Can the CE marking be replaced by an electronic label displayed on screen?

Not as a general rule. The CE marking must be affixed visibly, legibly and indelibly on the product under Regulation (EC) 765/2008 and the sectoral directives. A derogation exists when the product is too small, in which case the marking is placed on the packaging and in the user manual. No harmonised directive currently recognises a purely electronic CE label displayed on screen as equivalent to the physical marking.

What is the legal basis for the e-label in the United States?

The E-LABEL Act, signed on 26 November 2014, authorises the FCC to accept electronic labels for devices with an integral display. The detailed conditions are set out in 47 CFR 2.935. The FCC ID, the manufacturer name and the compliance statements may be displayed through the device menu, provided they are accessible in three steps or fewer and cannot be modified by the end user.

Is the e-label accepted in Canada by ISED?

Yes, under conditions defined by RSS-Gen. The device must have an integral display capability, the IC identifier must be accessible without installing a third-party application, and a secondary physical label must indicate the access procedure. The product packaging must also bear the IC identifier in plain text.

Can the Australian RCM marking be displayed electronically?

The ACMA allows electronic display of the RCM marking for products with an integral display, in line with the Radiocommunications Devices (Compliance Labelling) Notice. The display must be accessible through a documented procedure, and the supplier must retain evidence of the implementation in their Compliance Folder.

Does the e-label exempt the manufacturer from providing a paper user manual?

No. The authorisation of the e-label concerns only the affixing of the regulatory label on the product. User manual requirements (handbook, regulatory mentions, safety warnings) remain governed by the applicable product directives. In the medical field, the eIFU regime under Commission Implementing Regulation (EU) 2021/2226 is a separate framework, reserved for devices intended for healthcare professionals.

What if the product has no integral display?

No jurisdiction currently accepts an e-label for a product without integral display capability. The fallback options are a physical label on the product, marking on the packaging and documentation, or for small items a label on the accompanying documentation when the applicable directive permits.

Can a QR code printed on the product replace a physical label?

Not in general. A QR code pointing to a URL is not recognised as a regulatory label in any of the major jurisdictions. The FCC, ISED, ACMA and MIC all require the information to be displayed on the device's integral screen. A QR code can complement the access path to compliance information, but it does not substitute for the physical label or the on-menu display.

What are the most frequent pitfalls for a miniature wearable?

Four mistakes recur. First, assuming that the e-label covers the EU when in fact the CE marking must remain physical. Second, omitting the secondary access-instruction label required by the FCC and ISED. Third, placing the compliance screen behind a prior authentication or pairing step. Fourth, pointing the QR code at a URL that is not durable or not hosted by the manufacturer.

E-label vs physical label: rules by jurisdiction

Author Hugues Orgitello Last updated 27 May 2026 ~14 min read

Cross-cutting regulatory labelling guide

The shift from a printed regulatory marking to an electronic label, designated in the literature as e-label, accompanies the miniaturisation of connected products. For a BLE sensor the size of a coin, an IoT industrial module a few millimetres thick, or an IP camera intended for an outdoor pole, the surface available to carry an FCC ID, an IC identifier, a CE marking, a GITEKI symbol and a KC mark becomes a mechanical constraint on the same order as antenna placement or thermal dissipation. The e-label, defined as the display of regulatory information through an integral screen or a documented access procedure, is however not universally recognised. Each authority has its own framework, its own content requirements, and its own threshold of acceptability. This page documents the state of the rules jurisdiction by jurisdiction as of spring 2026, the content required when the label is electronic, the access mechanisms accepted, and the pitfalls that cause a certification to fail solely on the labelling dimension.

Why an e-label

Three independent forces push toward the electronic label.

The first is physical congestion. A product certified for the United States, Canada, the European Union, the United Kingdom, Australia, Japan and Korea typically carries between five and nine distinct regulatory markings. On a 20 mm by 30 mm enclosure, the surface no longer allows each to be rendered legibly and indelibly.

The second is regulatory agility. A product whose list of authorised countries evolves over time (band addition, certification deferred for a tertiary market) tolerates poorly an engraved or silkscreened marking that has to be requalified at every revision. A software menu is amended by firmware update.

The third is durability. A printed physical label fades, in particular on wearables exposed to sweat, household solvents or washing. An electronic label stored in flash is readable as long as the product functions.

These motivations explain why the e-label was first adopted in the United States, where the density of markings is highest and where the smartphone industry pushed the topic to the FCC starting in 2013.

The E-LABEL Act and 47 CFR 2.935

The US framework rests on the combination of a federal statute and an implementing rule.

The statute, titled Enhance Labeling, Accessing, and Branding of Electronic Licenses Act, was enacted by Congress in November 2014 (Public Law 113-197). It authorises the FCC, without mandating it, to recognise electronic labels for devices with an integral display. The FCC transposed the mandate into a rule published at 47 CFR 2.935.

The rule sets out the substantive conditions.

FCC requirement	Practical disposition
Integral display capability	The device has a screen capable of presenting the FCC ID in clear readable form
Access without third-party application	The information is accessible natively, without download
Three steps maximum	The user reaches the compliance information screen in three manipulations or fewer from the main menu
Permanent access	The information remains accessible throughout the product's life, including after battery depletion and recharge
Not user-modifiable	The end user cannot erase or modify the content
Required content	FCC ID, complementary regulatory identifiers, Part 15 or other statements required by the applicable rule
Access instructions	Provided on the product, on the packaging, or in the accompanying documentation

The rule leaves the manufacturer free to choose the access mechanism (menu, key sequence, scan of a physical QR code pointing to a URL hosted by the manufacturer) so long as the cumulative conditions are met.

See the FCC pillar for the broader US framework.

EU regulation: CE must remain physical

The contrast with the European Union is sharp. The CE marking is governed by Regulation (EC) 765/2008 and by the applicable product directives (RED for radio equipment, EMC, LVD, Machinery, MDR, IVDR depending on scope). None of these standards currently recognises, as a general rule, a purely electronic CE marking in lieu of the physical label.

The CE marking must be affixed visibly, legibly and indelibly on the product. Where the nature of the product does not permit this, the marking is placed on the packaging and on the accompanying documents. The derogation is used for small items, but it does not move the marking onto a screen.

The RED (Directive 2014/53/EU) further requires that the CE marking be accompanied by the notified body number where such a body has intervened, on the product or failing that on the packaging and the manual.

A change is under discussion within the revision of the New Legislative Framework and in sectoral proposals, but no legislative act adopted as of spring 2026 generalises the CE e-label. The prudent design stance is to plan for a physical CE label and not to base an EU market entry strategy on the assumption of imminent recognition of the CE e-label.

The EU does provide a neighbouring but distinct framework: electronic instructions for use (eIFU). Reserved to medical devices and governed by Commission Implementing Regulation (EU) 2021/2226, this framework authorises the electronic provision of instructions for use, under conditions, for devices intended for healthcare professionals. It does not concern the regulatory label itself and does not extend to consumer products.

For CE marking and its dimensions, see the CE pillar.

United Kingdom: UKCA aligned with the EU

The UKCA marking, which replaces the CE marking for placing on the market in Great Britain (England, Wales, Scotland) since the end of the post-Brexit transition period, follows the same principles as the CE marking in terms of physical affixing. The UK Statutory Instruments transposed from EU directives preserve the visible, legible and indelible label rule.

Northern Ireland remains under EU regime for products placed on its market, which keeps the physical CE marking with a complementary UKNI in some cases. No UK provision in 2026 recognises an e-UKCA. See UKCA marking for the details.

Canada: ISED RSS-Gen e-label section

ISED accepts the electronic label under conditions explicitly listed in RSS-Gen (section dedicated to electronic labelling). The requirements are close to the FCC's, with two notable differences.

First difference: a secondary physical label must be placed on the product or on the accompanying documentation, indicating the access procedure to the IC information. The FCC accepts that this instruction be given only in the documentation; ISED requires a physical reference on the product or accompanying documentation.

Second difference: the IC identifier must appear on the packaging of the product in plain text, independently of the e-label. This dual requirement (e-label on the screen plus IC on packaging) reflects Canadian customs practice, where border verification is performed without being able to power up the product.

See ISED Canada for the general context.

Australia: ACMA and the RCM marking

The ACMA authorises the electronic display of the RCM marking for products with an integral display, under the Radiocommunications Devices (Compliance Labelling) Notice. The requirements are:

The screen must be integral to the product and accessible without disassembly.
The RCM marking must be displayed in a screen identified as such.
The access procedure must be documented in the supplier's Compliance Folder.
The access instruction must be available to the end user.

The Australian rule is distinctive in its requirement to maintain a Compliance Folder, a dossier the supplier must be able to produce on ACMA demand for five years after the last placing on the market. Evidence of the e-label implementation (screen capture, user manual, photo of the access instruction) is part of it.

Japan: MIC and GITEKI

In Japan, the MIC (Ministry of Internal Affairs and Communications) recognises the electronic display of the GITEKI mark (Japanese radio conformity marking) for products with an integral display. The framework rests on the Radio Law and on MIC Notifications that specify the conditions of electronic presentation.

The Japanese conditions are:

The display must include the recognisable GITEKI graphic symbol, plus the certification number.
Access is through the integral menu, without network dependency.
A secondary physical label pointing to the menu is required.
For products without a display, the physical marking remains mandatory with no derogation.

The Japanese specificity is the requirement of the GITEKI graphic symbol, which must be rendered recognisably on the screen and cannot be replaced by an equivalent text.

Korea: electronic KC mark

The KCC (Korea Communications Commission) and the RRA (Radio Research Agency) accept an electronic presentation of the KC mark for certain categories of radio equipment, under conditions set out in RRA Notices. The framework is more restrictive than in the United States: it applies primarily to smartphones, tablets and equipment with a rich display, and does not extend to all radio products. A physical label remains required for categories not covered.

See KC South Korea for the general KC framework.

China: CCC remains physical

The CNCA (Certification and Accreditation Administration) has not, as of spring 2026, generalised acceptance of the e-label for the CCC marking (China Compulsory Certification). Products subject to CCC must carry the physical CCC marking on the product, in accordance with the Implementation Rules published by the CNCA for each category.

Sectoral experiments exist for some specific categories, but the general rule at the time of writing remains the physical CCC label. Any product strategy targeting the Chinese market must therefore plan for the CCC marking to be printed, engraved or silkscreened on the product. See CCC China.

MDR and eIFU: a framework distinct from the e-label

Commission Implementing Regulation (EU) 2021/2226 governs, for medical devices and in vitro diagnostic medical devices, the possibility of providing instructions for use in electronic form (eIFU). The framework is restrictive:

Reserved to devices intended exclusively for healthcare professionals (with a few exceptions for active implantable devices under specific conditions).
The manufacturer must provide, on user request, a free paper version within a reasonable timeframe.
The electronic information must be accessible via a stable website, multilingual according to the target market requirements, with guaranteed availability and a continuity plan.
The benefit/risk assessment of the eIFU must be documented in the device technical file.

The eIFU framework is not an e-label: it concerns the instructions for use, not the device's regulatory marking. The physical CE marking remains required on the medical device, in accordance with Article 20 of the MDR (Regulation (EU) 2017/745) and with the IVDR.

Jurisdiction summary

Jurisdiction	E-label	Secondary physical marking	Mention on packaging	Regulatory basis
US (FCC)	Accepted under conditions	Not required	Recommended	47 CFR 2.935, E-LABEL Act 2014
EU (CE/RED)	Not accepted as a general rule	Physical CE marking required	If small-item derogation	Reg (EC) 765/2008, RED 2014/53/EU
UK (UKCA)	Not accepted as a general rule	Physical UKCA marking required	If small-item derogation	UK Statutory Instruments post-Brexit
Canada (ISED)	Accepted under conditions	Required (access procedure)	Required (IC in plain text)	RSS-Gen e-label section
Australia (ACMA)	Accepted under conditions	Required (access procedure)	Per Notice	Radiocommunications Devices Notice
Japan (MIC)	Accepted under conditions	Required (menu pointer)	Per MIC notification	Radio Law + MIC Notices
Korea (KC)	Accepted for limited categories	Per RRA Notice	Per RRA Notice	RRA Notices
China (CCC)	Not generalised	Physical CCC marking required	Per Implementation Rules	CNCA Implementation Rules
MDR/IVDR (medical)	No (e-label) / eIFU for IFU	Physical CE marking required	Per directive	Reg (EU) 2017/745, Impl Reg 2021/2226

Required content on an e-label

The content required varies by jurisdiction, but converges on a set of information that must be presented on the compliance information screen.

Item	FCC	ISED	ACMA	MIC	Comment
Primary identifier (FCC ID, IC, RCM, GITEKI)	Yes	Yes	Yes	Yes	Certification number must be readable in plain text
Manufacturer name	Yes	Yes	Yes	Per notification	Legal name or registered trademark
Product model	Yes	Yes	Yes	Yes	Commercial reference identical to the certification record
Part 15 or equivalent statement	Yes (Part 15 or 47 CFR 15.19)	Yes (licence-exempt RSS)	Per Notice	Per Radio Law	Exact text prescribed by the applicable rule
Bilingual statement (FR + EN) in Canada	No	Yes	No	No	RSS-Gen mandates the FR + EN statement
Radio safety warnings	Per product	Per product	Per Notice	Per notification	External antennas, RF exposure, conditions of use
Serial number or batch	Recommended	Recommended	Per Notice	Per notification	Not always mandatory but a best practice

The absence of any of these elements where required is grounds for blocking certification. Market surveillance services verify the actual content on screen, and an FCC ID present but accompanied by a missing Part 15 statement is treated as non-conformity.

Access mechanisms

Three access mechanisms are commonly used.

The compliance information is presented in a menu of the user interface, accessible from the home screen. The typical path is: home screen, settings, about, regulatory information.

The FCC's three steps or fewer rule applies. The count is from the home screen. A menu buried behind an administrative parameter or a prior pairing procedure does not satisfy the rule.

For devices without a touch interface (BLE badge, miniature sensor with a single 0.5-inch OLED screen), the sequence is a documented combination of button presses described in the manual. The access procedure is considered user-accessible if it requires neither tool nor disassembly nor administrator authorisation.

Printed physical QR code

A QR code printed on the enclosure points to a URL hosted by the manufacturer and presenting the compliance information. This mechanism is not recognised as an e-label in the jurisdictions studied: it replaces neither the physical label nor the on-screen display. It does work, however, as a support for the access instruction to the menu-based e-label, in place of a text printed on the enclosure.

For a QR code to play this instruction role:

The pointed URL must be stable and hosted by the manufacturer.
The URL must remain active throughout the expected service life of the product (typically ten years for an industrial IoT product).
The content accessible through the link must comply with the jurisdiction's requirements, including local language where required.
The URL must not depend on a third-party service liable to shut down.

Online registry

For products without an integral display and intended for a market accepting remote access (rare), an online registry searchable by serial number is theoretically possible. No jurisdiction studied currently recognises it as replacing the physical label. The online registry is best conceived as a traceability complement, not as a compliant e-label.

Decision tree: physical or electronic label

For a product in scoping phase:

Does the product have an integral display capable of presenting readable textual information? If not, the physical label is mandatory in all jurisdictions studied. The e-label scoping stops here.
Which markets are targeted? Establish the list of jurisdictions and identify those that accept the e-label (US, Canada, Australia, Japan, Korea in certain categories) and those that require the physical marking (EU, UK, China, plus the MDR/IVDR medical chain with no e-label exception).
For the jurisdictions that accept the e-label, is the implementation effort justified? Design a compliance information menu, document the access procedure, retain evidence, translate the content. The effort pays off for products with high marking density and severe space constraints (wearables, miniature industrial modules).
For the jurisdictions that require the physical marking, how should markings be placed? Single multi-jurisdiction label, detachable label on packaging for small items, laser engraving, indelible silkscreen. See the CE pillar for CE dimension rules.
Document the coexistence of both approaches in the technical file. A single product can present an FCC ID as e-label and a CE marking as physical. The technical file must describe each of the two approaches and the associated evidence.

Common pitfalls

Assuming the EU permits an electronic CE marking

This is the most common pitfall, particularly on miniature wearables. No provision adopted as of spring 2026 generalises acceptance of a purely electronic CE marking. The small-item derogation of Regulation 765/2008 moves the marking to the packaging and the manual, not to a screen. Designing a product for the EU market on the assumption of an accepted e-CE is a scoping mistake that triggers a late mechanical redesign.

Omitting the secondary physical label in Canada

ISED requires a secondary physical label bearing the access instruction to the e-label. A design inspired by the FCC model, which puts the instruction only in the manual, is non-compliant with RSS-Gen. Late correction forces a redesign of the physical label or a request for ISED guidance, typically delaying the project by two to four weeks.

Compliance screen accessible only after pairing

The three-steps-or-fewer requirement is assessed from the home screen in the product's normal operating state. A product that only displays its compliance menu after pairing with a smartphone, initial WiFi configuration or user authentication is non-compliant. The menu must be accessible from first boot, offline.

QR code pointing to a non-durable URL

A QR code printed on the enclosure pointing to a URL hosted by a third-party service (subcontractor cloud, external redirection service) creates a long-term failure risk. The URL must be owned by the manufacturer and included in its long-term maintenance plan. A certification resting on an external URL loses its operational validity if the URL becomes unreachable, even if the dossier remains formally valid.

Confusing MDR eIFU and product e-label

The eIFU under Commission Implementing Regulation (EU) 2021/2226 concerns the instructions for use of medical devices, not the CE marking of the device. A manufacturer invoking eIFU to exempt itself from the physical CE marking commits a legal error. The CE marking remains physical on the medical device, and the eIFU is added for the instructions for use.

User-modifiable compliance information

47 CFR 2.935 and RSS-Gen require that the information presented be non-modifiable by the end user. A settings page where the user can edit a "device name" field displaying the FCC ID is non-compliant. The content must be read-only and stored in a zone not accessible to the user.

Bilingual statement forgotten in Canada

RSS-Gen mandates a bilingual French and English statement for warnings displayed in the compliance menu in Canada. An implementation aligned on the FCC e-label, in English only, is non-compliant. The translation must be integrated into the firmware before ISED submission.

Glossary and resources

For the terms (FCC ID, IC, RCM, GITEKI, KC, CCC, eIFU, e-label), see the glossary. For the general 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.