RP16

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Regulation (EU) 2023/988 · Article 16

Electronics carry four obligations that sellers keep mistaking for one.

A power bank entering the Union touches product safety, electromagnetic compatibility, restricted substances and waste registration. Each has its own paperwork, and only one of them is satisfied by a factory certificate.

Reviewing an electrical product file against the safety requirements
Electronics carry other directives on top of the product safety rules.

Four rules, one product

CE marking covers conformity, RoHS covers restricted substances, WEEE covers end-of-life registration in each member state, and the General Product Safety Regulation covers the residual safety obligations and the responsible person.

WEEE in particular is national rather than European, which surprises sellers who assume one registration covers the Union.

Batteries change the picture

Products with lithium cells attract more attention at the border and in the alert system, and they bring transport rules of their own. The documentation expected is correspondingly heavier.

If your catalogue includes cells, assume the file will be requested at some point rather than hoping it will not.

Documentation for an electronic device prepared for the European market
The responsible person holds the file; the manufacturer holds the risk.

Chargers, adapters and the plug

Mains-connected accessories are checked frequently and fail often, usually on insulation distances or on markings that do not match the tested sample.

A certificate that refers to a slightly different model is worse than no certificate, because it invites a closer look at everything else.

The four things you receive

Mandate, label block, live verification code and a staffed contact address inside the Union, all issued the same working day.

Every one of them is meant to be checked by someone who has no reason to believe you.

Built to be verified by a sceptic

We assumed from the start that the person reading your label would rather not take your word for it.

Everything in the service is shaped around that assumption, which is why it holds up when it is tested.

Questions we are asked

Does the responsible person handle my WEEE registration?

Not as part of the Article 16 role. WEEE registration is national and separate; we tell you where you stand but the registrations are made in each member state where you sell.

Is CE self-declaration enough for consumer electronics?

For many categories yes, provided the tests behind it are real and the file supports them. The declaration is a statement of responsibility, not a formality.

What if my supplier's certificate names a different model?

Then it does not cover the product you are selling. Mismatched certificates are one of the most common findings, and correcting them is far cheaper before a shipment than after a hold.

With electronics the obligations do not stack neatly, and the only workable approach is to treat each one as separate until it is proven satisfied.

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Related reading

How this is enforced across the Union

Electronics fall under the GPSR and under sector rules at once — Low Voltage, EMC and Radio Equipment. One responsible person covers them all for the authority.

Authoritythe Commission and the network of national market surveillance authorities
Language of warningsWarnings and safety information must be in the languages of every Member State where the product is sold, decided by each of them.

The regulation is directly applicable, but enforcement is national. That combination is what makes a single EU-established responsible person practical: one designation, twenty-seven possible authorities.