9 June 2026 · 7 min read

Importing electronics from China: what compliance actually falls on you

When you import electronics for EU, UK or US sale, several duties land on you personally, not the factory. Here is what changes once you are the importer.

A factory in Shenzhen can build an excellent product and still leave you holding legal obligations you did not expect, because compliance law in the EU, UK and US is written around the concept of an "importer", and once you are the one bringing the product into the country, a specific set of duties attaches to you personally, separate from whatever the manufacturer already did or did not do.

The core idea: manufacturer duties do not disappear, importer duties get added

Buying a compliant-looking product from a factory does not transfer the manufacturer's compliance obligations to them and leave you clean. In every one of the EU, UK and US frameworks, importer duties exist on top of manufacturer duties, precisely because the manufacturer is often outside the country's jurisdiction and enforcement reach, and the importer is the nearest party regulators can actually act against.

In the EU

Under EU product legislation, once you import a CE-marked product from outside the EU for EU sale, you are the "importer" as a distinct legal economic operator, with defined duties: verify the manufacturer has carried out the correct conformity assessment procedure and that the technical documentation exists, verify the product bears the required CE marking (and, where relevant, other markings and the notified body number), verify the Declaration of Conformity and instructions accompany the product, and ensure the manufacturer's name and address (and your own, as importer) are on the product, its packaging, or accompanying documentation. If you have reason to believe a product is not compliant, you cannot place it on the market until it is corrected, and if it is already on the market, you have to take corrective action and inform the relevant authorities.

Separately, if there is no EU-established manufacturer, and you are the one bringing the product in, you may by default become the "economic operator established in the Union" required under Regulation (EU) 2019/1020's Article 4, taking on the tasks of holding technical documentation and cooperating with market surveillance authorities. See our authorised representative guide for exactly when this applies to you specifically versus when a separate authorised representative is needed instead.

In the UK

The UK's equivalent importer duties run in parallel to the EU's under the relevant UK product regulations (electrical equipment, EMC, radio equipment and similar), adjusted for the current UKCA and CE recognition position. Since the Product Safety and Metrology etc. (Amendment) Regulations 2024 extended recognition of CE marking in Great Britain, an importer bringing in CE-marked goods from the EU has a somewhat eased documentation position for certain product categories, but the underlying importer verification duties (checking conformity assessment was done, checking marking and documentation are present, putting your own name and UK address on the product where required) still apply. Given how often this area has changed, check the current gov.uk guidance for your specific product category rather than relying on a general summary, including ours.

In the US

US importer duties are more segmented by regulator. Under CPSC rules, importers of most regulated consumer products need to certify compliance, either in a General Certificate of Conformity (self-testing generally allowed for general-use products) or, for children's products specifically, a Children's Product Certificate backed by testing at an accredited, CPSC-accepted third-party laboratory. Note that from 8 July 2026, importers of most CPSC-regulated consumer products need to begin electronically filing certificates of compliance with US Customs and Border Protection at the time of import, a significant operational change from the previous paper-based approach. Separately, if the product has a radio or is otherwise subject to FCC equipment authorization, whoever imports it needs the correct Certification or Supplier's Declaration of Conformity to already be in place before the goods can clear customs; see our FCC Certification vs SDoC piece for that distinction.

What happens at the border, and after

Customs authorities in the EU, UK and US can all request compliance documentation at the point of import, and non-compliant or undocumented goods can be detained, refused entry, or required to be brought into compliance or destroyed at the importer's cost. This is separate from, and in addition to, any later market surveillance action once goods have already reached shelves or warehouses. The party named as importer on the paperwork carries this exposure directly, which is part of why the choice of who is legally "the importer" (you, a distributor, a customs broker acting on your behalf) is worth deciding deliberately rather than defaulting to whoever happens to file the paperwork.

Language and labelling requirements differ by market

Compliance documentation and product labelling requirements are not just about content, they are about language too. EU member states can and do require safety information, instructions and the Declaration of Conformity to be available in their own official language for products sold in that country, even though the underlying legislation is EU-wide. UK requirements are in English. US labelling requirements are generally in English, with Spanish-language warnings required for certain product categories under specific state or federal rules. If you are having a factory produce packaging or manuals, confirm the required languages for every country you plan to sell into individually, rather than assuming one English-language version covers every market.

The documents you should be asking the factory for, before you pay

Given all of the above lands on you, the practical defence is asking the factory for the underlying evidence before committing to a production run, not after goods are already on the water: the actual test reports (not just a supplier's claim of compliance), the technical file or at minimum a description of what it contains, and a properly completed Declaration of Conformity naming the specific legislation and standards. A factory that cannot produce genuine test reports on request is a meaningful risk signal, whatever their sample photos or existing customer list look like.

What we will not tell you

We are not going to give you a generic "checklist that guarantees compliant imports", because the correct checklist depends entirely on your specific product, its technology (radio or not, children's product or not, battery or not) and your specific markets. What we can do reliably is map the regulations that apply to your specific product and market combination with our free requirements checker, each with a link to its official source, so you know precisely what to ask your factory for before the goods ship.

Sources

  1. 01CPSC: General Certificate of Conformity
  2. 02CPSC: Children's Product Certificate
  3. 03gov.uk: Placing manufactured goods on the market in Great Britain
  4. 04Regulation (EU) 2019/1020 on market surveillance
  5. 05FCC: Equipment Authorization overview

Not sure which rules apply to you?

Answer a few honest questions about your product and see every applicable regulation for the EU, UK and US, each linked to its official source.

Check your requirements

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