Importing 12-volt and cordless boat vacuums from China: the CE file explained

A 12-volt or cordless wet/dry boat vacuum needs CE marking under the European Union (EU) electromagnetic compatibility (EMC) Directive and the restriction of hazardous substances (RoHS) Directive, it may also fall under the EU machinery rules, and it brings battery and waste electrical and electronic equipment (WEEE) recycling duties; the Low Voltage Directive (LVD) applies only to its mains charger or to a mains-powered model. When the vacuum carries your brand, EU law treats you as its manufacturer, so the technical file and the EU declaration of conformity must exist in your company’s name before the first unit is sold.

CE marking is the manufacturer’s statement that a product meets the EU laws that require the mark. This page is general information for buyers. It is not legal advice.

Which EU laws apply to a 12 V or battery wet/dry vacuum

The Commission’s LVD Guide confirms that battery equipment below the voltage range is outside the LVD while its mains charger is inside. A 230 V shop vacuum for marinas falls under the Machinery Directive, because the Guide places appliances intended for commercial use there. On ecodesign, the Commission’s energy efficient products page says cordless vacuums are currently not regulated and points to an ongoing review. Of the GPSR, the rules on online listings (Article 19) and accident reporting (Article 20) still apply to CE-marked products.

What the legal texts say about machinery rules and a 12-volt vacuum

The Machinery Directive excludes household appliances intended for domestic use “insofar as they are covered by” the low voltage legislation (Article 1(2)(k)). Regulation (EU) 2023/1230 excludes household appliances intended for domestic use “insofar as they fall within the scope of” the LVD or of the Radio Equipment Directive 2014/53/EU (Article 2(2)(p)). The LVD covers equipment rated between 50 and 1,000 V AC and between 75 and 1,500 V DC (Article 1), and the LVD Guide states that battery-operated equipment outside that range is outside the LVD. The Commission’s Machinery Directive guide names vacuum cleaners as household appliances at §64, and states there that appliances for these housekeeping functions intended for commercial or industrial use are not excluded from the Machinery Directive. The same paragraph says the intended use stated by the manufacturer in its product information or declaration of conformity is the test.

None of these texts, and no Commission guidance we found, says in so many words how a 12 V or battery household vacuum is classified. A test laboratory or a notified body, an independent assessor designated by a member state, confirms which acts apply to your specific model.

Timing matters this winter. The Regulation replaces the Directive on 20 January 2027. Units placed on the market under the Directive before then may still be sold (Article 52 of the Regulation). If the machinery rules apply to your model, anything placed on the market from that date needs a declaration under the Regulation, and a container ordered in November can land after it.

Battery rules under the Batteries Regulation

A “producer” includes anyone supplying batteries under its own name or trade mark, including batteries built into appliances. With your brand on a cordless vacuum, that is you. Key dates:

Article 11(2)(a) lets washable appliances built to work mainly around splashing water, water streams or immersion have a battery that only independent professionals can remove and replace, where the safety of the user and the appliance requires it. Ask the lab before assuming a wet vacuum qualifies. The battery itself carries CE marking (Article 20).

WEEE registration and marking

Under the WEEE Directive, a producer is any company established in a member state that sells equipment under its own name or trade mark there, or imports it on a professional basis. Producers register in each member state’s national register (Article 16) and mark products with the crossed-out wheeled bin symbol, preferably to European standard EN 50419 (Article 14(4)).

What the technical file and declaration of conformity contain

The technical file is the evidence that the product meets each law. Under the EMC Directive (Annex II) and the Machinery Directive (Annex VII) it holds a general description; drawings and circuit diagrams with explanations; the harmonised standards applied, meaning European standards whose use presumes conformity, and how other requirements were met; calculations and test reports; a risk assessment with the protective measures taken; the user instructions; and declarations for bought-in parts such as the charger. The LVD Guide lists EN 60335-2-2 for vacuum cleaners and water-suction appliances, EN 60335-2-69 for commercial wet and dry vacuums and EN 60335-2-29 for battery chargers. In the Official Journal, EN 60335-2-2:2010 and EN 60335-2-29:2021 are listed under the LVD (Implementing Decision (EU) 2023/2723) and EN 60335-2-69:2012 under the Machinery Directive (Implementing Decision (EU) 2023/1586), each with its listed amendments.

The EU declaration of conformity (DoC) is a signed page. Under Annex IV of the EMC Directive it states the model, the manufacturer’s name and address, that it is issued under the manufacturer’s sole responsibility, the laws met, the standards applied with their dates, any notified body (an independent assessor designated by a member state), and the signatory’s name, function, place and date. The Machinery Directive adds an EU-based person authorised to compile the technical file.

Who is the manufacturer when the vacuum carries your brand

An importer or distributor that places a product on the market under its own name or trade mark takes on the manufacturer’s obligations: LVD Article 10, EMC Article 11 and the manufacturer definition in Article 2(i) of the Machinery Directive. The battery and WEEE producer definitions work the same way.

So the factory’s test reports are your evidence, and the DoC is your document: it names your company, you must be able to produce the technical file for an authority, and the EMC Directive has importers keep the DoC for 10 years. You are also importer of record, since the factory invoices the goods to you. More in the GPSR responsible person for imported cleaning tools.

Customs code and EU duty

TARIC, the EU’s integrated tariff database, gives these codes and rates.

We checked both codes on 12 November 2026; neither showed an anti-dumping duty, an extra duty on goods sold below normal value, for China. Rates and trade measures change: recheck before ordering and have your broker confirm the code. Import value added tax (VAT) comes on top, as explained in our deck brush guide.

Shipping lithium batteries

Lithium batteries must pass the design tests in sub-section 38.3 of the United Nations (UN) Manual of Tests and Criteria, and manufacturers and distributors must make a test summary available, as the Pipeline and Hazardous Materials Safety Administration (PHMSA), the US transport safety regulator, explains. A Transport Canada study found sellers who could not supply one, or whose summary did not match the batteries. Get the summary for your exact pack, and have your freight forwarder confirm dangerous goods documents and labels before booking.

Checklist before you pay a deposit

• EMC test report naming the exact model
• Safety test report to EN 60335-2-2 or EN 60335-2-69, and the charger’s report to EN 60335-2-29
• RoHS test report or material declarations for all ten substances
• The lab’s written view on whether the machinery rules apply to your model; if they do, a machinery risk assessment and a draft DoC under Regulation (EU) 2023/1230 for units placed on the market from 20 January 2027
• UN 38.3 test summary for the battery pack, with cell and pack model numbers matching the sample
• Battery design that lets users remove and replace the pack, for units placed on the market from 18 February 2027
• Draft DoC in your company’s name, and written agreement to hand over the technical file
• Label artwork: your name and addresses, model and batch number, CE mark, crossed-out bin, battery symbols
• Instructions and safety information in each market’s language
• New test reports required if the factory changes motor, cells or charger

Aslan sources boat vacuums from a 700-person vacuum manufacturer we work with directly, and EU compliance is priced into the number. For electrical goods our inspections also check the certification file. Vacuums take longer than non-electrical goods because of the compliance file. The range is on our marine cleaning page.