GPSR for Consumer Electronics: LVD, EMC, RED Cybersecurity, RoHS, WEEE, the Batteries Regulation and the USB-C Common Charger

Which EU laws apply to consumer electronics

A Bluetooth headset, a power bank or a smart camera can be subject to five or six EU laws at once. Mapping them first saves a lot of retesting and relabelling.

How do the GPSR and these directives combine? Under GPSR Article 2(1), for products subject to Union harmonisation legislation, Chapter II (safety requirements) does not apply to the risks that legislation covers, and Chapter III Section 1 (Articles 9–18 on manufacturers, importers, distributors and related duties) does not apply. Article 19 (distance sales), Article 20 (accidents), Article 22 (online marketplaces) and Articles 35–37 (recalls and remedies) still apply. The EU responsible operator requirement comes from Article 4 of Regulation (EU) 2019/1020, whose paragraph 5 lists the LVD, EMC, RED and RoHS directives. Every consumer electronics product therefore needs an EU manufacturer, importer, authorised representative or fulfilment service provider to carry out the Article 4 tasks.

The boundary in one line: whatever the sector law (LVD, EMC, RED, Batteries Regulation and so on) covers is governed by that law, and the GPSR only fills the gaps (Article 2(1)). CE marking and the label and listing information required by the GPSR exist side by side, and neither replaces the other. For more on this, see GPSR vs CE marking.

The CE core: LVD, EMC and RED, and what manufacturers must do

Start with the radio question. A product that intentionally emits or receives radio waves, such as Wi-Fi, Bluetooth, NFC or cellular, is radio equipment and falls under the RED. RED Article 3(1) already includes the LVD safety objectives (with no voltage limit) and the EMC requirements, so a radio product is normally declared against the RED alone. Its technical file covers safety, EMC, radio and human exposure to electromagnetic fields.

Non-radio products are assessed under the LVD and the EMC Directive. Note that LVD Article 1 covers only equipment rated between 50 and 1000 V AC or 75 and 1500 V DC. A USB-powered desk fan or a battery-powered LED gadget is outside the LVD, although its mains adapter is inside. The electrical, heat and battery risks of such low-voltage products must be addressed under the GPSR general safety requirement (Article 5), while the EMC and RoHS directives still apply.

The three directives give manufacturers the same basic duties (RED Article 10 as an example):

• design and build to the essential requirements, prepare the technical documentation and carry out the conformity assessment, then draw up the EU declaration of conformity (DoC) and affix the CE marking;
• keep the technical documentation and DoC for 10 years;
• mark the product with a type, batch or serial number, or put it on the packaging or an accompanying document if the product is too small;
• show the manufacturer's name, registered trade name or trade mark and postal address (a single contact point) on the product;
• supply instructions and safety information in a language consumers in the country of sale easily understand; radio products must also state the frequency bands and the maximum radio-frequency power in each band.

Where several laws apply, a single DoC covering all of them can be issued. Commonly used test standards include EN IEC 62368-1 (audio/video and ICT equipment safety), EN 55032 and EN 55035 (EMC), and ETSI EN 300 328 and the EN 301 489 series (2.4 GHz radio and its EMC). Which standards and editions give a presumption of conformity depends on the lists published in the Official Journal, so confirm the test plan with your test lab.

RED cybersecurity: Delegated Regulation (EU) 2022/30 applies from 1 August 2025

Commission Delegated Regulation (EU) 2022/30 activates three essential requirements in RED Article 3(3). It was originally due to apply from 1 August 2024, but Delegated Regulation (EU) 2023/2444 moved the date to 1 August 2025. Radio equipment in scope that is placed on the market since then must meet:

Medical and in-vitro diagnostic devices and some other regulated equipment are exempt (Article 2). In January 2025, Commission Implementing Decision (EU) 2025/138 published the references of the harmonised standards EN 18031-1, -2 and -3 in the Official Journal, with several restrictions, for example on clauses that allow users not to set a password. Where a restriction applies, the standard gives no presumption of conformity for that part, and a notified body may need to be involved. Agree the route with your lab early.

Looking ahead, the Cyber Resilience Act (Regulation (EU) 2024/2847) will set horizontal cybersecurity rules for products with digital elements. It applies from 11 December 2027, while its Article 14 reporting obligations for vulnerabilities and incidents apply from 11 September 2026. Watch for Commission information on how it will interact with the RED cybersecurity requirements.

RoHS and WEEE: restricted substances and country-by-country registration

RoHS (2011/65/EU) restricts lead, mercury, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE) to 0.1% and cadmium to 0.01% by weight in homogeneous materials. Delegated Directive (EU) 2015/863 added four phthalates (DEHP, BBP, DBP and DIBP) at 0.1% each. Annexes III and IV list exemptions. RoHS also requires technical documentation, a DoC and the CE marking, and supplier material declarations or test data are a key part of the file.

WEEE (2012/19/EU) sets the take-back and extended producer responsibility (EPR) rules:

• Bin symbol: under Article 14(4), producers must mark electrical and electronic equipment with the crossed-out wheeled bin symbol in Annex IX, preferably following EN 50419. It must be visible, legible and indelible.
• Who is the producer: Article 3(1)(f)(iv) covers anyone established in another Member State or in a third country who sells equipment by distance communication directly to households or other users in a Member State. A non-EU seller shipping directly to EU consumers may therefore be the producer under national law.
• Registration per country: producers must register in the national register of each country of sale and finance collection, and national rules differ. Article 17 requires producers established in one Member State to appoint an authorised representative when selling at a distance into another. For non-EU sellers, whether a local authorised representative is required depends on national law (Germany, for example, requires producers not established in Germany to appoint one), so check each country.
• Marketplace checks: Amazon's public EPR page says sellers of electrical and electronic equipment in Germany must provide a valid registration number, and that in France Amazon pays eco-contributions on the seller's behalf by default if no valid number is provided. Check the EPR section of Seller Central for current requirements.

The Batteries Regulation (EU) 2023/1542: which duties apply when

The Batteries Regulation has applied since 18 February 2024 and replaces the Batteries Directive 2006/66/EC. It covers all batteries, including batteries built into electronic products and stand-alone power banks and button cells. The dates below come from Article 96 and the articles cited:

On the Article 13(1)–(3) labels: the Commission must adopt an implementing act with harmonised label specifications, and the labels apply from 18 August 2026 or 18 months after that act enters into force, whichever is later. According to the public information we could find when checking, the implementing act was still at draft and consultation stage, so the real date is likely to be later than 18 August 2026. Rely on the final act as published on EUR-Lex.

Removability (Article 11): from 18 February 2027, products with portable batteries must let end users remove and replace the battery at any time with commercially available tools, unless a special tool is supplied free with the product. Instructions and safety information on removal and replacement must accompany the product and stay available online. Batteries must be available as spare parts for at least five years after the last unit of the model is placed on the market, and software must not be used to block a compatible replacement. There are limited exceptions, for example for washable appliances regularly exposed to water. Have a specialist assess at the design stage whether an exception or other ecodesign rules apply to phones, tablets or earbuds. Batteries with more than 0.002% cadmium or 0.004% lead must also show Cd or Pb below the collection symbol.

The USB-C common charger: different dates for phones and laptops

Directive (EU) 2022/2380 amended the RED and added Annex Ia. Member States apply it from 28 December 2024 to handheld mobile phones, tablets, digital cameras, headphones, headsets, handheld videogame consoles, portable speakers, e-readers, keyboards, mice, portable navigation systems and earbuds, and from 28 April 2026 to laptops.

• Receptacle: if the device can be charged by wire, it must have a USB Type-C receptacle (EN IEC 62680-1-3:2021) that stays accessible and operational, and it must charge with cables meeting that standard.
• Fast charging: if wired charging goes above 5 V, 3 A or 15 W, the device must support USB Power Delivery (EN IEC 62680-1-2:2021), and any other protocol must allow USB PD to work fully.
• Sale without a charger: Article 3a requires that consumers can buy the device without a charging device.
• Pictogram and label: the pictogram in Annex Ia Part III shows whether a charger is included (dimension a at least 7 mm), and the label in Part IV states the minimum and maximum charging power in watts and whether USB PD is supported. The information must also be in the instructions and may additionally be given through a QR code.

The pictogram and label usually go on the packaging. It also helps to state in the listing whether a charger is included and the power range, which avoids confusion and marketplace queries.

What the GPSR adds for electronics

Even when a product meets all the directives above, the GPSR still matters to electronics sellers in several ways:

• Connectivity and cybersecurity as safety aspects: GPSR Article 6(1) requires the safety assessment to consider the effect of interconnection with other products (point (b)), the effect of non-embedded items such as software on how the product works (point (c)), appropriate cybersecurity features against external influences, including malicious third parties, where they might affect safety, including a possible loss of interconnection (point (g)), and evolving, learning and predictive functions (point (h)). If an app-controlled heater could overheat when taken over remotely, that is a safety problem, not just a privacy issue.
• Software updates can change safety: the GPSR recitals say that software updates may substantially modify a product and should then trigger a new risk assessment, and Article 37 lists software updates among the remedies a consumer may apply in a recall. Assess firmware updates for new hazards before release.
• Risks the directives miss: for low-voltage, non-radio products, electrical safety falls under the GPSR general safety requirement. The standards supporting the GPSR in Implementing Decision (EU) 2026/901 include the sound exposure clauses of EN IEC 62368-1 (relevant to headphones and personal music players) and EN 50689 for consumer laser products such as laser pointers.
• Listing information (Article 19): the names, postal and electronic addresses of the manufacturer and the EU responsible person, product images and model, and the warnings and safety information (battery, charging and heat warnings, for example) must be clearly shown in the online offer. See GPSR information for online sales.
• Accident notification (Article 20): accidents such as battery fires or overheating that cause death or serious harm to health must be notified by the manufacturer without undue delay through the Safety Business Gateway. If the manufacturer is outside the EU, the responsible person who knows of the accident must ensure it is notified. See accidents, recalls and Safety Gate.

Labels, documents and Amazon EU

A QR code does not replace the physical label: GPSR Article 21 lets economic operators provide required information additionally in digital form, such as a QR code, but only as a supplement; mandatory information must still be printed on the product, packaging or accompanying document. The battery QR code in Article 13(6) of the Batteries Regulation is a separate legal requirement and does not replace the battery labels and symbols either.

Documents to have ready: the EU DoC; the technical documentation (description, circuit and construction data, risk assessment, list of standards, test reports, kept for 10 years); RoHS material declarations or test data; battery DoC and test data; and WEEE and battery EPR registration numbers for each country. Lithium batteries must also meet transport rules such as UN 38.3, but those are logistics requirements and do not replace product compliance documents. Document contents are covered in GPSR technical documentation, and you can draft a label layout at gpsrtools.com before checking it against the rules.

Amazon EU (based only on Amazon's public information; Seller Central wording can change): EU listings need manufacturer details, EU responsible person details and safety information, and products missing them may stop being shown. Recovery steps are in Amazon GPSR listing deactivated. Germany and France also require EPR registration numbers for electrical and electronic equipment. Use lawful routes only: never forge documents or use fake EU addresses. The role of the EU responsible person and the mandate are explained in EU responsible person.