Our product falls under an ecodesign regulation

The Ecodesign Directive 2009/125/EC is a framework. It does not set limits itself; implementing measures for defined products do (Article 2(3)). Products covered by an implementing measure may be placed on the market or put into service only if they comply with it and bear the CE marking (Article 3(1)). Before that, the manufacturer or its authorised representative ensures that conformity is assessed (Article 8(1)), affixes the CE marking and issues an EC declaration of conformity with the elements of Annex VI that refers to the measure (Article 5(1) and (3)).^[1]

The conformity route is light by default. Implementing measures leave manufacturers the choice between internal design control (Annex IV) and a management system (Annex V), and specify other modules only where duly justified and proportionate to the risk (Article 8(2)). Regulation (EU) 2019/1782 on external power supplies is a typical example: it applies from 1 April 2020, sets limits and information requirements in Annex II, and names the technical documentation content for the conformity assessment (Articles 3, 4 and 9). Regulation (EU) 2025/2052, adopted under the same directive, repeals it from 14 December 2028 (Articles 8 and 10).^[1][3][5]

The paperwork must last. The documents relating to the conformity assessment and the declarations are kept available for 10 years after the last of the product has been manufactured and provided within 10 days of a request (Article 8(3)), in an official language of the Union (Article 8(4)). Where the manufacturer is outside the Union and has no authorised representative, the importer ensures compliance and keeps and makes available the declaration and the technical documentation (Article 4). Regulation (EU) 2019/1020 adds that, for products under the directive, an economic operator established in the Union must be responsible and named on the product, its packaging, the parcel or an accompanying document (Article 4(1), (4) and (5)).^[1][4]

Regulation (EU) 2024/1781 replaced the framework, not the measures. It repealed the directive from 18 July 2024, but key provisions, including those on CE marking, declaration and conformity assessment, continue to apply to products regulated by implementing measures until those measures are repealed or declared obsolete (Article 79(1)(b)), and its own market surveillance articles already apply to them (Article 79(2)). New requirements come by delegated act and normally apply no earlier than 18 months after their entry into force (Article 4(4)); the first could not enter into force before 19 July 2025 (Article 4(7)).^[2]