E-label vs physical label: rules by jurisdiction

Hugues Orgitello updated 7 Oct 2026 15 min read

An e-label is the regulatory label shown on a screen instead of printed on the enclosure. For a coin-sized BLE sensor or a thin industrial module, room for an FCC ID, an ISED number, a CE marking, a Giteki mark, a KC identifier and a CCC mark is a mechanical constraint in its own right. Each regulator answers differently, and the answers have moved: Canada rewrote its rules in RSS-Gen Issue 6 (July 30, 2026), Australia remade its telecommunications labelling notice in 2025, China has allowed an electronic CCC mark since January 1, 2024, and the EU is negotiating digital declarations and instructions while keeping the CE marking physical. This page reads each text directly, as of October 7, 2026: who may use an e-label, how many steps are allowed, what must still be printed on the packaging, and where a QR code counts.

The rules side by side

Jurisdiction	Text	Who may use an e-label	Access limit	Still required physically	QR code as the label
United States (FCC)	47 CFR 2.935	Device with an integrated display, or a device that can only operate with a device that has one	No more than 3 steps from the settings menu, no special codes, accessories or permissions	FCC ID or other identifying information on the device or packaging, for import and sale (2.935(f))	Not provided for
Canada (ISED)	RSS-Gen Issue 6, section 9.4.1 and Annex B	Device with an integrated display; without one, an audio message or the screen of external equipment that is mandatory for use	No more than 3 steps from the main menu, no special access codes or accessories (B.2.2)	Physical label on the packaging at importation, distribution and sale (B.3)	Yes, on the product, if the code contains the label itself and not a link (9.4.2); e-labelling is then not used
Australia (ACMA, radio)	Equipment Rules 2021, Schedule 3, clauses 5 and 6	Device with a built-in display	None set; displaying the RCM must be difficult or impossible to prevent	None stated for the e-label	Yes, if the linked web page displays the RCM prominently (clause 5(1)(b) and (8))
Australia (ACMA, EMC)	EMC Labelling Notice 2017, section 3.6A	Device with a built-in display	None set	None stated for the e-label	Not in section 3.6A
Australia (ACMA, telecom)	Telecommunications Labelling Notice 2025, sections 12 and 14	Customer equipment with a built-in display	None set	None stated for the e-label	Yes, if the link leads to a web page that displays the RCM prominently (section 12(1)(b))
Japan (MIC)	Certification ordinance (MPT Ordinance No. 37 of 1981), Article 8	Equipment screen, or the screen of a product connected by wire before first use	None set; display must be immediate and clear after a specific operation	A document (or other appropriate means) explaining that the mark is electronic and how to display it (Article 8(3))	Not one of the three methods of Article 8
South Korea (MSIT, RRA)	RRA Notice 2026-4, Annex 5	Any equipment: display not removable by the user, or QR code	No more than 3 menu steps, protected against modification by users	KC mark and model name on the equipment or packaging, per Annex 5	Yes
China (CNCA, CCC)	CCC Mark Management Requirements, CNCA Announcement 2023 No. 12	Product with an integrated screen (the product cannot work with the screen removed) and an electronic nameplate	None set; the manual must give the path to the mark	Standard or printed CCC mark on the smallest sales package	Not provided for
European Union (CE)	RED 2014/53/EU, Article 20; Regulation 765/2008, Article 30	Nobody	Not applicable	CE marking on the equipment or its data plate, and on the packaging	No
Great Britain (UKCA or CE)	Product legislation by sector (GOV.UK marking table)	No electronic marking in the rules listed	Not applicable	UKCA or CE (radio equipment), CE or UKNI and CE in Northern Ireland	No

United States: E-LABEL Act and 47 CFR 2.935

The Enhance Labeling, Accessing, and Branding of Electronic Licenses Act (E-LABEL Act) is Public Law 113-197, signed on November 26, 2014 (Senate bill S. 2583). It added section 720 to the Communications Act and gave the FCC nine months to "promulgate regulations or take other appropriate action" so that manufacturers of radiofrequency devices with a display have the option of electronic labeling. The current rule, 47 CFR 2.935, dates from the SDoC order of November 2, 2017 (82 FR 50827). OET guidance is in KDB 784748.

Paragraph	What 2.935 requires
(a)	Applies to a device with an integrated electronic display screen, or to a device without one that "can only operate in conjunction with" a device that has a screen. It may show the FCC ID, warning statements or any other information otherwise required on a physical label
(b)	The information must be readily accessible. Prominent instructions on how to reach it go in the operating instructions, packaging inserts or another easily accessible format at purchase. They may be on the product website, if the packaging says how to find it and a copy goes into the certification application
(c)	No special codes, accessories or permissions, and no more than three steps from the device settings menu. Screen locks and passcodes that control overall access do not count as steps
(d)	Clearly legible without magnification
(e)	Programmed by the responsible party and secured so that third parties cannot modify it
(f)	The device or its packaging must still carry the FCC ID or other information (for example a model number and a web page with the regulatory information) that identifies it at importation, marketing and sale. A stick-on label, printing on the packaging or a label on a protective bag are acceptable; a removable label must survive shipping and be removed only by the customer after purchase

See the FCC pillar for the broader US framework and the FCC procedure for where labeling sits in the authorization steps.

Canada: RSS-Gen Issue 6, Annex B

RSS-Gen Issue 6 is dated July 30, 2026, and Amendment 1 (September 15, 2026) changed only section 7.5. Its change list says it "streamlined the labelling requirements allowing QR code labelling", allowed the label in the user manual or packaging for very small devices, and "clarified the electronic labelling requirements" in Annex B.

Section 9.4.1 says each unit must bear a label that is permanently affixed "or displayed electronically (e-labelling) as per annex B". The label content (section 9.4.4.1) is the ISED certification number preceded by "IC:", the HVIN, and, unless it is in the packaging or literature, the PMN. What is shown, including on a screen, must match the Radio Equipment List.

Annex B clause	Requirement
B.1	Integrated display: label may be electronic. No display: an audio message, or the display (or audio) of external equipment connected by cable, Bluetooth or Wi-Fi when that connection is mandatory for use. An audio message must be bilingual English and French
B.1 (modules)	A host may show a module certification number if the module authenticates itself over a secure interface, or if the host manufacturer factory-encodes and locks the number
B.2.1	Access instructions in the user manual, operating instructions or packaging, or on a product website reachable from the packaging, kept online for as long as the product is made or sold in Canada
B.2.2	No special access codes (other than the user login to the product controls) or accessories such as SIM cards; no more than three steps from the product main menu
B.3	A physical label on the product packaging at importation, distribution, offer for sale and sale; a removable label is acceptable if it survives handling and is removed only by the end user
B.4	Programmed by the responsible party and not modifiable or removable by the typical user

Required user manual notices must be in English and French (section 9.3.1), and they may also be displayed electronically under Annex B. When both the label and the manual notices are on screen, they must be clearly differentiated. See ISED Canada for the certification route.

Australia: three instruments, one RCM

The RCM can come from three labelling regimes, and all three now allow a built-in display.

• Radiocommunications: Radiocommunications Equipment (General) Rules 2021, Schedule 3. Clause 5(1) accepts as the label either the RCM or "a QR code, or similar thing" if the linked web page displays the RCM prominently (clause 5(8)). Clause 6 treats a device with a built-in display as compliant if the display can show the RCM when first offered for supply and at all later times, the accompanying documentation explains how, and it is "difficult or impossible to prevent" the RCM from being displayed.
• EMC: Radiocommunications Labelling (Electromagnetic Compatibility) Notice 2017, section 3.6A, with the same three conditions.
• Telecommunications: Telecommunications Labelling Notice 2025, in force since March 31, 2025. Section 12 accepts the RCM or a QR code that links to a web page displaying the RCM prominently. Section 14 allows the built-in display if the display method is in the accompanying documentation or published prominently on the manufacturer or importer website, and is hard to prevent. Items labelled under the 2015 notice within two years of commencement do not need relabelling.

A "built-in display" is integral to the item and cannot be used independently of it, so a phone app does not qualify. Record keeping differs: the Equipment Rules and the EMC notice keep compliance records for 5 years after first supply, the 2025 telecommunications notice until two years after the item ceases to be supplied. See ACMA and RCM and, for cellular devices, Telstra acceptance.

Japan: Article 8 of the certification ordinance

Article 8(1) of the ordinance on technical regulations conformity certification (MPT Ordinance No. 37 of 1981) allows three ways to show the Giteki mark: physical marking; storing the mark electronically and displaying it "immediately and clearly" on the equipment screen through a specific operation; or displaying it on the screen of a connected product, but only through a wired connection made before the equipment is first put into operation. For the two electronic options, a document supplied with the product (or another appropriate means) must say that the mark is electronic and how to display it (Article 8(3)). The same options apply to a host product repeating a module mark (Article 8(2)).

The ordinance sets no list of product categories and no step count. Details in TELEC and Giteki.

South Korea: Annex 5 of RRA Notice 2026-4

Labelling of radio and EMC equipment is in Annex 5 of RRA Notice 2026-4, issued by the National Radio Research Agency under the Ministry of Science and ICT. E-labelling is allowed for any equipment, by a display that the user cannot remove or by a QR code, reachable in no more than three menu steps and protected against modification by users. The KC mark and the model name stay on the equipment or packaging. Details in KC South Korea.

China: the electronic CCC mark since 2024

CNCA Announcement 2023 No. 12 (published August 10, 2023, in force January 1, 2024) replaced the 2018 marking rules with the CCC Mark Management Requirements. They define three kinds of CCC mark: the standard-format mark, the printed or moulded mark, and the electronically displayed CCC mark (电子标注CCC标志). The electronic mark:

• is allowed only for products with an integrated screen (one whose removal stops the product working normally) that use an electronic nameplate;
• must be clear, complete and distinct, with colour and size adapted to the screen;
• requires the manual or other accompanying documents to give the path to display it;
• does not remove the packaging marking: the smallest sales package must carry a standard-format or printed CCC mark.

The same announcement made CCC certificates electronic by default. Radio type approval (SRRC) and network access licensing are separate MIIT regimes: see SRRC China radio and CCC China.

European Union: the CE marking stays physical

Article 20(1) of the RED (Directive 2014/53/EU) requires the CE marking to be "affixed visibly, legibly and indelibly to the radio equipment or to its data plate, unless that is not possible or not warranted on account of the nature of radio equipment", and "also" visibly and legibly on the packaging. The packaging marking is therefore always required, not only when the product is small. The notified body number follows the CE marking only when the Annex IV procedure (full quality assurance) is used (Article 20(3)). The EMC and Low Voltage Directives use the same model, built on Article 30 of Regulation (EC) 765/2008. No adopted EU act allows the CE marking on a screen.

What is changing: Omnibus IV

On May 21, 2025 the Commission proposed COM(2025) 503, a directive amending 13 product directives, including the RED, "as regards digitalisation and common specifications". For radio equipment the proposal would:

• require the EU declaration of conformity to be drawn up "in electronic form" (Article 10(3));
• add a "digital contact" next to the postal address of the manufacturer and importer (Articles 10(7) and 12(3));
• allow instructions and safety information in electronic form, with safety information still on paper for consumer products, and the access method marked on the equipment, packaging or an accompanying document (Article 10(8)).

It does not amend Article 20: the CE marking stays physical. According to the Parliament procedure file 2025/0133(COD), the text agreed between Parliament and Council negotiators was confirmed by the member states' permanent representatives on June 26, 2026 and approved in committee on July 14, 2026; the plenary first-reading vote is forecast for November 23, 2026. The proposal defers most digitalisation provisions to 24 months after entry into force (12 months for the rest); the agreed text may differ, so check the final act once published.

Product passports and QR codes that add to the CE marking

Two adopted regulations add machine-readable data without replacing the label. The Batteries Regulation (EU) 2023/1542 requires a QR code on all batteries from February 18, 2027 (Article 13(6)) and a battery passport for LMT batteries, industrial batteries above 2 kWh and EV batteries from the same date (Article 77). The Ecodesign Regulation (EU) 2024/1781 creates the digital product passport, required only where a delegated act for the product group says so. See digital product passport. For CE marking dimensions and placement, see the CE pillar.

Medical devices: eIFU, not e-label

Commission Implementing Regulation (EU) 2021/2226 lets manufacturers supply instructions for use in electronic form under the MDR. In its original text this covered implantable and active implantable devices, fixed installed devices and devices with a built-in display system, for professional users only. Implementing Regulation (EU) 2025/1234 (published June 26, 2025) extended it to all devices under the MDR intended for professional users, including Annex XVI products, with paper instructions for lay users where their use is reasonably foreseeable. A documented risk assessment is required (Article 4), and paper copies must be supplied at no extra cost within 7 calendar days of a request at the latest (Article 5). None of this touches the CE marking of the device (MDR Article 20).

Great Britain: UKCA or CE, both physical

The GOV.UK marking table (updated March 31, 2026) lists "UKCA or CE" for radio equipment placed on the market in Great Britain, and "CE, or UKNI and CE" in Northern Ireland. The GB rules follow the EU affixing model, and the government guidance lists no electronic marking. See UKCA marking.

QR codes: where they count

Jurisdiction	QR code as the regulatory label	Condition
US	No provision	2.935(f) allows a model number plus a web page for packaging identification, not as the device label
Canada	Yes	On the product, containing the label itself (no link), readable by generic apps, referred to in the manual
Australia (radio, telecom)	Yes	The linked page must display the RCM prominently
Japan	No	Not one of the three Article 8 methods
South Korea	Yes	Within three menu steps, protected against modification
China	No provision	The electronic CCC mark is screen-only
EU, Great Britain	No	Omnibus IV would allow a code or address for the declaration of conformity and instructions, not the CE marking

Decision path for a new product

1. List the target markets. If the EU or Great Britain is on the list, a physical CE (or UKCA) marking on the product or data plate and on the packaging is required whatever happens elsewhere.
2. Check what the product has. An integrated screen opens the US, Canada, Australia, Japan, Korea and China. No screen: the US accepts a device that only works with a screen device, Canada an audio message or mandatory external equipment, Japan a wired connected product before first use, Australia and Korea a QR code.
3. Design one compliance screen for the strictest rules. Three steps from the settings or main menu (US, Canada, Korea), read-only content, no pairing or SIM needed to reach it, and a displayed number that matches the certification record.
4. Keep the packaging artwork. The FCC, ISED and CNCA all still require identification on the packaging, and the RED requires the CE marking on it.
5. Write the access instructions once. The manual, packaging or product website text must explain the display method in every market that uses it.

Claims the texts contradict

Common claim (including this page before October 2026)	What the text says
"The E-LABEL Act authorises the FCC, without mandating it"	Section 3 of Public Law 113-197 says the Commission "shall" act within nine months to give manufacturers the option
"Three steps from the home screen"	2.935(c) counts from the device settings menu; screen locks and passcodes are not counted
"The FCC does not require any physical marking or packaging mention"	2.935(f) requires the FCC ID or other identifying information on the device or packaging for import and sale
"FCC e-label information must survive battery depletion"	No such condition appears in 2.935
"ISED requires a secondary physical label on the product pointing to the menu"	Annex B.3 requires a physical label on the packaging; instructions can be in the manual, packaging or a website
"No jurisdiction accepts an e-label without an integrated display"	The FCC (device usable only with a screen device), ISED (audio, mandatory external equipment) and Japan (wired connected product) all have a route
"A QR code is not a regulatory label anywhere"	Australia, Korea and, for codes that embed the label, Canada accept one
"Japan requires a secondary physical label and MIC notifications define the e-label"	Article 8 of the certification ordinance requires a document explaining the display, not a physical label
"Korea limits e-labelling to smartphones and tablets, under the KCC"	Annex 5 of RRA Notice 2026-4 allows any equipment by display or QR code; the regime sits with MSIT and the RRA
"China has not generalised the CCC e-label"	Since January 1, 2024 the CCC Mark Management Requirements allow an electronic CCC mark on integrated screens, with a physical mark on the sales package
"The RED requires the notified body number wherever a notified body intervened"	Article 20(3) requires it only under Annex IV; EU-type examination (Annex III) does not add a number
"The small-item derogation moves the CE marking to the packaging"	Under RED Article 20(1) the packaging always carries the CE marking
"Australian records are kept in a Compliance Folder for five years after the last placing on the market"	The Equipment Rules and EMC notice say 5 years after first supply; the 2025 telecommunications notice, two years after supply ends
"eIFU is reserved for a few medical device types"	Since Implementing Regulation (EU) 2025/1234 it covers all MDR devices intended for professional users

Glossary and resources

For the terms (FCC ID, ISED, RCM, Giteki, KC, CCC, eIFU, e-label), see the glossary. For the US framework see the FCC pillar and for the European framework see the CE pillar. For Canadian certification, see ISED Canada. For the UKCA context, see UKCA marking.

See also

• User instructions, safety information & languages
• Component substitution: when does a swap trigger retest?
• Change management: FCC Class II permissive and RED delta
• EU market surveillance and Safety Gate (formerly RAPEX)
• Product recall and EU Safety Gate response procedure
• KC South Korea
• TELEC and Giteki (Japan)
• ACMA and RCM (Australia)

Working on scoping the e-label vs physical label trade-off for an IoT or wearable product placed on the market in multiple jurisdictions for a real product? AESTECHNO can audit your design and certification plan. Get in touch

Sources & references

1. Public Law 113-197, E-LABEL Act of 2014 (S. 2583, November 26, 2014), US Government Publishing Office www.govinfo.gov/content/pkg/PLAW-113publ197/html/PLAW-113publ197.htm
2. 47 CFR 2.935: Electronic labeling of radiofrequency devices, eCFR (Office of the Federal Register) www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-2/section-2.935
3. RSS-Gen Issue 6 (July 30, 2026, Amendment 1 of September 15, 2026): sections 9.3, 9.4 and Annex B, ISED Canada ised-isde.canada.ca/site/spectrum-management-telecommunications/en/devices-and-equipment/radio-equipment-standards/radio-standards-specifications-rss/rss-gen-general-requirements-compliance-radio-apparatus
4. Radiocommunications Equipment (General) Rules 2021 (F2021L00661), Schedule 3, Federal Register of Legislation (Australia) www.legislation.gov.au/F2021L00661/latest/text
5. Radiocommunications Labelling (Electromagnetic Compatibility) Notice 2017 (F2018L00028), section 3.6A, Federal Register of Legislation (Australia) www.legislation.gov.au/F2018L00028/latest/text
6. Telecommunications (Labelling Notice for Customer Equipment and Customer Cabling) Instrument 2025 (F2025L00401), sections 12 to 14, Federal Register of Legislation (Australia) www.legislation.gov.au/F2025L00401/latest/text
7. Ordinance on Technical Regulations Conformity Certification of Specified Radio Equipment (MPT Ordinance No. 37 of 1981), Article 8, e-Gov Japan (Digital Agency) laws.e-gov.go.jp/law/356M50001000037
8. Notice on Conformity Assessment of Broadcasting and Communications Equipment, RRA Notice 2026-4, Annex 5, National Radio Research Agency (RRA) www.law.go.kr/%ED%96%89%EC%A0%95%EA%B7%9C%EC%B9%99/%EB%B0%A9%EC%86%A1%ED%86%B5%EC%8B%A0%EA%B8%B0%EC%9E%90%EC%9E%AC%EB%93%B1%EC%9D%98%EC%A0%81%ED%95%A9%EC%84%B1%ED%8F%89%EA%B0%80%EC%97%90%EA%B4%80%ED%95%9C%EA%B3%A0%EC%8B%9C
9. CNCA Announcement 2023 No. 12 on CCC certificates and marks, with the CCC Mark Management Requirements (in force January 1, 2024), Certification and Accreditation Administration of China (CNCA) www.cnca.gov.cn/zwxx/gg/2023/art/2023/art_926495084f4740b792f914829b1be5c5.html
10. Directive 2014/53/EU (Radio Equipment Directive), Articles 10 and 20, European Union eur-lex.europa.eu/eli/dir/2014/53/oj
11. Regulation (EC) 765/2008: accreditation and market surveillance, general principles of the CE marking, European Union eur-lex.europa.eu/eli/reg/2008/765/oj
12. COM(2025) 503: proposal amending 13 directives as regards digitalisation and common specifications (Omnibus IV), European Commission eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025PC0503
13. Procedure file 2025/0133(COD), Omnibus IV digitalisation directive, European Parliament Legislative Observatory oeil.europarl.europa.eu/oeil/en/procedure-file?reference=2025/0133(COD)
14. Regulation (EU) 2023/1542 on batteries, Articles 13(6) and 77, European Union eur-lex.europa.eu/eli/reg/2023/1542/oj
15. Regulation (EU) 2024/1781 on ecodesign for sustainable products (digital product passport), European Union eur-lex.europa.eu/eli/reg/2024/1781/oj
16. Commission Implementing Regulation (EU) 2021/2226 on electronic instructions for use of medical devices, European Union eur-lex.europa.eu/eli/reg_impl/2021/2226/oj
17. Commission Implementing Regulation (EU) 2025/1234 amending 2021/2226 (eIFU for all devices for professional users), European Union eur-lex.europa.eu/eli/reg_impl/2025/1234/oj
18. Product regulations by sector and current approaches to product marking: UKCA and CE regimes, GOV.UK (Department for Business and Trade) www.gov.uk/government/publications/product-regulations-by-sector-and-current-approaches-to-product-marking-ukca-and-ce-regimes/product-regulations-by-sector-and-current-approaches-to-product-marking-ukca-and-ce-regimes