If you sell EV chargers in the EU under your own brand, EU law treats you as the manufacturer, even if every unit is built in Shenzhen. The CE marking on the housing is your declaration, not the factory’s. The factory’s test reports are useful evidence, but you sign the paperwork and answer to market surveillance authorities.
This guide covers the directives that typically apply to portable and wall-mounted AC chargers, the documents you need and how to split the work with your OEM supplier. For the wider picture, see our guide to OEM and private-label EV chargers.
Why your brand is the manufacturer
The European Commission’s page for manufacturers under CE marking sets out the core duties: carry out the conformity assessment, establish the technical documentation and draw up the EU declaration of conformity before affixing the CE marking. The EU’s Your Europe guidance adds that a business which has a product made and sells it under its own name or brand counts as the manufacturer.
In practice your factory does most of the engineering and testing. The legal responsibility still sits with you, so you need access to the evidence and a clear understanding of what it covers.
Which directives apply to an EV charger
Most AC chargers fall under several pieces of EU legislation at once. Your test lab will confirm the list for your exact design.
| Legislation | What it covers | When it applies to a charger |
|---|---|---|
| Low Voltage Directive 2014/35/EU | Electrical safety for equipment rated 50 to 1000 V AC or 75 to 1500 V DC | Mains-powered chargers without a radio module |
| EMC Directive 2014/30/EU | Electromagnetic emissions and immunity | Chargers without a radio module |
| Radio Equipment Directive 2014/53/EU | Safety, EMC and efficient use of radio spectrum | Smart models with Wi-Fi, Bluetooth or cellular |
| RoHS Directive 2011/65/EU | Restriction of ten hazardous substances | All electrical and electronic equipment |
The Low Voltage Directive covers equipment with an input or output voltage of 50 to 1000 V AC, so a 230 V portable charger or a three-phase wallbox is in scope. The EMC Directive limits emissions and governs immunity to interference. Once a charger has a radio module it becomes radio equipment under the Radio Equipment Directive, whose essential requirements include safety and EMC, so smart models are normally assessed under the RED rather than separately under the LVD and EMC Directive. The RoHS Directive restricts ten substances, including lead, cadmium, mercury and hexavalent chromium.
Other rules sit alongside CE marking. WEEE marking, the General Product Safety Regulation and the need for an EU-based economic operator all affect private-label chargers; see EU GPSR and the responsible person.
Conformity assessment and standards
For the LVD, the Commission notes that notified bodies are not required, so the manufacturer alone carries out the conformity assessment. EMC is usually handled the same way, through internal production control. Under the RED, a manufacturer can use internal production control when it has applied the relevant harmonised standards in full; otherwise a notified body is involved.
Labs commonly test chargers against standards such as EN IEC 61851-1 for conductive charging systems and, for Mode 2 portable chargers, IEC 62752 for in-cable control and protection devices, plus the relevant EMC and radio standards. Ask the lab to state in the report which editions were used and whether they are harmonised, because only harmonised standards give a presumption of conformity.
The technical file and the declaration of conformity
The technical documentation is the evidence behind your CE marking. It must be kept for at least 10 years after the product is placed on the market and shown to authorities on request. For a private-label charger it typically includes:
- A general description of the product, its variants and intended use.
- Design drawings, circuit diagrams and a bill of materials for safety-critical parts.
- A risk assessment covering electrical, thermal and mechanical hazards.
- Test reports for safety, EMC and radio (if fitted), plus RoHS evidence such as material declarations or test results.
- A list of the standards applied, with editions.
- Copies of labels, the user manual and safety instructions in the languages of the countries of sale.
- The signed EU declaration of conformity.
The declaration of conformity names your company as manufacturer, identifies the product by model and type, lists the directives and standards, and is signed by someone authorised to commit your business. Ask your factory for the test reports and a draft declaration, then review them yourself before signing.
Marking and labeling the product
The CE marking must be visible, legible and indelible, with a minimum height of 5 mm unless specific rules say otherwise. Your name, registered trade name or trademark and postal address, plus a type, batch or serial number, should appear on the product or, where size does not allow it, on the packaging or an accompanying document. Our article on rating labels and required markings covers the full label layout, and packaging, labeling and manuals covers the printed materials.
Do not let branding crowd out the legal marks. If the logo area on the housing is small, agree the label layout with the factory during sampling rather than after the first production run.
Splitting the work with your OEM supplier
A clear division of tasks avoids gaps. A workable approach is:
- The factory supplies test reports, a draft technical file and RoHS evidence for the exact configuration you order.
- You review the documents, confirm the standards with a test lab or notified body where needed, and sign the declaration of conformity.
- Both sides agree in writing that no safety-critical component, firmware or production site changes without notice.
- You keep the technical file, or have guaranteed access to it, for the full 10 years.
Certification marks at EVDANCE vary by model, so request the certificate and test report for the exact model and configuration you plan to sell. Our OEM and ODM program gives you a dedicated account engineer who gathers this documentation during sampling. This article is general information, not legal advice; confirm your obligations with a notified body, test lab or lawyer.
Key Takeaways
- A business that sells a charger under its own brand in the EU is treated as the manufacturer and signs the declaration of conformity.
- Most chargers fall under the LVD, EMC Directive and RoHS, while smart models with radio modules are assessed under the Radio Equipment Directive.
- The technical file must be kept for at least 10 years, so secure access to the factory’s test reports for the exact configuration you sell.
- The CE marking must be at least 5 mm high, visible, legible and indelible, so plan label space before branding the housing.
Sources & Standards
- European Commission (DG GROW) — Manufacturers: CE marking
- European Commission (DG GROW) — Low Voltage Directive (LVD)
- European Commission (DG GROW) — Electromagnetic Compatibility (EMC) Directive
- European Commission (DG GROW) — Radio Equipment Directive (RED)
- European Commission (DG Environment) — RoHS Directive
