Certification responsibility for an OEM product usually falls on the brand bringing it to market, not the factory that built it. That single fact changes how most of this section should actually be planned — and it’s worth understanding before assuming a supplier’s existing certifications cover you.
As an OEM/ODM manufacturer, certification and regulatory compliance are typically completed under our customers’ brands rather than under MyGica’s own name. Our engineering team has extensive experience supporting CE, FCC, UL, CB Scheme, RoHS, REACH, RED, and other regional compliance requirements throughout the product development process. For connected products, we also help OEM partners prepare for emerging EU cybersecurity requirements such as the Cyber Resilience Act (CRA).
Why Certification Usually Follows the Brand, Not the Factory
For markets like the EU, CE marking is a self-declaration made by whoever places the product on the market — legally, that’s typically the brand owner or importer, not the original manufacturer. A factory’s general “CE-compliant” claim on its own catalog product doesn’t automatically transfer to a version of that product rebranded and sold under a different company’s name; the responsible party changes, and so does who’s legally on the hook for the declaration of conformity.
The same logic shows up with FCC certification in the US, where a “grantee” is registered against a specific FCC ID — private-labeling or rebranding a wireless-enabled product sometimes requires its own registration steps, depending on how the underlying radio module and firmware are handled. The practical takeaway: asking “is this factory’s product CE/FCC certified?” is often the wrong question for an OEM project. The more useful one is “can this supplier get my branded version through certification, and have they actually done it before?”
Quick Reference: What Each Certification Actually Covers
| Certification | Region | What it covers | Typically required for |
|---|---|---|---|
| CE | European Union | Safety, EMC, and (for wireless-enabled products) radio equipment compliance, bundled into one marking | Any electronic product placed on the EU market |
| FCC | United States | Radio frequency emissions and electromagnetic compatibility | Any product containing a radio (Wi-Fi, Bluetooth, cellular) sold in the US |
| RoHS | EU (increasingly referenced globally) | Restricts specific hazardous substances (lead, mercury, certain flame retardants, etc.) in electronics | Electronics sold in the EU; many other markets now expect it as a baseline even where not strictly mandated |
| UL | US / North America | Electrical and fire safety testing, often to a specific UL standard for the product category | Not always legally mandated, but frequently required by retailers, insurers, or institutional buyers regardless |
| CB Scheme | International (~50+ member countries) | A safety test report recognized across member countries, reducing the need to fully retest in each one | Products being certified for multiple international markets at once |
Which combination actually applies depends on your specific product (does it have a radio module? what voltage does it run on?) and your target markets — this table is a starting reference, not a substitute for confirming exact requirements with a testing lab or certification consultant for your specific configuration.
Certification by Market
Certification requirements are ultimately driven by destination market, not just product type. As a starting reference:
| Market | Typical Certifications |
|---|---|
| EU | CE + RoHS + WEEE |
| USA | FCC + UL |
| Canada | ICES (EMC) + IC/ISED (required additionally for any wireless-enabled product) |
| UK | UKCA |
| Australia | RCM |
| Japan | PSE / TELEC (wireless) |
A note on the UK specifically: since Brexit, UKCA has been the UK’s own conformity marking, separate from CE — though the UK has extended transitional acceptance of CE marking more than once, so the current status is worth confirming rather than assuming, since it’s changed on more than one occasion since the original split.
Newer Regulations Worth Knowing: CRA and REACH
CE, FCC, RoHS, UL, and CB cover the certifications most buyers already have on their radar. Two additional EU regulations are increasingly relevant for connected e-paper products specifically, and are worth planning for now rather than treating as a future problem.
The Cyber Resilience Act (CRA)
The EU’s Cyber Resilience Act applies to “products with digital elements” — hardware or software designed to connect to a network or another device, directly or indirectly. Any e-paper display with Wi-Fi, Bluetooth, or cellular connectivity for remote content management falls squarely within this scope, which makes it directly relevant to most commercial e-paper signage, not just IoT devices in the traditional sense.
The CRA entered into force in December 2024 and phases in over several years, but two dates matter most for anyone shipping connected products into the EU in the near term: conformity assessment body notification requirements apply from June 2026, and mandatory vulnerability and incident reporting obligations begin September 11, 2026 — meaning manufacturers placing connected products on the EU market need vulnerability-handling and incident-reporting processes in place well before that date, not after it. Full requirements, including security-by-design obligations assessed before market entry, apply from December 2027.
In practice, this means buyers sourcing connected e-paper signage for EU deployment should be asking suppliers now whether they have a vulnerability handling and disclosure process in place, and whether they can produce a software bill of materials (SBOM) for the product’s firmware — not waiting until the 2027 deadline to raise it.
REACH
REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is a broader EU chemical safety regulation than RoHS — where RoHS specifically restricts certain substances in electronics, REACH covers a much wider list of “substances of very high concern” (SVHC) across virtually any product sold into the EU, including housing plastics, coatings, and cabling. The SVHC candidate list is updated periodically, so a product’s REACH status isn’t a one-time check — it’s worth confirming a supplier can provide current SVHC declarations rather than an outdated compliance statement.
Certifications for Battery-Powered Displays
Given how common battery and solar power configurations are for e-paper signage — see our guides to outdoor e-paper deployment and customization options — battery certification deserves its own section rather than a footnote. This is also an area with real, active regulatory change right now, not a settled topic.
UN38.3 is the one most likely to actually block a shipment if missing: it’s a mandatory transport-safety test for lithium batteries, required by the large majority of countries for air, sea, and road transport under IATA, IMDG, and ADR rules. Without a valid UN38.3 test report, carriers and freight forwarders can legally refuse the shipment outright — this isn’t a market-access certification in the way CE or FCC are, it’s a precondition for the goods physically leaving the factory by normal logistics channels at all.
IEC 62133 (EN 62133 for the EU) is the companion safety standard covering the battery’s behavior in use rather than in transit — overcharge, short-circuit, and thermal abuse testing. It’s required for CB Scheme certification of batteries and factors into CE marking for battery-containing products sold in the EU.
The EU Battery Regulation (EU) 2023/1542 is newer and worth watching closely if you’re shipping battery-powered e-paper into the EU: as of January 1, 2026, all lithium-ion batteries shipped by air — including batteries already installed inside a product — must not exceed 30% state of charge, a rule that’s already in effect and easy to miss if working from older shipping guidance. New labeling requirements (chemical composition, recycling symbols, and CE marking on the battery itself) apply from August 18, 2026. Larger battery categories are also moving toward a digital “Battery Passport” requirement in the years ahead, though this currently affects industrial and EV-scale batteries more than the smaller cells typical in signage.
Exporting a Lithium-Battery Product to the US: The Four-Part Checklist
For a battery-powered e-paper display heading to the US specifically, four requirements typically apply together, and it’s worth treating them as one bundle rather than four separate boxes to check:
- UN38.3 — the underlying design-safety test that qualifies the battery type as fit for transport at all. This is the foundation everything else builds on.
- DOT 49 CFR (PHMSA Hazardous Materials Regulations) — the US-specific transport rules that implement and build on UN38.3, covering packaging (non-conductive inner packaging, rigid outer packaging), Class 9 hazmat marking, watt-hour labeling, and shipping paperwork for anything moving to, from, or within the US by air, sea, or road. Having a UN38.3 report doesn’t automatically mean a shipment is packaged and documented to 49 CFR standards — they’re related but distinct requirements, both need to be satisfied.
- FCC — required if the display has any wireless module (Wi-Fi, Bluetooth, cellular), independent of the battery itself.
- UL — not always legally mandated depending on product category, but frequently expected by US retailers, integrators, and institutional buyers as a practical condition of doing business, as noted earlier in this guide.
Missing any one of these doesn’t necessarily block the product from being built — but it can very much block it from being legally shipped, imported, or sold, which makes this bundle worth confirming with a supplier before production starts, not after a batch is ready to ship.
What This Looks Like in Practice
For an OEM e-paper signage project, certification scope is usually driven by two things: what’s inside the unit (a Wi-Fi or cellular module triggers FCC/CE-RED requirements that a purely wired, offline display wouldn’t need) and where it’s being sold (a project shipping only to the US has a different certification path than one shipping to both the US and EU).
This is the area where having a manufacturing partner with direct certification experience — rather than a general assurance that “we can handle it” — actually matters. We’ve taken client products through UL, FCC, CE, RoHS, and CB Scheme certification specifically because most OEM buyers don’t have in-house regulatory expertise and don’t want to manage multiple external test labs and consultants themselves on top of running the rest of the project.
What to Prepare Before Starting the Certification Process
A few things tend to speed this up regardless of which certifications apply:
- A finalized bill of materials (BOM) — RoHS compliance in particular depends on the specific materials and components used, so certification typically can’t be finalized against a BOM that’s still changing.
- Documentation for any wireless module — if a Wi-Fi, Bluetooth, or cellular module is being used, its own existing certifications (many modules are pre-certified individually) can sometimes streamline the finished-product process, but this needs to be confirmed rather than assumed.
- Clarity on target markets up front — certification scope planned for a single market and expanded later is usually more expensive than planning for known target markets from the start.
FAQ
If a factory says their products are CE certified, does that cover my rebranded version?
Not automatically. CE is a self-declaration made by whoever places the product on the EU market — typically the brand or importer, not the original manufacturer — so a rebranded or customized version often needs its own declaration of conformity, even if the base hardware is identical.
Do I need UL certification if it’s not legally required for my product category?
It depends on your buyers. Many retailers, integrators, and institutional purchasers require UL certification (or an equivalent) as a condition of purchase even where it isn’t strictly mandated by law, so it’s worth checking your specific customers’ requirements rather than only the legal minimum.
Does adding Wi-Fi to an e-paper display change what certification is required?
Yes — any wireless-enabled product typically needs to meet radio frequency and EMC requirements (FCC in the US, the radio equipment portion of CE in the EU) that a purely wired or offline display wouldn’t be subject to.
Does the Cyber Resilience Act apply to a Wi-Fi-connected e-paper sign?
Very likely yes, if it’s being placed on the EU market — the CRA applies broadly to any hardware or software designed to connect to a network, directly or indirectly, which covers most connected signage. Vulnerability and incident reporting obligations begin September 2026, so this is worth addressing well ahead of the 2027 full-compliance deadline, not after it.
Does a battery-powered e-paper display need UN38.3 certification?
Yes, if it contains a lithium battery and is being shipped by air, sea, or road — UN38.3 is required by most carriers and countries as a precondition for legal transport, separate from any market-entry certification like CE or FCC. Without it, shipments can be refused by freight forwarders outright.
What’s the difference between UN38.3 and DOT 49 CFR for shipping to the US?
UN38.3 is the international design-safety test that qualifies a battery type as fit for transport. DOT 49 CFR is the US-specific regulation (enforced by PHMSA) that builds on UN38.3 and adds packaging, marking, labeling, and documentation requirements for shipments moving to, from, or within the US. A battery can have a valid UN38.3 report and still fail to meet 49 CFR packaging or marking requirements — both need to be satisfied for US shipments.
Can certification be done in parallel with production, or does it have to happen first?
This varies by certification and target market, but in general, certification testing needs a finalized, production-representative sample — starting it too early against a design that’s still changing usually means retesting later, which costs more time than waiting for a stable BOM.