Reference · Import
Market Compliance Matrix
The requirement set differs by destination, and the differences are where shipments get held. One table for the five markets buyers most often ask about.
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: that is set by the tariff classification your broker files, market by market, and it is argued through in how classification and landed cost work.
| 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.
- 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.
Questions on this reference
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.