EU ErP New Rule EC 2023/826: Standby Power for Small Appliances and Electronics — An Invisible Barrier for EU Exports
1. What exactly does this regulation govern?
Don't be fooled by the words "standby power" — it governs far more than just the "standby" state.
The new regulation (EU) 2023/826 covers a very wide range of products:
| Product Class | Typical Examples | Covered? |
|---|---|---|
| Small home appliances | Coffee machines, electric kettles, air purifiers | ✅ Covered |
| IT equipment | Routers, printers, set-top boxes (except desktops, laptops) | ✅ Covered |
| Consumer entertainment electronics | Speakers, game consoles, TV boxes | ✅ Covered |
| Electric furniture & home improvement | Electric standing desks, electric curtains, smart locks | ✅ Covered |
The core requirement is: equipment must have power-management functionality and meet the energy requirements in the off, standby and network-standby modes.
What does this mean? Your product can't "dumb-wait" — keep drawing power while it's plugged in. It has to automatically enter a low-power state, and once there, the consumption has to be within the limits.
2. Why is it called an "invisible barrier"?
Because many companies are still designing to the old rule (EC) 1275/2008.
The old rule has been around for more than a decade, and a lot of engineers can recite the limits with their eyes closed. But the new rule (EU) 2023/826 tightens both the limits and the requirements, so old experience is directly voided.
What's even more critical: the ErP directive is a mandatory requirement of the CE mark. It's a component of CE, just like LVD (Low Voltage Directive) and EMC (Electromagnetic Compatibility Directive). If ErP fails, you don't get CE, and the product can't enter the EU.
Many companies think CE is simply safety and EMC, completely unaware that ErP is another hard gate. By the time the goods are held at customs, far more than just the certification fee has been lost.
3. Pitfalls that sink you the moment you hit them
Pitfall 1: Thinking "has power management" is enoughThe regulation requires "has power-management functionality", but many companies read it as "has an energy-saving mode switch". Wrong. The function must be automatic — it can't depend on the user setting it manually. The product must enter the low-power state automatically within the specified time.
Pitfall 2: Only testing off mode, ignoring network standbyMany products with WiFi/Bluetooth keep networking in the background even when they appear "off". Network standby has different and stricter power limits than ordinary standby. If you only test ordinary standby and the network standby exceeds, it's still non-compliant.
Pitfall 3: Using old-regulation test reports to make up the numbersThe new rule (EU) 2023/826 has replaced (EC) 1275/2008 and (EC) 107/2009, so old reports can no longer be used. Some companies try to clear customs with reports from years ago and get rejected outright. Testing has to be redone to the new rule.
Pitfall 4: Ignoring "electric furniture & home-improvement equipment"This is a newly added category, and many companies making electric standing desks and electric curtains never realized they're now regulated. They panic only when the notice arrives, and redesigning is both time-consuming and costly.
4. Your 5-step checklist right now
Since enforcement has already been in effect for a while, if you haven't acted yet, catch up with this list:
| Step | Action | Description |
|---|---|---|
| 1 | Confirm whether the product is in scope | Compare against the regulation's coverage list to confirm whether your product is regulated |
| 2 | Check whether the existing design meets the new limits | Focus on consumption in the off, standby and network-standby modes |
| 3 | Check whether the power-management function is automatic | Can't rely on user manual settings; it must enter low-power automatically |
| 4 | Redo ErP testing to the new regulation | Use an accredited lab to issue a report under (EU) 2023/826 |
| 5 | Update technical documentation and the CE declaration | Include the new test report in the technical file to keep the CE mark compliant |
5. Final thoughts
The ErP standby power issue — it's neither huge nor tiny. It doesn't involve personal safety the way safety regulations do, but it is a hard condition for EU market access. Many companies trip up not because they can't do it, but because they don't know about it.
Now that the new rule is in force, if you're still designing with old thinking, adjust quickly. If you already have the new report, don't forget to review it periodically — the regulation requires continuous compliance, not a one-off.
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