What is the difference between CE and FCC, and where does RoHS fit in?
CE is a conformity assessment regime for the European Union market and, for radio equipment, is carried out under RED 2014/53/EU. Its counterpart in the USA is 47 CFR Part 15 and it generally works as a device approval or identifier (FCC ID) regime. RoHS 2011/65/EU is a separate directive; it regulates the restriction of hazardous substances and does not take the place of RED.
The most common mistake is assuming that a CE-marked device is automatically legal in the USA, and a device with an FCC ID automatically legal in Europe. That is not true. The two regimes use different technical limits, different measurement methods and different documentation processes.
The main differences:
- Approach: under CE, conformity assessment is largely the manufacturer's responsibility and is declared with an EU Declaration of Conformity. On the FCC side radio devices generally receive an identifier at the end of an approval process.
- Reference documents: in Europe, harmonised ETSI standards (for example the EN 300 220 series for sub-GHz, EN 300 328 V2.2.2 for 2.4 GHz, the EN 301 489 series for EMC); in the USA, the 47 CFR Part 15 rules.
- Marking: the CE mark with a letter height of at least 5 mm; on the FCC side, showing the device identifier on the label.
RoHS is an entirely different matter: it regulates the restriction on the use of hazardous substances such as lead, cadmium and mercury. RED and RoHS are separate directives but both are declared under the same CE mark. The fact that a product bears the CE mark does not automatically tell you which directives it was declared against; that information is written in the declaration of conformity.
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