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Analisis · 2026-10-03

Appliances: three layers of mandatory rules, ten markets

Appliances look like the most standardised category, but a shared technical baseline and a shared mandatory requirement are different things. IEC 60335 is the baseline nearly everywhere; what turns it into a legal obligation differs by market. This covers three layers across ten markets, safety, energy and marking.

One baseline, ten sets of obligations

Anyone who makes appliances knows the IEC 60335 family: 60335-1 holds the general requirements and 60335-2-x splits by product, with a part each for kettles, vacuum cleaners and fans. Most markets adopt it, so the technical baseline can be treated as one and the same. IEC 60335-1 gained AMD1:2025 on 31 October 2025, forming Edition 6.1, and markets are migrating from Edition 6.0.

A single technical baseline is not a single set of obligations, though. Adoption is not simultaneous, the citing law differs, and so does the way compliance is proved. The ten markets below are taken one at a time.

EU and UK: one declaration, two marks

The EU puts appliance safety inside the Low Voltage Directive, LVD 2014/35/EU, which applies to equipment rated between 50 and 1000 V AC, or 75 and 1500 V DC. Electromagnetic compatibility falls under EMC 2014/30/EU, energy under the implementing regulations made beneath the Ecodesign framework ErP 2009/125/EC, and general product safety under GPSR (EU) 2023/988, which has applied since 13 December 2024.

On conformity, most appliances fall in the self-declaration category: test against the harmonised standards EN 60335-1 and EN 60335-2-x, compile the technical file, sign the declaration of conformity and apply the CE mark. This is where people misjudge the system. CE is not a certificate handed out by a body; behind most CE marks on appliances sits the manufacturer's own declaration.

The UK framework comes from the same source but has separated. The Electrical Equipment (Safety) Regulations 2016 and the EMC Regulations 2016 apply, Great Britain uses the UKCA mark, and CE is recognised indefinitely, so either route works into GB. What to watch is that the two lists of harmonised standards are not identical item for item, so a test report should be checked against the list of whichever market it is aimed at.

US: no federal appliance safety law

The US structure differs from the EU's, and this is worth setting out on its own. There is no federal appliance safety act, and therefore no unified mandatory mark equivalent to CE. What is mandatory sits elsewhere: electromagnetic compatibility, where products with digital circuitry fall under FCC Part 15, and energy, where DOE standards (10 CFR 430 and 431) and the FTC EnergyGuide label (16 CFR 305) apply.

So what carries safety? Standards such as UL 60335-1, listing by a third-party certification body (an NRTL), and requirements from sales channels and insurers. The standard itself is voluntary, but it is hard to avoid in practice, because large retail channels and insurers ask for the listing. For a buyer, this means the US compliance file leans on test reports and listing records more than on any single mark.

Japan and Korea: PSE and KC both split by tier

Japan regulates under the Electrical Appliance and Material Safety Act (DENAN), centred on the PSE mark, and PSE has two tiers. Products designated as specified electrical appliances require third-party inspection by a registered inspection body and carry the diamond mark; the rest may be self-declared and carry the circle mark. Which tier a product is in decides whether a third party is needed at all, and that is the first thing to establish in Japan.

Korea regulates under the Electrical Appliances and Consumer Products Safety Control Act, and under the KC mark three tiers of assessment apply as well: safety certification (higher risk, third-party testing and potentially a factory inspection), safety confirmation (testing), and a supplier's declaration of conformity. Both countries share one trait worth noting: the tier is set by the regulatory list, not by intuition about the product, so two similar models from one factory can land in different tiers.

China: GB 4706 plus CCC

China builds on GB 4706.1 and the GB 4706 series parts (aligned with the IEC 60335 family), with EMC handled separately under GB 4343.1 for disturbance and GB 17625.1 for harmonics. Appliances that fall inside the CCC mandatory certification catalogue need CCC certification through a designated body, which includes a factory inspection; the current implementation rule for household and similar equipment is CQC-C0701-2024.

One division is easy to miss: products inside the catalogue and outside it follow entirely different routes. Inside means mandatory certification plus factory inspection. Outside means complying with the mandatory GB standards and carrying product liability yourself, with no unified certification mark. Whether a product ships as an accessory with a host machine or retails on its own can change the answer, and dropping that condition turns an accurate statement into a wrong one.

Canada and Australia-NZ: mandatory at provincial and state level

Canada has no federal electrical safety act. The obligation comes from provincial electrical safety law, which typically requires certification by an SCC-accredited body, Ontario's ESA being the usual example; energy falls under NRCan's Energy Efficiency Regulations, and general safety is covered by the CCPSA.

Australia and New Zealand work the same way, with the obligation sitting in state electrical safety law and managed through the EESS tiers: higher-risk levels need third-party certification and registration, lower-risk levels lean on a declaration, and the common mark is RCM, under AS/NZS 4417.1 and .2. The technical standards are AS/NZS 60335.1 and the AS/NZS 60335.2.x series. In both markets the mark is national while enforcement is local.

Gulf and Brazil: designated bodies and local representatives

The Gulf states regulate under the GSO technical regulation for low-voltage electrical equipment, requiring assessment by a designated body and the G-Mark, with Saudi Arabia routing through conformity certificates on SABER. There is no self-declaration option in this route.

Brazil applies mandatory certification through INMETRO, handled by an INMETRO-accredited certification body, and generally requires a local representative in Brazil; products with wireless functions also need ANATEL certification. For an exporter, the part of this that takes longest is often not the testing but finding a local entity to hold the paperwork.

Ten markets side by side

Read the three layers together, and what is worth remembering is not the standard numbers but which layer the obligation lands on. In the EU it lands on safety, proved by self-declaration. In the US it lands on EMC and energy, while safety is carried by channel and insurer requirements for third-party listing. In the Gulf and Brazil it lands on designated bodies; in Canada and Australia-New Zealand it lands in provincial and state law.

The table also explains why one test report is worth different amounts in different markets. The report proves the technical baseline, while the obligation lands in law. Same baseline, different law.

What to ask before you order

Appliance evidence should be asked for in three separate groups; mixing them is the fastest way to a vague answer. On safety, ask which edition of IEC 60335, or the corresponding national adoption, the batch was tested to, which laboratory issued the report, and which parts of the series it covers. On energy, ask for the measured efficiency value, the regulation it was assessed against, and the label version. On access, ask who holds the certification in the target market: the factory, the trading company, or the importer.

That last group is the most often skipped and the most likely to surface at the port. A CCC certificate, a KC certificate or an INMETRO certification is held by a legal entity, not by a production line, and if the holder changes, the certificate does not travel with the goods. To work through these in order, start with the free verification checklist. The previous article in this series covers toys, one toy, ten markets; label language is covered in label language requirements; to see how certifications are recorded in a report, look at a report sample, or get in touch.