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Multi-marking layouts: CE, FCC, UKCA, ANATEL and other marks

Guide, multi-jurisdiction labelling

The label of an electronic product sold in more than two markets is rarely the topic a project thinks of first, and it is almost always the topic that becomes critical at the moment of industrialisation. Each jurisdiction applies its own marks, with its own rules on size, proportion, position and associated mentions. Stacking eight to twelve marks on a usable surface of a few square centimetres imposes trade-offs: order of marks, clearance between logos, choice between printed label, laser engraving or e-label, and arbitration between a single worldwide label or zone-specific variants. This guide gathers the requirements per jurisdiction (CE, UKCA, FCC, IC, RCM, GITEKI, KC, NCC, ANATEL, CMIIT, CCC, EAC, NOM, TDRA, SDPPI, CITC, ICASA), the composition rules between marks that must be associated, a textual example of a typical marking stack for a global IoT product, and the most frequent pitfalls observed during market surveillance.

Why the marking stack becomes an industrialisation topic

Section titled “Why the marking stack becomes an industrialisation topic”

A product intended for the European market alone essentially carries the CE, the notified body number when there is one, the WEEE pictogram, and a manufacturer identifier. A simple label of three or four square centimetres is enough. The same product intended for the EU, the United Kingdom, the United States, Canada, Brazil, Japan, Korea, Taiwan, China and Australia stacks ten distinct regulatory marks, plus industry marks (Bluetooth SIG, Wi-Fi Alliance, USB-IF) if the relevant technologies are claimed, plus the WEEE pictogram, plus possibly a battery passport QR code under Regulation 2023/1542, plus an A-G energy label. The usable surface remains unchanged, the inventory of marks can triple.

This observation imposes, from the product specification phase, two structuring decisions. The first is the labelling strategy (single worldwide label, geographic variants, e-label), which conditions industrialisation cost, SKU risk and stock management. The second is the marking technology (printed adhesive label, screen printing, laser engraving, in-mold moulding), which conditions the lifetime of the marking, its resistance to use conditions, and the minimum legible size that the technology permits. Screen printing on black plastic does not offer the same fineness as laser engraving on anodised metal: marks imposed at the legibility threshold (FCC ID, ANATEL approval number, Korean KCC ID) do not render in the same way.

Summary table, requirements per jurisdiction

Section titled “Summary table, requirements per jurisdiction”

The table below summarises, per mark, the rules on content, size and position. The cross-references to the individual guides develop each framework.

MarkMandatory contentTypical minimum sizePosition
CE (EU)CE logotype compliant with Decision 768/2008/EC, plus four-digit notified body number if module D-H5 mm height (derogation for products too small, proportions preserved)On the product, or failing that on packaging and instructions
UKCA (GB)UKCA logotype, plus UKMCAB number if Approved Body involved5 mm height, rule aligned with CEOn the product, or failing that on packaging and instructions
FCC ID (US)Format Grantee Code + Product Code (XXX-YYYY), plus name and address of US responsible party (47 CFR 2.1077)Legible at a normal distance, no single numerical sizeOn the product or via e-label if admitted by 47 CFR 2.935
IC (Canada)Format IC: Company Number-Unique Product Number, HVIN if multiple configurationsLegible at a normal distance, RSS-Gen ruleOn the product or via e-label
RCM (Australia)RCM triangle with supplier identifier registered in the ACMA Supplier Database3 mm typical height, proportions set by the Labelling NoticeOn the product or packaging depending on size
PSE (Japan, safety)PSE round or diamond, plus declarant identifierDefined by Densan-ho and METI ministerial ordinanceOn the product
GITEKI 技適マーク (Japan, radio)MIC round radio conformity mark, plus seven-character TELEC numberLegible, no single numerical minimumOn the product or via e-label under conditions
KC (Korea)KC symbol with KCC number (radio) or KC Safety ID (safety)No single numerical minimum, legibility imposedOn the product
NCC (Taiwan)NCC identifier in format CCXXXXYYYYZZ-Z, plus regulatory mentions in traditional ChineseLegible, NCC LP0002 ruleOn the product or packaging depending on size
ANATEL (Brazil)ANATEL logo plus twelve-digit Numero de Homologacao, mentions in Brazilian PortugueseANATEL logo proportions imposed, minimum legible sizeOn the product
CMIIT / SRRC (China, radio)CMIIT ID number in format CMIIT ID: YYYYZZZZZ, no dedicated logoLegible, no single numerical minimumOn the product or via e-label under conditions
CCC 中国强制性认证 (China, safety)CCC mark, plus fifteen- or sixteen-character certificate numberSizes standardised per category (S, M, L), proportions imposedOn the product
EAC (Eurasian Economic Union)Closed EAC symbol with letters E, A, C5 mm typical height, TR CU 020/2011 ruleOn the product, packaging and documentation
NOM (Mexico)NOM identifier with applied standard reference, plus NYCE or ANCE mention depending on bodyLegible, no single minimumOn the product or packaging
TDRA (United Arab Emirates)TDRA radio registration number, plus regulatory mentionsLegible, TDRA Conformity Assessment ruleOn the product or via e-label
SDPPI (Indonesia)SDPPI Postel registration number, plus mentions in IndonesianLegible, Kominfo ruleOn the product
CITC (Saudi Arabia)CITC number, plus mentions in Arabic for consumer productsLegible, CITC Type Approval ruleOn the product
ICASA (South Africa)ICASA approval number in format TA-YYYY/XXXXLegible, ICASA Type Approval Regulations ruleOn the product or packaging
WEEE (EU)Crossed-out bin pictogram, geometry fixed by Annex IX of Directive 2012/19/EUProportions and legibility imposed, no single numerical minimumOn the product or packaging depending on size

See UKCA marking, ANATEL homologation, SRRC and Chinese CMIIT, Chinese CCC mark, Japanese TELEC and GITEKI and general CE marking for the detail per jurisdiction.

Industry marks are not regulatory marks but contractual marks, conditioned by membership of a consortium and by completion of a voluntary certification program. Their legal regime, their attribution procedure and their rules of use fall under the private law of the consortium, not under State regulatory law.

MarkConsortiumPrerequisiteStatus
BluetoothBluetooth SIGQualification of the Declared Product ListingMandatory if the Bluetooth mark is claimed
Wi-Fi CertifiedWi-Fi AllianceWi-Fi Certified programOptional, grants right to use the Wi-Fi Certified mention
PTCRBPTCRB (CTIA)PTCRB certification for US cellular productsPrerequisite at most North American operators
MatterConnectivity Standards AllianceMatter certification and CSA membershipConditions the right to use the Matter logo
ThreadThread GroupThread certification and Thread Group membershipConditions the right to use the Thread logo
USB-IF CertifiedUSB Implementers ForumUSB-IF Certified Logo programConditions the right to use the USB logos
HDMIHDMI Licensing AdministratorHDMI Adopter AgreementConditions the right to use the HDMI logo
Energy StarEPA and DOE (US), EU partnersEnergy Star program and compliance with specificationsConditions the right to use the Energy Star logo

The practical consequence is that these marks never substitute for regulatory marks: a Bluetooth product carries the Bluetooth logo (contractual) and the CE (EU regulatory) and the FCC ID (US regulatory) and the IC (CA regulatory), not one or the other. This accumulation is one of the main causes of label crowding on compact IoT products.

See Bluetooth SIG Qualification, Wi-Fi Alliance, Thread Group, USB-IF, PTCRB for the detail of each program.

Beyond product conformity marks, the label must also carry, where applicable, environmental marks and the upcoming product passports.

  • WEEE pictogram (crossed-out wheeled bin), for any EEE falling under Directive 2012/19/EU. Fixed geometry, imposed position, mandatory presence regardless of the applicable CE regime. See WEEE.
  • Battery pictogram under Regulation 2023/1542 (Battery Regulation), for any product incorporating a battery. The regulation introduces a digital battery passport accessible via QR code for traction and industrial batteries from February 2027, with progressive extension to portable batteries. The physical QR code is mandatory and must be readable by a consumer-grade reader.
  • A-G energy label under Regulation 2017/1369 and its delegated acts, for the product categories concerned (lighting, white goods, displays). The size and position are specified by the delegated acts and are not negotiable.
  • Energy Star (US and partners) for the covered categories, a contractual mark distinct from the EU energy label.
  • Eco-design pictograms under the upcoming Ecodesign for Sustainable Products Regulation (ESPR), with a digital product passport being deployed in successive sectoral waves.

The Digital Product Passport (DPP) introduced by ESPR structurally transforms the label: a growing portion of the mandatory information migrates to a database accessible by unique product identifier, read via QR code or NFC. This trend relieves the physical surface of the label, but imposes a new marking (the DPP QR code) which itself becomes regulatory.

Composition, inseparable marks and association rules

Section titled “Composition, inseparable marks and association rules”

Several marks are inseparable from a complementary identifier or mention, the absence of which is considered a marking non-conformity, not a simple presentation defect.

Main markInseparable elementSource
CEFour-digit notified body number if module D, E, F, G or HDecision 768/2008/EC, article R12
UKCAUKMCAB number of the Approved Body if involved in production phaseSI 2019/696 and its amendments
FCC IDName and address of US responsible party, Part 15 conformity mention47 CFR 2.925, 47 CFR 2.1077
IC (ISED)Applicable RSS mention, plus HVIN if multiple configurationsRSS-Gen, sections on identification
ANATEL logoTwelve-digit Numero de HomologacaoResolucao 715/2019
CCCCCC certificate numberCCC regulation and applicable GB standards
KCKCC number (radio) or KC Safety ID (electrical safety)Korean Radio Wave Act, Electrical Appliances Safety Act
GITEKITELEC numberJapanese Radio Law, MIC Ordinance
NCCNCC identifier in normalised formatNCC LP0002
CMIITCMIIT ID number in plain textSRRC Regulations
EACDeclaration or certificate number associated in the file, not systematically on the labelTR CU 020/2011
WEEEIdentifiable manufacturer marking (name, registered trademark or EAR number for Germany)Directive 2012/19/EU, Annex IX

Omission of the inseparable element is treated as absence of the mark. A product that carries CE without the required NB number is not "partially marked", it is unmarked in the sense of surveillance. This severity explains why final label review checklists focus first on these pairs.

No transversal text sets a numerical distance between two neighbouring marks. Each framework requires, separately, that its mark be visible, legible and identifiable without ambiguity. Stabilised industry practice, without normative value, consists of respecting:

  • a white space of at least one mark height between two adjacent logos,
  • a sufficient background/mark contrast (typically a luminance ratio greater than 4.5 to 1, transposed from web accessibility for lack of a dedicated regulatory rule),
  • a consistent orientation of all marks on the label (all horizontal, or all vertical in the case of a cylindrical product labelled on its side),
  • an implicit visual hierarchy placing mandatory regulatory marks in a dominant position relative to contractual marks.

Compliance with these rules being conventional, the final arbiter remains the surveillance authority that finds, or does not find, the mark to be legible "under normal conditions of use".

Textual example of a marking stack, global compact IoT

Section titled “Textual example of a marking stack, global compact IoT”

To set the order of magnitude, here is the textual representation of a typical label of a cellular and BLE IoT product intended for worldwide deployment. The usable surface is on the order of 30 mm by 50 mm, which is representative of a portable device or a fixed sensor.

+------------------------------------------------+
| Acme Sensor X42 |
| Model: AS-X42-W1 Serial: 24A0001234 |
| |
| [CE 0682] [UKCA 0001] [FCC ID: ABC-X42W1] |
| [IC: 1234A-X42W1] [RCM-N123] |
| |
| [ANATEL 01234-24-12345] |
| [CMIIT ID: 2024AB1234] [CCC C24-09-12345] |
| |
| [GITEKI 技適マーク 003-240123] |
| [KC ID R-R-ACM-AS-X42W1] |
| [NCC: CCAB24LP1234T2] |
| |
| Made in [Country] Acme Corp, [Address] |
| EU Importer: [Name, Address] |
| UK Importer: [Name, Address] |
| [WEEE pictogram] [Batt. pictogram] [QR] |
+------------------------------------------------+

This label accumulates eleven regulatory marks (CE, UKCA, FCC ID, IC, RCM, ANATEL, CMIIT, CCC, GITEKI, KC, NCC), plus the WEEE pictogram, plus the battery pictogram, plus a product passport QR code, plus the identification of the manufacturer and of the EU and UK importers. The surface is saturated, the marks are at the legibility threshold, and any future addition (for example if the product must be extended to India under WPC) imposes either a label redesign, or a partial shift to e-label.

A more ambitious variant, designed for 18 markets, shifts to e-label everything each jurisdiction permits (FCC, IC, CMIIT, GITEKI, NCC, TDRA, ANATEL for certain categories) and keeps on the physical label only the imperative graphic marks (CE, UKCA, ANATEL logo, CCC, KC, EAC, RCM, WEEE) plus the QR code giving access to the e-label.

Since 2014 on the FCC side (KDB 784748), 2017 on the ISED side, and with progressive adoption elsewhere, e-label allows the physical marking of certain information to be replaced by a software display accessible via the product itself. Conditions vary across jurisdictions, but a common logic emerges:

  • the product must include a display or configuration interface allowing the information to be shown,
  • access to the information must be achievable without specialised tools, in two or three menu actions maximum,
  • the graphic mark information (CE logo, ANATEL logo, CCC mark) must remain physical in all jurisdictions where the mark has an imposed graphic form,
  • a physical mention on the product must point to the e-label (typically "FCC ID: see device settings" or equivalent),
  • in case of export, the marks relevant to other jurisdictions must remain accessible, which sometimes implies a language or region menu.

E-label resolves the crowding of the physical label, but it shifts the constraint to the firmware: any menu change, any update that removes an information screen, can break compliance. The label review becomes a firmware review, which is rarely integrated into product validation processes.

Optimisation patterns, single label or regional variants

Section titled “Optimisation patterns, single label or regional variants”

Three models coexist in practice. The choice is conditioned by product volume, by the diversity of target markets, and by the industrial constraints of production.

A single label carrying all marks for all markets. Advantage, a single label SKU, logistical simplicity, no risk of shipping a product with the wrong label. Disadvantage, maximum crowding, marks at the legibility threshold, complete redesign at each market addition. Suited to low-volume products sold simultaneously in all markets (industrial equipment, OEM modules).

A label per geographic zone (EU + UK, North America, LATAM, APAC, Middle East and Africa). Advantage, usable label surface, comfortable legibility, ability to add a market in the zone without redesign of the others. Disadvantage, multiplication of label SKUs, risk of shipping the wrong SKU to the wrong zone (frequent reason for customs blocking), stock management complexity. Suited to high-volume products with a stable market mix.

A physical label reduced to imperative graphic marks (CE, UKCA, ANATEL logo, CCC, KC, EAC, RCM, WEEE), plus a QR code and an "e-label" mention pointing to the software display for all IDs and numbers (FCC ID, IC, CMIIT, GITEKI, NCC, TDRA, etc.). Advantage, compact and legible label, addition of a market via firmware update, graphic surface available for commercial identification. Disadvantage, strong dependency on firmware, exclusion of products without screen or interface, strong constraint on the update review process. Suited to connected products with a user interface or companion app.

Cybersecurity and e-label, a new intersection

Section titled “Cybersecurity and e-label, a new intersection”

The introduction of IoT cybersecurity frameworks (European Cyber Resilience Act, EN 303 645, NISTIR 8425 on the US side, US Cyber Trust Mark labelling scheme) adds a new mark to the inventory. The singularity is that these frameworks rely largely on evolving labels: cybersecurity conformity is not a frozen state at the moment of placing on the market, it includes an obligation to provide updates during a defined support duration. The physical label therefore cannot carry a lifetime conformity attestation, which pushes regulators toward cybersecurity e-labels readable via QR code, pointing to a support sheet kept up to date by the manufacturer.

The US Cyber Trust Mark, whose rollout began in 2024 under FCC, is explicitly designed as a QR label. The upcoming European product passport under ESPR will carry the same logic of evolving information. The physical marking is then reduced to a logo + QR, the actual content being online.

See Cyber Resilience Act, EN 303 645 IoT cybersecurity and NISTIR 8425 for the applicable frameworks.

For consumer products sold in several EU Member States, the obligation to provide instructions, warnings and safety information in the official language of the country of placing on the market creates a multilingual constraint on packaging distinct from the mark itself. The CE marking remains unique, but the associated mentions (importer, safety instructions, short declarations of conformity) must be translated.

Three practices dominate:

  1. Single multilingual label (FR + EN + DE + ES + IT at minimum), with duplicated mentions in each language. Significant surface consumed, but a single product reference.
  2. Local labels overlaid on a base label in English, applied at the national distribution stage. Common practice in multi-country distribution, but exposed to overlay errors.
  3. Separate multilingual paper instructions from the product label, which then carries only the regulatory marks and short mentions. The most widespread practice for IoT products, where the instructions are supplemented by online documentation accessible by QR code.

These choices do not affect the CE marking itself, but they interact with the usable surface of the label and with the organisation of the marking stack.

Marking technology and legibility thresholds

Section titled “Marking technology and legibility thresholds”

The application technology determines the actually achievable minimum legible size, which differs from the theoretical regulatory minimum size.

TechnologyTypical resolutionAdvantagesLimitations
Adhesive printing (label)300-600 dpiLow cost, multi-colour, easy modificationAgeing, possible detachment, counterfeitable
Direct screen printing200-400 dpiGood resistance, aesthetic integrationTooling cost, few simultaneous colours
Laser engraving1000+ dpi on metalIndelible, very high resolution, anti-counterfeitLimited contrast on some materials, machine cost
In-mold mouldingCoarse (200 dpi)Integrated to plastic, indelible, no per-piece costModified mould tooling, no per-batch modification
Pad printing200-400 dpiLow cost, multi-shapeVariable ageing, medium repeatability
Cut marking (cut sticker)Edge onlyPremium aestheticNo fine graphic content

Laser engraving on anodised metal is the reference technology for compact products that must carry numerous IDs at the legibility limit (industrial modules, medical devices, outdoor sensors). For consumer products, adhesive printing remains predominant despite its defects, due to cost and production flexibility. The choice of technology must be made before freezing the industrial design, because it conditions the minimum legible size that can be promised to the regulator.

Several findings recur in surveillance authority reports (DGCCRF in France, OPSS in the United Kingdom, FCC Enforcement Bureau in the United States, ANATEL Fiscalizacao in Brazil) and deserve integration into review checklists.

  1. CE without notified body number when module D, E, F, G or H is applicable. This omission is the most frequent marking error, particularly on products under LVD with a third-party body.
  2. Distorted CE ("China Export") with non-compliant proportions, typical of products imported without control of the official vector file. See CE marking for the sources of the official files.
  3. Overlapping marks or marks without clearance, which make identification ambiguous and trigger an illegibility finding, even if each mark taken in isolation is technically present.
  4. FCC ID without name and address of US responsible party, when 47 CFR 2.1077 requires this association. Frequent error on rebadged OEM products.
  5. ANATEL logo without Numero de Homologacao or with a number cut off on the label (limit of poorly anticipated usable surface).
  6. UKCA marking on a product intended for the European market by confusion with CE. Inverse case also observed.
  7. Bluetooth or Wi-Fi logo displayed without valid consortium certification, which constitutes a contractual violation distinct from regulatory marks.
  8. Inconsistent stack ordering, with contractual marks (Bluetooth, Wi-Fi) placed in a dominant position relative to CE or FCC. Without regulatory value in itself, but often treated as an indicator of poor understanding of the regime.
  9. Marks at the legibility threshold with unsuitable technology (six-character FCC ID in low-resolution screen printing on black plastic), which pass in theory but are contested in practice.
  10. E-label without physical mention pointing to the display, which makes the information de facto inaccessible.

A multi-jurisdiction label review does not reduce to a superposition of per-market checklists. It is structured in five complementary passes:

  1. Jurisdiction pass, market by market, to verify that each mandatory mark is present and accompanied by its inseparable element. This is the base layer.
  2. Geometric pass, on the final printed rendering, to verify proportions, minimum size, clearance between marks, and legibility under normal conditions of use. This is the layer that checklists miss most often.
  3. Consistency pass, to verify that the order, orientation and visual hierarchy are consistent and that contractual marks do not dominate regulatory marks.
  4. Document pass, to verify that the declaration of conformity, the user manual and other accompanying documents carry the equivalent mentions (UK responsible person, EU importer, FCC SDoC declaration, etc.) and that no inconsistency exists between the physical label and the document.
  5. E-label pass (if applicable), to verify that the software display renders the same information as those exempted from physical marking, in all jurisdictions concerned, and that the access mechanism is documented in the manual.

A per-product checklist, kept up to date at each market addition and at each firmware revision, is the basic tool. The most mature version of this checklist integrates the regulatory references per line (Blue Guide article, CFR paragraph, ANATEL resolucao) to support justification in case of a surveillance finding.

  • The label of a product sold in more than two markets quickly becomes an industrialisation topic in its own right, distinct from the certification file of each market taken in isolation.
  • The marking stack of a typical global IoT product accumulates eight to twelve regulatory marks, plus environmental pictograms, plus contractual marks, plus product passport, on an unchanged usable surface.
  • Each mark is associated with an inseparable element (NB number for CE, FCC ID + US responsible party, ANATEL logo + Numero de Homologacao, etc.). The absence of this element amounts to absence of the mark.
  • E-label relieves the physical surface for alphanumeric marks (FCC, IC, CMIIT, GITEKI, NCC, TDRA), but the imperative graphic marks (CE, UKCA, ANATEL logo, CCC, KC, EAC, RCM, WEEE) remain physical.
  • The choice between single worldwide label, regional variants and hybrid with dominant e-label is made from the product specification phase, because it conditions the marking technology and the industrial surface.
  • The product passport under ESPR and the regulated battery under Regulation 2023/1542 transform the label into an interface to an online database, which adds the QR code to the list of imperative marks.
  • A label review is structured in five passes (jurisdiction, geometric, consistency, document, e-label), not in a flat per-market checklist.

To place this topic within the overall mapping, see CE marking, UKCA marking, ANATEL homologation, SRRC and CMIIT, Chinese CCC, TELEC and GITEKI and the Glossary for definitions.

Sources & references

  1. Blue Guide on the implementation of EU product rules 2022 (C/2022/3637) , European Commission, DG GROW op.europa.eu/en/publication-detail/-/publication/b3c5aca0-bcb7-11ec-b6f4-01aa75ed71a1
  2. Decision 768/2008/EC on a common framework for the marketing of products , EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008D0768
  3. 47 CFR 2.925, Identification of equipment (FCC ID labelling requirements) , Code of Federal Regulations www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-2/subpart-J/section-2.925
  4. 47 CFR 2.935 and KDB 784748, Electronic labelling (e-label) , FCC Office of Engineering and Technology www.fcc.gov/oet/ea/kdb
  5. RSS-Gen, General requirements for compliance of radio apparatus , ISED Canada ised-isde.canada.ca/site/spectrum-management-telecommunications/en/spectrum-management/standards/rss-gen-general-requirements-compliance-radio-apparatus
  6. Directive 2012/19/EU on waste electrical and electronic equipment (WEEE) , EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32012L0019