CE marking for US companies: from FCC and UL to the EU Declaration of Conformity

What carries over from FCC and UL, and what does not

• FCC authorization (equipment authorization or Supplier's Declaration of Conformity) is a US legal requirement only. In the EU, radio products fall under the Radio Equipment Directive 2014/53/EU and other electronics under the EMC Directive 2014/30/EU. Your FCC test data can help, but the evidence must be against the EU harmonised standards, for example ETSI EN 300 328 for 2.4 GHz radios and EN 55032 for emissions.
• Immunity is the usual gap. FCC rules for consumer products limit emissions only; the EU also requires immunity testing, typically EN 55035 for multimedia and IT equipment or EN 301 489 for radio equipment.
• UL 62368-1 and EN 62368-1 are both based on IEC 62368-1, so the safety work largely transfers. A CB test report under the IECEE CB Scheme that includes the European group differences is the usual way to reuse it. A UL listing mark itself has no legal meaning in the EU.
• Voltage and plugs change the assessment. Products for 230 V / 50 Hz mains fall under the Low Voltage Directive 2014/35/EU and must be tested at EU supply conditions, with the plug types of the countries you sell in.
• Several EU requirements have no US counterpart at all: RoHS (2011/65/EU), the Batteries Regulation (EU) 2023/1542, ecodesign and energy labelling, the USB-C common charger rule for phones, earbuds and similar devices, and the cybersecurity requirements for internet-connected radio equipment.

The steps to sell your product in the EU

1. Identify the EU legislation that applies to the product. The product guides on this site show the typical set for common product types.
2. Map your existing FCC, UL and CB test reports to the EU harmonised standards and close the gaps, usually EMC immunity, EU-specific radio tests, and RoHS documentation.
3. Check whether a notified body is needed. Most consumer electronics can use internal production control; some products, such as certain machinery or radio equipment not fully covered by harmonised standards, need a notified body.
4. Compile the technical documentation and keep it for 10 years after the last unit is placed on the market.
5. Draw up and sign one EU Declaration of Conformity covering all applicable legislation, and affix the CE marking.
6. Appoint an economic operator established in the EU and put its name and postal address on the product, packaging or accompanying document.
7. Translate instructions and safety information into the language of every EU country you sell in, and complete the producer registrations for WEEE, batteries and packaging in each of those countries.

The EU economic operator: the step US companies miss

Under Article 4 of Regulation (EU) 2019/1020, a product covered by the main CE directives (including the LVD, EMC, RED, RoHS, Machinery and Toy Safety legislation) may only be placed on the EU market if an economic operator established in the EU is responsible for it: an EU-based importer, an authorised representative with a written mandate, or a fulfilment service provider. A US address on the label is not enough, and customs can suspend the release of products that do not name one.

If you sell through a European distributor, the distributor usually becomes the importer. If you ship directly to EU customers or through Amazon FBA in Europe, you normally need an authorised representative. Several countries, Germany among them, also require a producer without a local establishment to appoint a local authorised representative for WEEE registration.

Common mistakes in declarations from US companies

• An FCC Grant, an FCC SDoC or a UL certificate is sent where an EU Declaration of Conformity is required.
• The declaration cites FCC Part 15 or UL standards instead of EU legislation and EN standards.
• EMC is covered by emission tests only, with no immunity testing.
• The Low Voltage Directive and EMC Directive are listed next to the Radio Equipment Directive, which already covers both for radio products.
• Only a US address is given, with no economic operator established in the EU.
• The declaration is in English only, although several EU countries require their own language.

What about the UK?

The United Kingdom is not part of the EU. Northern Ireland follows EU product rules, while Great Britain has its own UKCA regime but continues to recognise CE marking for most product types. A UK address does not count as an EU economic operator.

Frequently asked questions