Household appliances
EU Declaration of Conformity for Robot Vacuum Cleaners: requirements and checklist
By Ing. Jaroslav Křepelka, Owner, DoC solutions s.r.o. · Updated 18 October 2026
In short: A Wi-Fi robot vacuum is declared under the Radio Equipment Directive 2014/53/EU, including the cybersecurity requirements of Delegated Regulation (EU) 2022/30 that apply since 1 August 2025, and the RoHS Directive 2011/65/EU, with EN 60335-1 and EN 60335-2-2 for safety. Robot cleaners are excluded from the vacuum cleaner ecodesign Regulation (EU) No 666/2013, and from 20 January 2027 the Machinery Regulation no longer applies to household appliances within the scope of RED.
Robot vacuums combine a battery-powered appliance, a mains charging dock, Wi-Fi and an app, and often cameras or lidar that map the home. That makes them radio equipment with cybersecurity and data-protection obligations, and it raises a question few suppliers answer correctly: does the Machinery Directive apply?
This page covers robot vacuums and robot mops for household use, with their charging and self-emptying docks.
Checklist: what your robot vacuum cleaner declaration must contain
- Model of the robot and of the dock, exactly as on their labels
- Name and postal address of the manufacturer (and of the authorised representative, if appointed)
- The statement that the declaration is issued under the sole responsibility of the manufacturer
- Radio Equipment Directive 2014/53/EU, including Delegated Regulation (EU) 2022/30
- RoHS Directive 2011/65/EU
- Where you conclude it applies before 20 January 2027, the Machinery Directive 2006/42/EC
- The harmonised standards applied, with year and amendments
- Place and date of issue, name and function of the signatory, and the signature
Which EU legislation applies
| Legislation | Applies? | In the DoC? | Notes |
|---|---|---|---|
| Radio Equipment Directive2014/53/EU | Applies | In the DoC: Yes | Covers electrical safety (Article 3(1)(a), with no voltage limit), EMC and the radio for the robot and the dock. Do not cite the LVD and EMC Directives separately. |
| Cybersecurity and data protection delegated actDelegated Regulation (EU) 2022/30 | Applies | In the DoC: Yes | Applicable since 1 August 2025. App-connected robots communicate over the internet, so network protection (Article 3(3)(d)) applies, and maps, camera images and usage data are personal data, so data protection (Article 3(3)(e)) applies as well. |
| Machinery Directive2006/42/EC | Depends on model | In the DoC: Yes | Until 19 January 2027. Article 1(2)(k) excludes household appliances only insofar as they are covered by the Low Voltage Directive, and the robot itself runs on a battery below the LVD voltage range. Manufacturers therefore assess whether the directive applies, and some cite it. Its harmonised standard EN 60335-1 is also listed under the Machinery Directive. |
| Machinery Regulation(EU) 2023/1230 | Usually not | In the DoC: No | From 20 January 2027 Article 2(2)(p) excludes household appliances that fall within the scope of the Low Voltage Directive or the Radio Equipment Directive, which covers a Wi-Fi robot vacuum. Check the scope again for robots without any radio. |
| RoHS Directive2011/65/EU | Applies | In the DoC: Yes | Restriction of hazardous substances in electrical and electronic equipment. |
| Batteries Regulation(EU) 2023/1542 | Applies | In the DoC: No | Obligations for the battery pack: marking, producer registration and, from 18 February 2027, the end-user removability and replaceability requirement of Article 11. |
| Vacuum cleaner ecodesignRegulation (EU) No 666/2013 | Usually not | In the DoC: No | Article 1(2)(a) excludes battery-operated and robot vacuum cleaners. |
| WEEE Directive2012/19/EU | Applies | In the DoC: No | Producer registration in every EU country where you sell and the crossed-out wheeled bin symbol. |
Typical harmonised standards
A harmonised standard gives presumption of conformity only in the version cited in the Official Journal of the EU. Always check the current list for each directive before you issue or update a declaration (European Commission: harmonised standards); the versions below are the ones commonly used at the time of writing, and the right selection depends on your product.
Safety
- EN 60335-1:2012 + A11:2014 + A13:2017 + A1:2019 + A14:2019 + A2:2019 + A15:2021Household and similar electrical appliances — safety — general requirements
- EN 60335-2-2:2010 + A11:2012 + A1:2013Particular requirements for vacuum cleaners and water-suction cleaning appliances
- EN 60335-2-29:2021 + A1:2021Particular requirements for battery chargers (the charging dock)
- EN 62233:2008Electromagnetic fields of household appliances with regard to human exposure
- EN 62133-2:2017 + A1:2021Safety of portable sealed secondary lithium cells and batteries
Radio and EMC
Versions shown are cited under RED in Implementing Decision (EU) 2022/2191 as amended; for EN 301 489-1 use the version listed in the Official Journal. EN 55014 is used as evidence for the EMC requirement of RED.
- ETSI EN 300 328 V2.2.2Wideband transmission systems in the 2.4 GHz band (Wi-Fi, Bluetooth)
- ETSI EN 301 8935 GHz RLAN, for dual-band Wi-Fi models
- ETSI EN 301 489-1 and EN 301 489-17 V3.3.1EMC standard for radio equipment — wideband data transmission systems
- EN 55014-1:2017 + A11:2020 and EN 55014-2:1997 + A1:2001 + A2:2008EMC requirements for household appliances — emission and immunity
- EN 62311 or EN 62479Human exposure to electromagnetic fields from the radio
Cybersecurity
- EN 18031-1:2024Internet-connected radio equipment (cited with restrictions)
- EN 18031-2:2024Radio equipment processing data (cited with restrictions)
Hazardous substances (RoHS)
- EN IEC 63000:2018Technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances
Already have a declaration for your robot vacuum cleaner?
A certification expert checks it against everything on this page and tells you exactly what to fix. Written report in 48 hours, €99 per product (excl. VAT).
Common mistakes in robot vacuum cleaner declarations
Cybersecurity and data protection not addressed
Since 1 August 2025 app-connected robots must meet RED Article 3(3)(d) and (e). Home maps and camera images are personal data, so both requirements apply, typically shown with EN 18031-1 and EN 18031-2.
LVD and EMC listed next to RED
For radio equipment RED covers safety and EMC; listing the other directives is a template error.
The vacuum cleaner ecodesign regulation is cited
Regulation (EU) No 666/2013 expressly excludes robot and battery-operated vacuum cleaners. Citing it shows the declaration was copied from a mains vacuum cleaner.
The dock is not covered
The charging or self-emptying dock is mains equipment and part of the product. Its model must be identified and covered by the safety and EMC evidence.
No plan for battery removability
From 18 February 2027 portable batteries in appliances must be removable and replaceable by the end user, unless an exemption in Article 11 applies. Designs being finalised now should take this into account.
What you need besides the declaration
- Technical documentation
- Safety, radio, EMC and EMF test reports for robot and dock, a cybersecurity and data protection assessment with EN 18031 evidence, battery data and RoHS documentation. Keep it for 10 years.
- Privacy and security information
- Information on what data the robot and app collect, how to delete it and how security updates are delivered.
- Marking and instructions
- CE marking, crossed-out wheeled bin, model, manufacturer details and safety instructions in the language of each EU country where the robot is sold.
- Economic operator in the EU
- An importer, authorised representative or responsible person established in the EU (Article 4 of Regulation (EU) 2019/1020).
No EU presence yet? We can act as your EU authorised representative or responsible person.
Frequently asked questions
Which directive applies to a robot vacuum?
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The Radio Equipment Directive for Wi-Fi and app-connected models, including the cybersecurity delegated act, together with the RoHS Directive. Before 20 January 2027 manufacturers also assess the Machinery Directive.
Do robot vacuums have to meet the vacuum cleaner ecodesign rules?
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No. Regulation (EU) No 666/2013 excludes robot and battery-operated vacuum cleaners.
Does the new Machinery Regulation apply to robot vacuums?
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Not to robots within the scope of the Radio Equipment Directive or the Low Voltage Directive: from 20 January 2027 Article 2(2)(p) of Regulation (EU) 2023/1230 excludes such household appliances.
What does MyCECheck check on a robot vacuum declaration?
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RED and the cybersecurity delegated act, the safety, radio, EMC and EN 18031 standards and their versions, the identification of robot and dock, and the economic operator. Written report within 48 hours.
Already have a declaration for your robot vacuum cleaner?
A certification expert checks it against everything on this page and tells you exactly what to fix. Written report in 48 hours, €99 per product (excl. VAT).