Skip to main content

Launch compliance

What a battery-powered handheld with WiFi/Bluetooth needs before it can be sold in Italy and the EU. Costs and lead times are estimates until a lab quote replaces them in scripts/business/costs.yaml.

Status (2026-10-15)

Nothing started. Costs below are estimates. The list comes from the EU regulations named in each row. A notified test lab confirms which standards apply to the final product.

Product (CE marking)​

ObligationRuleWhat it means for usDone
Radio equipmentRED 2014/53/EUThe ESP32-S3 module is pre-certified, but the finished console is a new radio product and needs its own assessment: radio (EN 300 328, partly covered by the module's reports), EMC (EN 301 489-1/-17), safety (EN 62368-1) and RF exposure (EN 62479). RED covers safety at any voltage, so the Low Voltage Directive does not apply on its own (the battery is far below 75 V DC).☐
Radio cybersecurityRED delegated act 2022/30, EN 18031-1, in force since 1 Aug 2025Applies to a radio device that can reach the internet (our WiFi file server). Self-assessment is allowed only if EN 18031-1 is applied in full and no restriction of Decision (EU) 2025/138 hits us. The one that matters: if the web UI has a password, the user must not be able to skip it. Otherwise a notified body is needed. Espressif supplies pre-filled templates for the chip's part.☐
Hazardous substancesRoHS 2011/65/EUSupplier declarations for the PCBA, display, battery and cables.☐
ChemicalsREACH 1907/2006SVHC declaration from the suppliers.☐
Common chargerDirective (EU) 2022/2380Handheld consoles must charge over USB-C (ours does). Sell without a charger, with the required label.☐
BatteryRegulation (EU) 2023/1542Battery label and CE. User-removable and replaceable from Feb 2027, which affects the enclosure.☐
Battery transportUN 38.3 + MSDSTest summary from the cell supplier, needed by every courier for lithium cells.☐
General safetyGPSR (EU) 2023/988Technical file, a responsible economic operator in the EU, traceability (batch number), user manual and safety warnings in Italian.☐
ToysToy Safety Directive 2009/48/ECNot a toy if it is designed and sold for ages 14+. Marketed to children, it would need EN 71 and EN 62115 tests too. Box, shop and manual say 14+.☐
Declarationall the aboveEU Declaration of Conformity and the CE mark on the product, box and manual.☐

Registrations in Italy​

ObligationRuleWhat it means for usDone
WEEE (RAEE)D.Lgs. 49/2014Register as a producer in the national AEE register (via the Chamber of Commerce) and join a take-back scheme. Crossed-out bin on the product.☐
BatteriesD.Lgs. 188/2008 and Reg. 2023/1542Register as a battery producer (the battery is placed on the market inside the console) and join a scheme.☐
PackagingCONAI, D.Lgs. 152/2006Join CONAI and add environmental labelling on the box.☐
Consumer lawCodice del Consumo14-day withdrawal right, 2-year legal guarantee, pre-contract information on the shop.☐

What it costs​

Estimates until two lab quotes replace them in scripts/business/costs.yaml (one_off, kind: compliance). The registration fees are the Chamber of Commerce figures.

ItemLab in Italy / EU (EUR)RangeLab in China (EUR)Without WiFi in the firmware
Pre-compliance scan800500-1 000200same
EMC + radio tests4 0003 000-6 0001 200same
RF exposure (EN 62479)500300-800200same
Safety report (EN 62368-1)2 5001 500-3 500700same
Cybersecurity (EN 18031-1, self-assessment)1 500+3 000-8 000 with a notified body8000, if the lab confirms it does not apply
RoHS / REACH300supplier declarations, spot XRF150same
Samples shipped to the lab0100same
RAEE + battery registers (Italy)23046 + 184, once230same
Declaration, technical file, Italian manual, labels500our work + translation500same
Total~10 300~7 000 to ~22 000~4 100Italy ~8 800, China ~3 300

The China column is a rough estimate from the price gap between EU and Chinese labs; only quotes make it real. The model uses the Italy/EU column. Registrations and the technical file cost the same wherever the tests are done, because they are Italian obligations and our own work.

Every year after that: the WEEE and battery take-back scheme, CONAI and product liability insurance (monthly_fixed).

What keeps it low:

  • The module's own radio reports cover most of EN 300 328.
  • The cell supplier provides the cell's EN 62133-2 and UN 38.3 reports.
  • The pre-compliance day finds problems before the paid test.
  • A web UI whose password cannot be skipped avoids the notified body.
  • The test happens once the design is frozen. Changing the PCB, the display or the battery afterwards means retesting.

Spreading the cost. The reports cover one hardware design, so the cost is spread over the units of that design:

  • About 12 EUR per console over 850 units (pessimistic case, three years).
  • About 5 EUR per console over 2 200 units (base case).
  • One CE file covers the whole EU: selling outside Italy spreads it further.

In the books, the ordinary regime and the SRL deduct it over up to 5 years (one_off_amortization_years, chosen with the commercialista). The forfettario deducts nothing. Per-scenario figures: Business plan.

When, and how to pay less​

Before the first sale. CE marking is due before the first unit is placed on the market in Italy, even a single one. There is no grace period and no way to spread the testing over the years. What can be spread:

  • In the books: the ordinary regime and the SRL deduct the cost over up to 5 years (see above).
  • With customers' money: pre-orders or crowdfunding can be collected before testing and pay for it. The consoles ship only after the CE marking.
  • Before CE: a prototype can be shown at fairs and events marked "not for sale". It can be sold as a development kit to professionals for research, never to consumers.
  • After CE: the reports hold until the hardware changes. A new PCB, or a different display or battery model, means testing again, at least in part. Certify the final revision.

Lowering the cost on the current hardware:

  1. Self-declaration (Module A). No notified body is needed: the manufacturer applies the harmonised standards and keeps the evidence in the technical file. The law asks for conformity and proof of it, not for an accredited lab. In practice radio and EMC still need lab equipment.
  2. A lab in China. Many test to the EU standards for 1 500-3 000 EUR in total, against 7 000-10 000 EUR in Europe. The report is valid if the standards are the right ones. Choose a lab accredited to ISO 17025; the responsibility stays ours.
  3. The module's reports. Espressif's ESP32-S3 module reports cover most of the radio part, but only when the module is fitted as Espressif requires: antenna clear of copper. The current board breaks that rule (copper under the antenna, the same cause as the weak WiFi), so the next revision should fix it before testing.
  4. Pre-checks at home. A near-field probe and an SDR receiver (100-200 EUR) find emissions before the paid test, so it runs once.
  5. No WiFi in the firmware we sell. Without the file server and network updates, the console probably cannot reach the internet. EN 18031 then no longer applies, which saves 1 500 EUR or more. Get the lab's written confirmation. The radio tests stay, because the radio is in the chip.

With these steps the S3 console's certification is about 3 000-5 000 EUR instead of about 10 000.

Radio turned off is still radio equipment. RED looks at the hardware. WiFi and Bluetooth are inside the ESP32-S3, firmware can switch them back on, and ours is open: anyone can flash Retro-go with WiFi on. The S3 has no fuse that removes the radio for good. Turning the radio off saves the cybersecurity part only.

No radio chip. Only a processor without a radio takes the product out of RED. Then it needs EMC, RoHS, the battery rules, GPSR and the registrations, but no radio, RF exposure or cybersecurity tests:

ESP32-S3 (today)No radio (e.g. ESP32-P4 alone)
DirectiveREDEMC + general safety
Radio, RF exposure, EN 18031 testsneedednot needed
Certification, EU lab~10 000 EUR~4 000-5 000 EUR
Certification, lab in China~3 000-5 000 EUR~1 500-2 500 EUR

The price: no WiFi file transfer, no network updates, no Bluetooth pads. USB and the SD card take their place. It also means a new board and a firmware port, see Plan A: no radio chip.

What can be done in China​

TaskIn China?Why
Radio, EMC, safety, RF exposure testsyesA test report is valid in the EU when it applies the EU harmonised standards. Check the lab's ISO 17025 accreditation (CNAS, in the ILAC scheme) and that the report number can be verified with the lab.
Battery UN 38.3, EN 62133-2, MSDSyesThey come from the cell supplier.
RoHS / REACH declarations, XRFyesFrom the suppliers, or from the same lab.
Production, assembly, final test, boxyesJLCPCB or an assembler can ship finished consoles (HS 9504.50, 0% duty, 22% import VAT).
Labels and manualyes, written by usPrinted there, in Italian, with our name and address.
EU Declaration of Conformity, CE markingnoWe sign it: whoever sells under their own name is the manufacturer, even when JLCPCB builds the board.
Technical filenoWe keep it for 10 years and hand it to market surveillance on request.
Economic operator in the EUnoGPSR and Reg. (EU) 2019/1020 need one in the EU: us, as the importer.
RAEE, battery, CONAI registrationsnoItalian registers, through the Chamber of Commerce. In every other EU country with direct sales: its own WEEE and battery registration, often through a paid local representative.
Company, VAT, trademarknoItaly and EUIPO.

Watch out for "CE certificates". Many Chinese suppliers sell a "CE certificate" from a body that is not notified. It has no legal value. What counts is the test report and our Declaration of Conformity.

Content and brand​

  • No ROMs or BIOS in the firmware, on the bundled SD card or in downloads. Only free or licensed titles may be bundled, under their own licences (Freedoom, OpenTyrian).
  • Name and art. The name, logo and photos must not use console makers' trademarks or game art. Register our own mark (EUIPO, one class about 850 EUR).
  • Software licences. Retro-Go is GPLv2, and so are several of its cores. Selling the console means shipping the source, or a written offer for it, for the firmware we distribute. Some cores (Snes9x, MAME 0.37 for CPS1/Neo Geo, Musashi 3, fMSX, Wolf3D, the N64 ports) forbid commercial use and must be removed or replaced first: see Software licences.

Order of work​

  1. Freeze the hardware revision that will be sold. Every change after testing means retesting.
  2. Get quotes from two labs (RED + EN 18031 + safety). Write the cheapest complete one into costs.yaml as real.
  3. Make the firmware changes EN 18031 needs, before testing.
  4. Do the registrations (WEEE, batteries, CONAI) once the company exists, before the first sale.