Electronics: FCC vs. CE vs. UKCA Compared
Electronics is the product category with the most regulatory diversity across the three major Western markets. The US requires FCC and UL. The EU requires CE Marking under the EMC Directive, the Low Voltage Directive (or Radio Equipment Directive for wireless devices), and RoHS substance restrictions. The UK requires UKCA marking — which, for electronics, uses the same technical standards as the EU but requires separate conformity assessment and documentation. And an FCC test report is not valid for CE Marking. A CE Declaration of Conformity is not valid for UKCA.
This guide compares electronics compliance across the US, EU, and UK, and explains how to build multi-market compliance from a single test program and a single set of product data.
Not sure which EMC, safety, and substance regulations apply where? Use the Sustalium Global Compliance Map — select Electronics and toggle between markets to see FCC, CE, and UKCA requirements side by side.