, update transparency β have been active since April 2024.
Unintentional RF radiators require a Supplier's Declaration of Conformity via accredited lab. Intentional radiators (Wi-Fi, Bluetooth, cellular) require full FCC certification through a TCB, with an FCC ID affixed to the product. CE marking satisfies neither.
Korea requires mandatory KC marking for safety and EMC. From 5 November 2026, new consumer devices must use USB Type-C ports under MSIT Notice 2025-56. China CCC mandatory for IT/AV equipment; India BIS for smartphones, tablets, and power banks.
The enforcement dates driving documentation updates, reformulation decisions, and market access across the electronics industry.
RoHS-related product recalls recorded in the EU market in Q1 2025 alone
Average voluntary suspension timeline from market surveillance notification to relisting
Cyber Resilience Act fully applicable β replacing RED cybersecurity across all products with digital elements
A structured overview of the core compliance frameworks in each major market β useful for manufacturers planning first international expansion or reviewing multi-market compliance programmes.
| Requirement | EU | UK (Great Britain) | United States |
|---|---|---|---|
| Conformity mark | CE marking β mandatory for EEE under applicable directives | UKCA or CE marking (CE indefinitely accepted as at 2024) | No single conformity mark; FCC ID mandatory for certified devices |
| Hazardous substance restriction | RoHS 2011/65/EU β 10 restricted substances; Annex III exemptions; CE marked | UK RoHS (SI 2012/3032 as amended) β parallel framework enforced by OPSS | No federal RoHS equivalent; state-level restrictions apply (California, others) |
| EMC compliance | EMC Directive 2014/30/EU β tested against EN 55032 / EN 55035 harmonised standards | UK EMC Regulations β technically identical standards in most cases | FCC Part 15 β Class A (industrial) or Class B (consumer); SDoC procedure |
| Radio / wireless certification | RED 2014/53/EU β covers safety, EMC, spectrum; cybersecurity from Aug 2025 | UK Radio Equipment Regulations 2017 β broadly mirrors RED | FCC certification (TCB); intentional radiators require FCC ID |
| Cybersecurity | RED Articles 3.3(d)(e)(f) from Aug 2025; CRA from Dec 2027 | PSTI Act 2022 product security requirements β in force April 2024 | FCC Cyber Trust Mark (voluntary, consumer IoT); NIST framework |
| E-waste / WEEE | WEEE Directive 2012/19/EU β producer registration, collection targets per member state | UK WEEE Regulations β separate producer registration with approved compliance scheme | No federal e-waste law; state programmes (California EWRA, 25+ state schemes) |
| Authorised Representative | Non-EU manufacturers must appoint an EU Authorised Representative for CE marking | Non-UK manufacturers must appoint a UK Responsible Person for UKCA | No equivalent requirement; responsible party must be identifiable via FCC records |
| Technical documentation | Technical Construction File (TCF) + Declaration of Conformity; retained 10 years | UK equivalent Technical Documentation + UK Declaration of Conformity | FCC lab reports + compliance information statement; no DoC equivalent |
Electronics compliance work spans pre-launch directive mapping, technical documentation, conformity assessment, EU/UK Authorised Representative services, and ongoing exemption monitoring. We cover the full scope.
We identify every EU directive, UK regulation, and international framework that applies to your specific product β by category, functionality, and target market β and produce a structured conformity assessment roadmap sequencing testing, documentation, and registration requirements in order of critical path dependency.
We prepare and review Technical Construction Files (TCFs) and Declarations of Conformity for CE marking and UKCA, ensuring all applicable directives are covered, harmonised standards are correctly referenced, and documentation is structured to withstand market surveillance scrutiny β including gaps when new requirements such as RED cybersecurity are added post-certification.
For manufacturers with radio equipment placed on the EU market after 1 August 2025, we assess compliance against Articles 3.3(d)(e)(f) of RED and EN 18031-1/2/3:2024. We identify which conformity modules require Notified Body involvement, structure the gap remediation, and update the Declaration of Conformity and Technical File accordingly.
We screen product Bills of Materials against the ten restricted substances under EU and UK RoHS, identify reliance on Annex III exemptions, and track expiry dates across your product portfolio. For manufacturers affected by the non-renewal of Exemptions 6(a) and 6(b), we advise on reformulation timelines and manage renewal applications where applicable.
Non-EU manufacturers placing CE-marked products on the EU market must appoint an EU Authorised Representative. We provide EU AR services β holding and maintaining the TCF, acting as regulatory contact for market surveillance authorities, and signing the Declaration of Conformity on behalf of the manufacturer where required. UK Responsible Person services are available separately.
We advise on FCC Part 15 authorisation pathways β identifying whether SDoC or full FCC certification is required, coordinating with accredited testing laboratories, preparing the compliance information statement, and advising on FCC ID labelling. We also address CPSC obligations for children's electronics and California-specific requirements.
We support market entry into China (CCC and China RoHS), South Korea (KC marking), India (BIS registration), Japan (VCCI), and Australia/New Zealand (RCM), coordinating local testing partners and managing documentation and registration workflows for each market simultaneously where multi-market timelines require it.
These are the situations we encounter most frequently when manufacturers and importers come to TGC - often after a compliance gap has already caused a commercial or regulatory incident.
CE Marking Gap
Market Entry Risk
Substance Compliance
Legal Requirement
Cybersecurity Compliance
Producer Responsibility
Answers to the questions we hear most often from electronics manufacturers, importers, and product teams navigating multi-market compliance.
Electronics sold in the EU typically require CE marking under several directives simultaneously. The core directives for most electronic products are: RoHS Directive (2011/65/EU) - restricts 10 hazardous substances; EMC Directive (2014/30/EU) - electromagnetic compatibility; and Low Voltage Directive (2014/35/EU) for products operating at relevant voltage ranges. Products with radio functionality additionally require compliance with the Radio Equipment Directive (RED, 2014/53/EU).
CE marking requires a completed Declaration of Conformity (DoC) and a Technical Construction File (TCF) maintained by the manufacturer or EU Authorised Representative, both retained for 10 years. There are more than 30 CE marking directives and regulations in total - the specific set that applies depends on the product's functionality, intended use, and physical characteristics. A directive mapping exercise is the correct starting point for any new product or market entry.
From 1 August 2025, all radio equipment placed on the EU market must comply with cybersecurity requirements under Articles 3.3(d), (e), and (f) of RED 2014/53/EU, activated by Delegated Regulation (EU) 2022/30. Article 3.3(d) requires that devices do not harm the network or misuse network resources. Article 3.3(e) requires protection of personal data and user privacy. Article 3.3(f) requires protection against fraud, particularly for payment-capable devices.
Affected products include IoT devices, wearables, connected toys, smart home equipment, baby monitors, and any device capable of connecting to the internet. Compliance is demonstrated through harmonised standards EN 18031-1, EN 18031-2, and EN 18031-3, published in January 2025. Some products require Notified Body involvement in the conformity assessment; others can use self-declaration via Module A. The RED cybersecurity requirements will be superseded by the Cyber Resilience Act (CRA) when it becomes fully applicable on 11 December 2027.
As of 2024, the UK government has indefinitely extended recognition of the CE mark for Great Britain. CE marking is legally equivalent to the UKCA mark for products subject to relevant UK regulations, with no announced end date for this equivalence. Manufacturers can currently place CE-marked products on the GB market without separately obtaining UKCA marking.
However, the underlying UK technical requirements must still be met - in most cases these are identical to EU harmonised standards. Manufacturers planning long-term GB market access should maintain UKCA-compatible technical documentation in case the UK changes its position. Northern Ireland continues to require CE marking under the Windsor Framework, not UKCA. For products sold in both the EU and UK, CE marking currently satisfies both markets.
FCC 47 CFR Part 15 regulates all electronic devices that can emit radiofrequency (RF) energy in the 9 kHz to 3,000 GHz range. Unintentional radiators - devices that generate but do not intentionally transmit RF, such as computers or power supplies - require a Supplier's Declaration of Conformity (SDoC), which involves testing by an accredited laboratory but no pre-approval from the FCC.
Intentional radiators - devices designed to transmit RF, such as Wi-Fi, Bluetooth, or cellular devices - require FCC certification through an FCC-recognised Telecommunications Certification Body (TCB). After certification, the device is assigned an FCC ID that must be permanently affixed to the product. FCC Class B, the more stringent classification, applies to consumer products. The FCC and CE frameworks are entirely separate and must be satisfied independently - there is no mutual recognition between them.
Several key RoHS Annex III exemptions were subject to renewal decisions adopted by the European Commission in September 2025, entering into force on 11 December 2025. Exemption 6(a) β lead as an alloying element in steel for machining purposes and in galvanised steel β was not renewed and expires 12 months after entry into force: by 11 December 2026 for categories 1-7 and 10. Exemption 6(b) β lead as an alloying element in aluminium β was not renewed in its general form: sub-exemption 6(b)-I (recycled scrap aluminium, categories 1-7 and 10) expires 11 December 2026, and 6(b)-II (machining aluminium, categories 1-7 and 10) expires 11 June 2027.
These non-renewals directly affect manufacturers using aluminium alloys in mainstream EEE categories. Applications for renewal of exemptions expiring 31 December 2027 must be submitted by 30 June 2026, as per Article 5(5) of the RoHS Directive (applications cannot be made later than 18 months before expiry). Manufacturers should audit their current reliance on these and other Annex III exemptions now.
Several Asia-Pacific markets require mandatory pre-market certification for electronics. China requires CCC (China Compulsory Certification) for IT equipment, audio/video equipment, and specified electrical products - products cannot be imported, sold, or used in China without CCC. South Korea requires mandatory KC marking for safety and EMC compliance. India requires mandatory BIS (Bureau of Indian Standards) registration for smartphones, laptops, tablets, power banks, and specified peripherals under the Electronics and Information Technology Goods Order.
Japan's VCCI mark is technically voluntary but commercially essential for IT equipment - products without VCCI face significant market access barriers from distributors and retailers. Australia and New Zealand use the mandatory RCM (Regulatory Compliance Mark) for prescribed electrical equipment. South Korea has additionally mandated USB Type-C ports on new consumer devices from 5 November 2026, modelled on EU Directive 2022/2380.
TCF Β· RED cybersecurity Β· RoHS exemptions Β· multi-directive conformity
Gap assessments and remediation roadmaps at commercial pace
EU Β· UK Β· US Β· APAC testing labs and Notified Body networks
Talk to a TGC specialist about your product, your target markets, and your deadlines. We will tell you exactly where the risks are and what it takes to resolve them - before they become a problem at the border or the shelf.
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