Importing electronics from China: LVD, EMC, RoHS, WEEE

The Low Voltage Directive 2014/35/EU covers electrical equipment with a nominal input or output voltage between 50 and 1,000 volts AC, and between 75 and 1,500 volts DC. It targets electrical safety: shocks, overheating, fire risk. Its scope creates a frequent confusion: a product powered at 5 volts over USB falls outside these voltage ranges, but its mains adapter falls fully within them. And falling outside low voltage scope exempts you from nothing: EMC and RoHS almost always apply.

The EMC Directive 2014/30/EU requires a device not to disturb its environment and to keep working despite the disturbances it is exposed to. Switch-mode power supplies, motors, dimmers: anything that switches current emits interference. It is the most cross-cutting directive in electronics, and one of the most often missing from the files we audit.

The RoHS Directive 2011/65/EU caps ten substances in electrical and electronic equipment: lead, mercury, cadmium, hexavalent chromium, two families of brominated flame retardants and four phthalates added by Directive 2015/863, applicable since July 2019. The usual threshold is 0.1% by weight per homogeneous material, and 0.01% for cadmium. RoHS falls under CE marking: it is proved by tests on the materials, not by a logo applied to the product.

As soon as a product communicates, over Bluetooth, Wi-Fi or any other radio frequency, a fourth directive comes into play: the Radio Equipment Directive 2014/53/EU. It brings electrical safety, electromagnetic compatibility and efficient use of the radio spectrum together in a single text. A connected speaker falls under it, on top of the three previous directives, and its declaration must show that.

The trap comes from pre-certified modules. The factory fits an already approved radio module and concludes the product is compliant. It is not: it is the finished product that must be assessed, with its housing, its antenna and its power supply. A certified module poorly integrated can emit outside the limits, and the finished product's file still needs to be built regardless.

An electronic product rarely falls under a single piece of legislation, and its EU declaration of conformity must reflect that: every directive covered, every standard applied, the manufacturer, the European authorised representative if one exists, then a signature and a date. For consumer electronics and IT equipment, the common harmonised standards are the EN 62368-1 family for safety and the EN 55032 and EN 55035 families for EMC, published in the Official Journal of the European Union. Check that the standards cited are still in force: the lists change over time, and a withdrawn standard no longer gives a presumption of conformity.

The declaration must stay available for ten years after the last product is placed on the market: the manufacturer archives it, and you must be able to produce it for the authorities at any time. Demand the document before paying the balance, then check the consistency between the declaration, the test reports and the actual product. A report run on a similar model does not cover your reference.

The WEEE Directive 2012/19/EU organises the end of life of electrical and electronic equipment around extended producer responsibility. When the manufacturer is not established in the Union, whoever places the product on the market is treated as the producer: the importer, meaning you. This status does not depend on the brand shown on the product, but on where the manufacturer is established.

This translates into concrete steps: registering as a producer in every member state where you sell, following local mechanisms, a national register or an approved compliance scheme; showing your producer identification number on your sales documents; funding collection and treatment, in France through an eco-fee shown on the selling price. The product carries the crossed-out wheeled bin symbol. If it contains batteries, the Batteries Directive 2006/66/EC adds its own markings. These obligations need preparing before the first sale, not after the first check.

Many factories produce market-specific versions: a Chinese rating plate, a 220-volt label, a local manual. Demand the EU version in writing, in the brief: a type C, E or F plug, a rating plate at 230 volts and 50 hertz, an approved cable, a manual in the language of the country of sale. These details are validated on the pre-production sample, never on a catalogue photo.

On compliance itself, four documents form the foundation: the signed EU declaration of conformity, named test reports, the RoHS declaration material by material, and the technical file. A document with no precise product reference, a declaration that cites only one piece of legislation out of three, or a materials list several years old are warning signs. Importer identification happens on the product: your name and address must appear on the device or its packaging.

Sorva is a sourcing and brokerage house, with a Chinese-speaking team in Guangzhou. On electronics, we build the compliance foundation from the factory selection stage: applicable legislation identified with you, EU declaration of conformity and test reports demanded from the factory in Chinese, consistency checked between the standards cited, the actual product and the European version ordered. If tests are missing, we steer the factory towards a recognised laboratory, and we run a pre-shipment inspection to confirm the goods shipped match the file.

In most cases you pay no fees: you open a file with us, we negotiate the goods on your behalf, and we take a commission on the ex-factory value.