CE marking changes in 2025 and 2026
The period from late 2024 through 2027 is the busiest legislative cycle for EU product compliance since the New Legislative Framework was adopted in 2008. Several long-standing directives are being replaced by regulations, horizontal safety and sustainability instruments have started to apply, and the AI Act attaches an entirely new layer of requirements to the CE system. This page collects the changes by application date, states which economic operators are affected, and links to the detailed CECheck pages on each act.
Dates below are application dates — the day from which the requirements are enforceable — unless stated otherwise. Entry into force (twenty days after publication in the Official Journal, as a rule) is earlier and generally has no direct effect on manufacturers. The distinction matters for every act in this list; where a transition period allows products under the old rules to continue being placed on the market, that is noted.
Summary table
| Date | Act | What changes | Who is affected |
|---|---|---|---|
| 13 Dec 2024 | GPSR (EU) 2023/988 | Replaces GPSD 2001/95/EC; safety-net duties, EU responsible person, marketplace obligations | All economic operators dealing in consumer products, including online marketplaces |
| 2 Feb 2025 | AI Act (EU) 2024/1689 | Prohibited AI practices and AI-literacy obligations start to apply | Providers and deployers of AI systems |
| Apr 2025 | ESPR (EU) 2024/1781 | First ESPR working plan adopted; priority product groups named for ecodesign and Digital Product Passport rules | Manufacturers in the priority groups (textiles and iron/steel among them) |
| 1 Aug 2025 | RED 2014/53/EU + Delegated Regulation (EU) 2022/30 | Cybersecurity essential requirements under Article 3(3)(d), (e) and (f) become mandatory | Manufacturers of internet-connected radio equipment |
| Aug 2025 | Battery Regulation (EU) 2023/1542 | Supply-chain due diligence obligations start to apply (18 Aug 2025) | Larger economic operators placing batteries on the market |
| 2 Aug 2025 | AI Act (EU) 2024/1689 | Obligations for general-purpose AI models; governance and notified-body chapters apply | GPAI model providers; conformity assessment bodies |
| 1 Jan 2026 | Toy Safety Regulation (EU) 2025/2509 | Regulation enters into force; Digital Product Passport for toys introduced; transition from Directive 2009/48/EC begins | Toy manufacturers, importers, distributors |
| 8 Jan 2026 | CPR (EU) 2024/3110 | New Construction Products Regulation applies (phased), replacing Regulation (EU) No 305/2011 | Construction product manufacturers and their supply chains |
| 2 Aug 2026 | AI Act (EU) 2024/1689 | General application, including Annex III high-risk AI systems | Providers and deployers of standalone high-risk AI |
| 20 Jan 2027 | Machinery Regulation (EU) 2023/1230 | Replaces Machinery Directive 2006/42/EC in full; no transition for old-rule products after this date | Machinery manufacturers, importers, distributors |
| 18 Feb 2027 | Battery Regulation (EU) 2023/1542 | Battery passport required for LMT, EV and larger industrial batteries (Article 77) | Battery manufacturers and importers |
| 2 Aug 2027 | AI Act (EU) 2024/1689 | High-risk rules apply to AI safety components in products under Annex I harmonisation legislation | Manufacturers of machinery, medical devices, toys, lifts, radio equipment and other Annex I products embedding AI |
Applying since December 2024: the GPSR
The General Product Safety Regulation (EU) 2023/988 has applied since 13 December 2024, replacing the General Product Safety Directive 2001/95/EC. It is not a CE marking act — it provides for no conformity assessment procedure and no marking — but it changed the baseline for every consumer product, CE-marked or not. Its most consequential requirements are the obligation to have a responsible economic operator established in the EU for every consumer product sold, extended traceability duties, accident reporting through the Safety Business Gateway, prescriptive recall-notice rules, and direct obligations on online marketplaces. For CE-marked products, GPSR acts as a safety net covering aspects the sectoral act does not.
2025
RED cybersecurity requirements — 1 August 2025
Delegated Regulation (EU) 2022/30 activated the dormant essential requirements of Article 3(3)(d), (e) and (f) of the Radio Equipment Directive 2014/53/EU for internet-connected radio equipment. Since 1 August 2025, in-scope equipment must not harm the network or misuse network resources (3(3)(d)), must protect personal data and privacy (3(3)(e)), and must protect against fraud (3(3)(f)). This affects a very large share of consumer electronics: routers, wearables, connected appliances, toys with wireless connectivity, and most IoT devices. Harmonised standards in the EN 18031 series were developed to support these requirements; where a manufacturer cannot rely on harmonised standards covering the full requirement, involvement of a Notified Body is required under the RED's assessment routes. Technical documentation and the EU Declaration of Conformity for existing products needed updating to cite the delegated regulation.
Battery Regulation — staged application continues
The Battery Regulation (EU) 2023/1542, which brought batteries into the CE marking system, applies its obligations in stages. During 2025 the most significant new layer was supply-chain due diligence: from 18 August 2025, economic operators above the regulation's size threshold must operate a due diligence policy covering raw materials such as cobalt, lithium, natural graphite and nickel, verified by third parties. Requirements on the removability and replaceability of portable batteries follow under the regulation's staged calendar. The battery passport — the first mandatory Digital Product Passport in EU law — applies from 18 February 2027 (see below).
First ESPR working plan — April 2025
The Ecodesign for Sustainable Products Regulation (EU) 2024/1781 is a framework: its concrete obligations arrive through delegated acts per product group. In April 2025 the Commission adopted the first working plan, naming the priority product groups for which ecodesign requirements and the Digital Product Passport will be developed first — textiles and iron/steel are among the priorities. The working plan itself imposes no obligations; it signals where delegated acts, and therefore DPP duties, will land first.
AI Act — prohibitions and GPAI
The AI Act (EU) 2024/1689 entered into force on 1 August 2024. Its prohibitions on certain AI practices, together with AI-literacy obligations, have applied since 2 February 2025. Obligations for general-purpose AI models, and the chapters on governance and notified bodies, applied from 2 August 2025. Neither milestone directly touched CE marking; the CE-relevant provisions arrive in 2026 and 2027.
2026
Toy Safety Regulation (EU) 2025/2509 — in force 1 January 2026
The Toy Safety Regulation (EU) 2025/2509 entered into force on 1 January 2026, beginning the replacement of Directive 2009/48/EC. Its headline changes are stricter chemical rules (including endocrine-disruptor restrictions), reinforced obligations for online sales, and the introduction of a Digital Product Passport for toys, which takes over the function of the paper Declaration of Conformity in that sector. The regulation provides a transition period during which toys compliant with Directive 2009/48/EC may still be placed on the market; manufacturers should treat the transition as preparation time for the DPP infrastructure rather than as a postponement. The exact end dates of the transitional windows should be checked against the regulation's final provisions on EUR-Lex.
Construction Products Regulation (EU) 2024/3110 — from 8 January 2026
The new Construction Products Regulation (EU) 2024/3110 applies from 8 January 2026 on a phased basis, progressively replacing Regulation (EU) No 305/2011. The CPR retains its distinctive structure — CE marking based on a Declaration of Performance rather than a Declaration of Conformity — and adds environmental performance declarations, digital documentation designed to connect with the Digital Product Passport framework, and reworked harmonised technical specifications. Because the old CPR's standards remain usable during long transitional periods for each product family, construction product manufacturers face a decade-scale migration rather than a single switchover date.
AI Act — general application 2 August 2026
From 2 August 2026 the AI Act applies generally. For the CE system, the significant part is that standalone high-risk AI systems listed in Annex III must complete conformity assessment and carry CE marking under Article 48. The obligations for AI embedded as a safety component in products covered by Annex I harmonisation legislation — machinery, medical devices, toys, lifts, radio equipment, and others — follow one year later, on 2 August 2027. The mechanics are covered in the AI Act and CE marking.
2027 outlook
Machinery Regulation (EU) 2023/1230 — 20 January 2027
The Machinery Regulation (EU) 2023/1230 applies from 20 January 2027, replacing Directive 2006/42/EC with no general transition for old-rule products: machinery placed on the market from that date must comply with the regulation. Provisions concerning notified bodies have been in force since January 2024 so that bodies could be designated in advance. The regulation extends scope into software safety, AI-driven safety functions, and cybersecurity affecting safety, and introduces mandatory third-party assessment for six categories of high-risk machinery listed in Annex I Part A. Manufacturers with machinery in continuous production should plan their documentation and assessment migration during 2026.
Battery passport — 18 February 2027
Under Article 77 of the Battery Regulation, LMT batteries, electric vehicle batteries and industrial batteries above 2 kWh placed on the market from 18 February 2027 must have an electronic battery passport accessible via a data carrier on the battery. This is the first operational Digital Product Passport and the model for the ESPR-based passports that follow; see the Digital Product Passport.
AI Act Annex I high-risk — 2 August 2027
From 2 August 2027, AI systems that are safety components of products under the harmonisation legislation listed in Annex I of the AI Act, where that legislation requires third-party conformity assessment, are treated as high-risk. In practice, the AI Act's requirements will then be checked within the sectoral conformity assessment — a single procedure where the sectoral act permits it — affecting medical devices, machinery, lifts, toys and other Annex I sectors that embed AI.
The United Kingdom position
Against this background of EU change, the UK has moved the other way: Great Britain recognises CE marking indefinitely for 21 product regulations, with UKCA remaining an optional alternative in those categories. Divergence risk now runs primarily through the EU updating its acts (as above) while the corresponding GB rules stand still; a product compliant with a new EU regulation is not automatically compliant with the older GB rules it mirrors, and vice versa. See CE marking vs UKCA.
What unaffected manufacturers should still do
- Re-check scope annually: the applicable-legislation analysis done at product launch goes stale as acts are replaced.
- Re-date and re-verify the technical documentation whenever a cited act or harmonised standard is superseded.
- Watch the Official Journal for harmonised standard citations under the new acts — the presumption of conformity travels with the citation, not with the standard's publication by CEN or CENELEC.
- Confirm which conformity assessment module applies under the replacing act; several of the new regulations move product categories between modules.
Sources
- Regulation (EU) 2023/988 of the European Parliament and of the Council of 10 May 2023 on general product safety — EUR-Lex.
- Regulation (EU) 2023/1230 of the European Parliament and of the Council of 14 June 2023 on machinery — EUR-Lex.
- Regulation (EU) 2024/3110 of the European Parliament and of the Council laying down harmonised rules for the marketing of construction products — EUR-Lex.
- Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries — EUR-Lex.
- Regulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products — EUR-Lex.
- Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence — EUR-Lex.
- Commission Delegated Regulation (EU) 2022/30 supplementing Directive 2014/53/EU with regard to the essential requirements referred to in Article 3(3)(d), (e) and (f) — EUR-Lex.