Compliance by market: the approvals your product needs
Before you can design for compliance, you need to know which rules apply. That depends on what the product does and where it will be sold. This article is a map of the main approvals for electronic products in the largest markets.
It is not legal advice, and requirements change, so confirm the current rules for your product before you commit to a plan.
At a glance
| Market | EMC | Radio | Safety | Materials | Cybersecurity |
|---|---|---|---|---|---|
| United States | FCC Part 15, usually by supplier’s declaration | FCC certification, FCC ID on the label | NRTL listing (such as UL) for many products | No federal RoHS; some state rules, including California Prop 65 warnings | No federal rule; California, and Oregon for consumer devices, require reasonable security, met by a unique or user-set password |
| Canada | ICES-003 | ISED certification | Certification mark (such as CSA or cUL) for mains products | No federal RoHS | No general rule |
| European Union | EMC Directive (CE) | Radio Equipment Directive (CE) | Low Voltage Directive (CE), or general product safety | RoHS (CE), REACH, WEEE, and battery rules | Radio Equipment Directive now; Cyber Resilience Act reporting since September 2026, in full from December 2027 |
| Great Britain | UK EMC rules; CE accepted | UK radio rules; CE accepted | UK electrical safety rules; CE accepted | UK RoHS, UK REACH, and UK WEEE | PSTI rules for connected consumer products (whole UK) |
Market by market
United States: FCC
Almost every electronic product falls under FCC Part 15. Products that only emit radio energy as a side effect, such as anything with a processor, are “unintentional radiators.” Most are authorized through a Supplier’s Declaration of Conformity: you test the product, keep the records, and include a compliance statement naming a responsible party in the United States.
Products with a radio transmitter are “intentional radiators” and need certification, granted by a Telecommunication Certification Body after testing at an FCC-recognized lab, with an FCC ID on the label. The applicant must also name an agent in the United States to accept service of process (legal papers) on its behalf; a company based in the US can be its own agent. Confirm early that your lab and certification body are still FCC-recognized; the FCC has withdrawn recognition from some overseas labs and is considering wider limits.
The US has no federal security rule for connected products; the FCC’s Cyber Trust Mark is voluntary. California requires connected devices to have reasonable security features, and Oregon requires the same of devices used mainly for personal, family, or household purposes. For a device that can be logged into from outside the local network, a unique password per device, or one the user must set before first use, meets that requirement.
Canada: ISED
Similar in structure to the FCC. Digital devices follow ICES-003, and radios need ISED certification. If your company is not based in Canada, ISED certification also needs a representative in Canada, who answers ISED’s questions about the product. Compliance labels and notices must be in both English and French.
European Union: CE marking
Radio products follow the Radio Equipment Directive, which covers radio performance, EMC, and safety. Since August 2025 it has also covered cybersecurity for internet-connected radios, and for radio toys, childcare products, and wearables that handle personal data. Many rechargeable radio products, such as phones, headphones, keyboards, and portable speakers, must also charge through USB-C under the RED’s common charger rules.
Non-radio products generally follow the EMC Directive, plus the Low Voltage Directive if they are rated for 50 to 1000 V AC or 75 to 1500 V DC. Consumer products below those voltages still fall under the General Product Safety Regulation.
The manufacturer keeps a technical file and signs a Declaration of Conformity, and a product sold into the EU needs a responsible business based there, such as an importer or authorized representative.
European Union: cybersecurity is changing
The Cyber Resilience Act covers most products with software and a data connection. Its duty to report actively exploited vulnerabilities and severe security incidents began in September 2026, and its full requirements, which replace the Radio Equipment Directive’s cybersecurity rules, apply from December 2027. Every unit placed on the EU market from then must comply, so if you will still be shipping the product, design for it now. Designing connected products for EU and UK cybersecurity rules covers what that means for hardware and firmware.
United Kingdom: UKCA
The UK has its own mark and regulations, closely modeled on the EU’s. Great Britain now accepts CE marking indefinitely for most electronics, including EMC, low voltage, and radio equipment, so many products need no separate UKCA work. If you are not based in Great Britain, the UK importer’s name and address still go on the product, packaging, or accompanying documents. Northern Ireland follows EU rules.
Connected consumer products must also meet the UK’s own security rules (the PSTI regime): no universal default passwords, a published way to report vulnerabilities, a stated period of security updates, and a statement of compliance shipped with the product.
Hazardous substances: RoHS and REACH
RoHS restricts lead and other substances in electronics sold in the EU, the UK, and a growing list of other markets. In the EU, RoHS is also one of the CE marking directives, so it belongs in your Declaration of Conformity.
REACH is the EU’s broader chemicals regulation. For most electronics makers it means checking that nothing in the product breaks a REACH restriction, knowing whether any part contains a listed substance of very high concern above 0.1% by weight, and telling customers if it does. Whoever places such a product on the EU market must also notify it to ECHA’s SCIP database.
In practice, both come down to choosing compliant parts and collecting declarations from suppliers. Separately, the EU’s WEEE rules require the crossed-out wheeled bin mark and registration as a producer in each EU country where you sell; the UK has its own WEEE rules.
Products with batteries also fall under the EU Batteries Regulation, (EU) 2023/1542. It covers battery labeling, and registration and take-back duties for producers. From 18 February 2027, it also requires portable batteries in a product to be removable and replaceable by the end user, which shapes the enclosure. Exemptions and their conditions are still changing, so check the current position before you design.
In the US, California’s Proposition 65 requires a warning on consumer products sold in California that can expose people to a listed chemical, such as lead in solder, brass, or PVC cable, unless you can show the exposure is too low to need one. Businesses with fewer than 10 employees are exempt, but customers may still require the warning by contract.
Product safety
The safety standard depends on the product type: IEC 62368-1 for audio, video, IT, and communication equipment, IEC 61010-1 for test, measurement, and control equipment, and IEC 60335 for household appliances. Medical devices have their own.
In the United States, a listing from a Nationally Recognized Testing Laboratory such as UL is required for many workplace and installed products, and retailers and customers often ask for it even where the law does not. In Canada, mains-powered electrical products generally must carry a mark from an accredited certification body, such as CSA or cUL, before they can be sold.
Energy efficiency
If you ship a power adapter, it must meet efficiency rules: the US Department of Energy’s standard for external power supplies (currently Level VI, marked on the adapter; the Department has proposed changes) and the EU’s ecodesign regulation for external power supplies. Choosing an adapter that already meets them is usually enough. Many household and office products, including some powered over USB, also fall under the EU’s limits on off, standby, and networked standby power, which generally call for a low-power mode the product switches to on its own. In the US, products that charge a battery may also fall under the Department of Energy’s battery charger standard and California’s own rules.
Other markets
Japan (MIC radio certification and PSE electrical safety), Korea (KC), Australia and New Zealand (RCM), and others have their own approvals. Some accept test reports from the FCC or EU process; others require local testing, a local certificate holder, or both. Check early, because these can add time to a launch.
Where to go from here
Settle your list of markets in the concept phase. It shapes the radio approach, the safety design, and the test plan. Plan for compliance from day one covers what to do with that list. The compliance planner builds a starting list for your product and markets.
If you are planning a product for sale in several markets and want help mapping the path to certification, get in touch.