Reference · Import
Market Compliance Matrix
The requirement set differs by destination, the documents required differ with it, and the differences are where shipments get held. One table for the five markets buyers most often ask about.
Which compliance documents apply to EU, UK and US imports?
Read the matrix by destination column, not by document row: the EU asks for CE, RoHS and GPSR (EU) 2023/988 obligations, the UK for UKCA prepared on request, and the US for the FDA material declaration and the labelling rules that attach to it. A certificate that is valid in one column does not discharge another. Ask which authority would ask to see each file, and verify the certificate number with the issuing body before artwork approval. The import compliance guide explains why the columns differ.
This matrix is the starting point for a compliance conversation, not the end of it. Rules change, thresholds move, and a customs officer applies the regulation in force on the day. Confirm the current position with the authority named below before you ship — see how we test for the measurements our declarations rest on. One thing this table deliberately does not contain is a duty rate or an HS code: the rate is set by the tariff classification your broker files, market by market, and it is argued through in how classification and landed cost work. Read the last column as the documents required at the border rather than every document you may end up holding.
Compliance is a stack, not a list
Requirements by destination market
| Market | Marking / conformity | Chemical restriction | Documents to hold |
|---|---|---|---|
| European Union | CE marking under the Low Voltage, EMC and RoHS directives, with general product safety obligations under Regulation (EU) 2023/988 | REACH Annex XVII, including phthalates; SVHC screening | DoC, technical file, RoHS report, REACH statement, GPSR risk assessment |
| United Kingdom | UKCA marking for Great Britain; CE accepted under the transition arrangements in force | UK REACH, which maintains its own candidate list | UK DoC, technical file, substance reports |
| United States | No federal product marking for non-radio devices; FCC applies only to units with radio, which this range does not have | State-level regimes apply; phthalates are restricted in some states | Material compliance statement, MSDS, general certificate where applicable |
| Canada | Provincial electrical-safety approval where applicable; ISED only if the unit has radio | Consumer product safety regime | Test reports, bilingual labelling |
| Australia | RCM marking where electrical safety schemes apply at state level | Industrial chemicals regime | Test reports, supplier declaration of conformity |
Where a destination requirement cannot be met by a catalogue configuration, the answer is usually an OEM change rather than a waiver: a different material, a different finish, or a different cable. The guide to clearing customs cleanly walks through which changes are cheap and which reset a tooling budget.
The EU column, and what changed
The EU column reflects Regulation (EU) 2023/988, which replaced the General Product Safety Directive and widened what a risk assessment has to cover before a product is placed on the market [European Parliament and Council, 2023]. A matrix that still describes the previous regime is the most common way an otherwise correct document set fails at the border.
The two rows buyers cannot fill
Two rows in this table are the ones a buyer usually cannot fill in alone. The first is the responsible person: under the general product safety framework an operator established in the Union has to be named on the product or its packaging, and for an importer that obligation is theirs whether or not the factory prepared anything. What that person actually signs for, and what they do not, is a term the industry uses loosely — the wholesale glossary keeps the definition next to the ones it is confused with. The second is the technical file, which has to exist before a declaration is signed and is not the same document as the declaration itself.
What a matrix cannot tell you
A matrix also cannot tell you whether the numbers behind a certificate are still the numbers in the product. That is why we publish the measurement conditions rather than only the results: the noise figure is taken at 30 cm, the IPX5 figure is a 12.5 l/min spray for three minutes, and the material declaration names the silicone grade. How each figure is measured is the page that makes those claims checkable — a table of destinations is only as good as the test records underneath it, and a buyer who asks for the report rather than the logo is asking the right question.
According to the Wikipedia entry Registration, Evaluation, Authorisation and Restriction of Chemicals, REACH places the duty of demonstrating safe use on the manufacturer or the importer rather than on a market authority, which is why the EU column of this matrix asks who holds the file rather than which body approved the product. The same shift — responsibility moving to the party placing goods on the market — is what [Chopra & Meindl, 2016] place at the point where compliance becomes a supply-chain design question instead of a paperwork task.
References
- European Parliament and Council (2023). Regulation (EU) 2023/988 on general product safety, replacing Directive 2001/95/EC. Official Journal of the European Union.
- European Parliament and Council (2014). Directive 2014/30/EU on electromagnetic compatibility. Official Journal of the European Union.
- Health and Safety Executive (2021). UK REACH — how to comply if you sell or supply chemicals or products. London: HSE.
- U.S. Consumer Product Safety Commission (2008). Consumer Product Safety Improvement Act of 2008, Public Law 110-314.
- Chopra, S. & Meindl, P. (2016). Supply Chain Management: Strategy, Planning, and Operation (6th ed.). Harlow: Pearson.
Questions on this reference
Which required documents differ most between the three markets?
The EU asks for a declaration of conformity and a technical file; the UK asks for the UKCA position and a UK-based responsible entity; the US has no product approval but expects material documentation on request. Import compliance fails most often on the second item rather than the first, because a responsible entity is easy to overlook until a shipment needs one.
Does Slow Duo hold FCC certification?
FCC applies to devices that emit radio frequency energy. The Slow Duo range is app-free with onboard control only, so there is no radio module to certify. We do not claim FCC for that reason.
Is UKCA included or does it cost extra?
UKCA documentation is prepared on request for the UK market at no additional charge. It is not included by default because the majority of shipments are EU or US bound.
Can one configuration be shipped to all five markets?
Usually yes on the product, and no on the paperwork. The construction that passes in the EU generally passes elsewhere; what differs is the marking, the labelling language and the named importer. Plan the documents per destination, not the product.
Which layer of the stack is most often missing?
Labelling and traceability. It is decided after the product is finished, it needs a name and an address from somebody other than the factory, and it is the row inspectors read first. See what every shipment includes for what ships automatically.
Next: how the three chemical regimes differ — or what changes when the product carries your brand.
A table tells you the requirement; it does not tell you who has to prove it. The import guide works through classification and landed cost on top of this matrix, and the certificate pack lists the documents that evidence each row. What a wholesale order actually commits us to is in the commercial commitments.
Putting this reference to work
This page is the data. The four sections below are where it changes a decision: the terms it is quoted alongside, the guide that explains the reasoning, and the models the figures apply to.