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# CE Marking for Accessories and Spare Parts

CE marking requirements for accessories and spare parts depend almost entirely on two questions: is the item placed on the market independently, and does it contain active electronics? A passive plastic case needs no CE marking; a case with wireless charging circuitry does. A like-for-like spare part is fine; one that changes the product's compliance envelope is not.

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At a glance

Accessory/spare part scenarios

5

High-risk changes triggering reassessment

6

FAQs

4

## CE marking requirement by scenario

### Accessory placed on market independently

CE required

Any accessory sold as a standalone product on the EU market must be CE marked under applicable directives. A power supply sold separately from the device needs its own LVD and EMC CE marking. A separate charging cable with a USB-C connector needs RoHS and potentially LVD compliance.

### Accessory bundled with the main product

No CE needed

When an accessory is sold only as part of a system and covered by the main product's technical documentation and DoC, it does not need independent CE marking. The system-level CE assessment covers the accessory. The key is whether the accessory is 'placed on the market' separately.

### Third-party accessory for a CE-marked product

CE required

Third-party manufacturers who make accessories (cases, chargers, docks, replacement batteries) for existing CE-marked products are fully responsible for their own products' CE compliance. They cannot reference the original device manufacturer's CE marking.

### Replacement spare part that restores original function

No CE needed

Spare parts that replace failed components and restore the product to its original CE-compliant specification do not require a new CE assessment if they are identical or equivalent to the original parts. The original CE marking remains valid.

### Upgrade or enhanced spare part that changes function

CE required

If a spare part changes the product's performance, adds new functionality, or potentially introduces new hazards not covered in the original CE assessment, it constitutes a substantial modification. The manufacturer must assess whether a new CE evaluation is needed.

## Changes that typically trigger CE reassessment

Replacing a wired module with a wireless radio module — introduces RED scope where none existed

Installing a higher-capacity battery or different battery chemistry — affects LVD thermal testing, battery safety, and potentially transport regulations

Changing the mains power supply to a higher wattage unit — affects LVD electrical safety assessment for the new power level

Adding an antenna to an existing product that did not previously have intentional radio transmission

Replacing a plastic enclosure with a metal one that changes RF shielding characteristics

Installing third-party firmware that changes radio transmission parameters (power, frequency, protocol)

## Frequently asked questions

### Do USB cables need CE marking?

USB cables that carry only data and power at low voltage (USB 2.0, USB 3.x) are generally simple cables — they contain no active electronics and are not within the scope of LVD (below 50V AC/75V DC), EMC, or RED. They may be subject to RoHS if they contain electronic components. However, USB Power Delivery (PD) cables with active chips (e-marker cables for 100W+) contain electronic components and may fall within RoHS scope. Always check whether your cable contains any active circuitry.

### Can I sell third-party batteries for CE-marked devices?

Yes, but the third-party battery must be CE marked under applicable regulations. Lithium-ion batteries are subject to the Battery Regulation (EU) 2023/1542 and relevant safety standards (IEC 62133 for portable rechargeable batteries). If the battery is packaged with a charging circuit (a battery pack with electronics), LVD and EMC may also apply. The third-party battery manufacturer cannot rely on the original device manufacturer's CE marking.

### Does modifying a CE-marked product void its CE marking?

Not automatically — but substantial modifications require reassessment. The EU Blue Guide defines substantial modification as a modification that may affect compliance with applicable essential requirements or changes the intended use in a way not foreseen in the original assessment. The entity making the modification is responsible for determining whether a new CE assessment is needed. If they are selling the modified product, they may become the manufacturer for the modified product.

### Are phone cases and protective covers considered accessories needing CE marking?

A passive phone case with no electronics — just plastic or fabric materials — does not fall under any CE directive scope (no radio, no electronics, not mains powered). It may be subject to GPSR for general consumer safety. If the case incorporates active electronics (battery, wireless charging receiver, NFC, MagSafe alignment magnets with electronics), those electronic components bring the case into CE scope.

**Disclaimer:** Educational resource only. Substantial modification assessment is product-specific and directive-specific. When in doubt about whether a modification requires a new CE assessment, consult a qualified compliance engineer.

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