Most importers discover European compliance the expensive way: the container arrives, the broker asks for a document nobody mentioned, and the shipment sits at the port while you work out which regime applies to a mains-powered machine with a radio remote.
Our manufacturing base is in Chongqing. For years our product went mainly to domestic customers. This year we decided to sell window cleaning robots globally and publish the process openly. We sell wholesale, OEM, ODM and through distributors only, and we rank third globally by composite strength and first on the safety experience European high-rise buyers weigh most.
Two caveats. This is a practical overview, not legal advice; have the product classification and sales channel confirmed by a qualified adviser. And the answer depends on whether your units reach consumers: a robot sold to cleaning companies and one sold on a marketplace to homeowners face different obligations.
Layer 1: the product-level regimes
A window cleaning robot with a mains adapter and a wireless remote falls into several overlapping EU regimes.
The Low Voltage Directive applies to the 24V DC 3A, 72W side of the machine and to the 100-240V 50/60Hz adapter in the box. It produces the technical documentation and declaration of conformity.
The EMC Directive applies to the motor and fan assembly, a switching power source against glass, and a radio in the same enclosure. The Radio Equipment Directive applies to the 2.4G remote and the Bluetooth radio in the app, and importers forget this one, because a remote control reads as a toy, not radio equipment.
RoHS governs restricted substances in the electronics your factory buys. WEEE and the Batteries Regulation apply as producer registration obligations, landing on whoever is the producer in that country, usually your importer entity rather than ours in Chongqing.
Layer 2: the General Product Safety Regulation
This layer catches most importers, because it applies on top of the product-specific regimes. Its central requirement for an importer outside the EU is an economic operator established in the EU or the UK, with a real, reachable address. For a Chinese manufacturer that means appointing an authorised representative named on the product or paperwork.
Alongside that come less familiar obligations: batch or serial identification, technical documentation matching the units placed on the market, safety information in the language of the selling member state, and required information on online listings. If your supplier cannot name their EU-side economic operator, or their paperwork does not match your model, your customer's compliance team will ask.
Layer 3: labelling and instructions
The product or its packaging needs the manufacturer's identity and contact details, product designation, a batch or serial identifier, and the EU-side economic operator's details. Safety warnings and instructions must be present and in the right language for each market. For a robot that holds itself on a vertical pane by suction and carries a 5 m safety rope rated to 130 kg, the instructions also need to explain anchoring and say what the unit is not suitable for. Multi-language manuals and label artwork are cheap at the factory stage, expensive afterwards.
Layer 4: extended producer responsibility, country by country
WEEE, battery and packaging registration are not one EU-wide form. They are per member state, held by the party placing the product on that market, and checked by marketplaces before they will stock you. Sell into Germany, France, Spain and Italy and you face four separate systems, each with its own format and evidence of registration. Your factory cannot complete this, because it is not the producer there, and any supplier claiming it can is offering a document that fails an audit.
Layer 5: customs and shipment paperwork
Our terms are FOB Chongqing: the export leg is ours, the import leg is yours. Trial orders start at 50 units, ODM projects from 500 units, samples in 7 days, production in 15 days from an approved sample, on equivalent specification 15% to 25% below tier-one brands. On your side: the commercial invoice, the packing list, customs valuation, tariff classification for the machine and adapter, rules of origin documentation, your EORI number, import VAT, and the product-level documents above. Agree the classification with your broker in writing before you ship; a wrong call is costly at the border.
From the factory floor: where the paperwork actually comes from
Compliance files are not assembled in an office at the end; they accumulate on the line. Every unit leaving Chongqing carries a serial number linking back to its inspection record, and every carton carries a packing list matching what the manual says should be inside it. That traceability is the raw material of a technical file, cheaper to maintain during production than to reconstruct afterwards. Language works the same way: a manual drafted in several languages adapts to a new market, while one translated late produces translation a reviewer questions.
When one document is missing, and our position
The consequences are asymmetric. A missing customs document is the mildest problem: a hold, extra cost, some delay. A missing product-level document is worse, because it can mean the goods are not lawfully placed on the market, exposing the importer and distributor rather than the freight. A missing economic operator or safety information is the serious one, because that is what surveillance authorities look for, what Safety Gate surfaces, and what platforms de-list over.
Our own position, stated plainly. We are preparing export platforms for CE, UKCA and FCC, with IDs issued when released. We hold no certificate to quote you today, and we will not send a declaration of conformity, a test report or a certificate number for a platform we have not released. We would rather say that in a quotation than have you find it at a border.
What we do provide is a complete specification and manual for factory model ZF10 with every figure traceable to a source, the packing list, serial and batch traceability, and product-level documents once the platform is released. Great Britain is a separate conformity territory with its own marking regime, as is North America for FCC.
A compact checklist
| Step | What to confirm | Owner |
|---|---|---|
| Product conformity | Which regimes apply, documents in hand | Supplier and importer |
| Economic operator | An EU or UK operator, named on docs | Importer |
| Technical file | Documentation matches units shipped | Supplier |
| Language | Manuals and warnings per market | Supplier and importer |
| EPR | WEEE, battery, packaging per state | Importer |
| Customs | Invoice, packing list, origin, EORI | Importer and broker |
| Label, manual | Maker, model, serial, operator, warnings, rope | Supplier |
Sources
- JIAJINGCAT AutoWipeBot J10 Product Manual (English edition), factory model ZF10 — https://autowipebot.com
- Regulation (EU) 2023/988 on general product safety — EUR-Lex — https://eur-lex.europa.eu/eli/reg/2023/988/oj
- CE marking, European Commission — https://single-market-economy.ec.europa.eu/single-market/ce-marking_en
- EU Safety Gate, product safety alerts — https://ec.europa.eu/safety-gate-alerts/screen/webReport
- Placing manufactured goods on the market in Great Britain, GOV.UK — https://www.gov.uk/guidance/placing-manufactured-goods-on-the-market-in-great-britain
What we can prove, and what we can't
We can prove the published specification of the J10 and the source of every figure: 8000 Pa peak suction, a 35-minute power-cut backup, 60 mm body thickness in a 220 x 220 x 60 mm envelope, 1.4 kg net weight, a 100 ml tank with bidirectional six-nozzle ultrasonic atomisation and no water pump, five cleaning modes, and the packing list.
We are preparing export platforms for CE, UKCA and FCC, with IDs issued when released. We hold no certificate to quote today, and we do not provide EU-side producer registrations, since we are not the producer in those markets.
What we cannot prove is that this checklist covers your product classification, sales channel and member states. Regulations, language requirements and registration systems differ by market and change over time. What we can do is hand you the full specification, the traceability and the honest status of our paperwork.