Importing Chinese Robots into the EU: CE, AI Act and GDPR Checklist

1. Define the product before requesting certificates

Record the model, hardware revision, firmware, controller, end effector, radio modules, charger and battery. State what the robot will do, where people can approach it and who integrates the final system.

What is being supplied?	What to establish before ordering
A complete machine	Applicable machinery requirements, risk assessment, conformity-assessment route, declaration, marking and instructions for the delivered configuration.
Partly completed machinery, such as an assembly intended for integration	Its declaration of incorporation, assembly instructions and responsibility for conformity of the completed machine. It is not CE-marked under the Machinery Directive merely as partly completed machinery; other applicable legislation may still require marking.
A component or accessory	The component's own legal scope and the evidence the final-system manufacturer needs. A component report does not automatically establish conformity of the assembled robot.
A research or demonstration unit	The precise exclusion or controlled demonstration provision being relied on, rather than the purchaser's university status alone.

The current Machinery Directive distinguishes complete and partly completed machinery. Its research exclusion concerns machines specially designed and constructed for research with temporary use in laboratories; its trade-fair provision requires an appropriate non-conformity notice and safety measures. These are not general permissions for routine workplace deployment. Machinery Directive, Articles 1–6 and 13

2. Build a configuration-specific CE evidence file

CE marking follows the applicable product legislation and conformity assessment. There is no universal third-party “CE certificate” for robots. Some routes permit manufacturer assessment; others require a notified body. Ask which route applies and what the documents actually cover. Commission Blue Guide

Area to assess	Scope and evidence to request
Machinery	Intended use, risk assessment, safety measures, applicable declaration and operating/integration instructions. List the exact standards and editions used, including which references are published in the EU Official Journal.
EMC	Assess equipment within Directive 2014/30/EU and its exclusions; “all electronics” is too broad. Obtain evidence for the relevant operating configurations.
Radio equipment	For equipment within RED, obtain the declaration and conformity-assessment evidence for the radio-equipped product as supplied. A Wi-Fi module certificate alone does not settle antenna, firmware and final-product configuration questions.
Electrical safety	LVD covers equipment within its voltage range and exclusions: 50–1,000 V AC or 75–1,500 V DC. Machinery and RED have their own electrical-safety treatment; RED safety requirements have no voltage threshold. Assess the separate charger/PSU too.
Batteries	Identify the legal battery category, capacity, model and responsible operator. Check the applicable conformity, marking, producer and waste obligations by category and date, including batteries incorporated into equipment.

RED includes EMC and electrical-safety objectives, so a table that simply adds RED, EMC and LVD to every robot can misstate the applicable route. RED Article 17 also permits different assessment procedures: a separate notified-body certificate is not mandatory for every radio module or configuration. RED, Articles 3 and 16–18, EMC scope, LVD scope, Machinery Directive, Annex I §1.5.1

For the machinery transition, the corrected general application date of Regulation (EU) 2023/1230 is 20 January 2027. Products placed on the market in conformity with the Directive before that date have transitional protection for their subsequent making available. A purchase-order date, manufacturing date or old certificate alone does not establish when a particular unit was placed on the market. Document the relevant transaction and timing. Machinery Regulation, Articles 51–54

Battery deadlines also need their conditions. The Article 13 general-information label deadline is the later of 18 August 2026 and 18 months after the relevant implementing act enters into force. Do not treat the first date alone as a universal completed deadline. From 18 February 2027, LMT and EV batteries and industrial batteries exceeding 2 kWh require a battery passport when placed on the market or put into service. The requirement does not cover every robot pack. Confirm the category and current implementing measures for the actual pack. Batteries Regulation, Articles 13 and 77, Commission battery-passport guidance

3. Assign the responsible parties in writing

A Chinese manufacturer does not invariably need an additional EU authorised representative. For products covered by Article 4 of Regulation 2019/1020, the EU-established responsible economic operator can be an EU manufacturer, the importer, a properly mandated authorised representative or, in the specified fallback situation, a fulfilment-service provider. Other applicable legislation can impose its own representative requirements. Market Surveillance Regulation, Article 4

Role	Procurement decision
Product manufacturer or final-system integrator	Identify who assumes responsibility for the product or completed assembly, including changes to its intended use or configuration.
EU importer	Establish who places the third-country product on the EU market and performs the applicable conformity, traceability and corrective-action duties.
Authorised representative	If appointed or required, obtain the written mandate and its scope. A distributor agreement is not the same mandate.
AI provider, importer or deployer	Identify these separately for each relevant AI system; the company shipping the robot is not automatically every AI or model provider.
Data controller and processor	Assign these according to who determines processing purposes/means and who processes on behalf of whom. Match the contract to the actual data flow.

Rebranding or modifying a product can make an importer or distributor responsible as manufacturer under the applicable product law. AI Act provider responsibilities have their own triggers, including certain substantial modifications or changes of purpose. Assess both instead of assuming one label settles all roles. Blue Guide, role definitions, RED, Article 14, AI Act, Article 25

Do not reduce record retention to “the importer holds the whole technical file for ten years.” For example, RED requires the importer to keep the EU declaration for ten years and ensure that technical documentation can be made available to authorities. Address-label placement and language rules also have sector-specific conditions and exceptions. Agree who holds each document, how it can be obtained and which destination-language instructions accompany the shipment. RED, Article 12

4. Classify the AI functions using the amended rules

Ask for the AI system and model names, versions, provider, intended functions, safety dependencies and update process. Separate motion safety, navigation, conversational interaction and any employee or biometric analytics.

The July 2026 change affects machinery, not just dates. Regulation (EU) 2026/1744 was published on 24 July 2026 and entered into force on 27 July 2026. It moved the machinery legislation into Section B of Annex I of the AI Act. For the product-linked high-risk AI covered by that route, Article 2(2) limits direct AI Act application, and the amended Machinery Regulation requires relevant AI requirements to be incorporated through sectoral delegated acts applying by 2 August 2028. This does not make every other AI function on a robot exempt. Digital Omnibus on AI, Articles 1, 3 and 4, AI Act, Article 2(2)

Selected milestone	Meaning for a buyer
2 February 2025	The original prohibited-practice and AI-literacy provisions began applying. The July 2026 amendment revised Article 4; providers and deployers must take measures supporting staff AI literacy.
2 August 2025	GPAI-model obligations and core governance provisions began applying, subject to transitions. Providers of models placed on the market before that date have until 2 August 2027 for their applicable model obligations.
2 August 2026	General application, including applicable Article 50 transparency duties. The high-risk dates below are separate.
2 December 2026	Transition deadline under Article 111(4) for Article 50(2) synthetic-content marking/detection duties of providers whose covered systems were placed on the market before 2 August 2026. This is not a general transparency deferral.
2 December 2027	Chapter III Sections 1–3 high-risk rules, except Article 6(5), for Article 6(2)/Annex III systems.
2 August 2028	Corresponding product-linked high-risk timeline under Article 6(1)/Annex I; apply the specific sectoral treatment, including machinery's Section B route.

These are selected statutory milestones, not one universal compliance deadline. Existing-system transitions and the system's actual role still matter. AI Act, Articles 111 and 113, Commission implementation timeline

For the product route, Article 6 requires both the relevant product/safety-component relationship and the specified third-party conformity-assessment condition. A third-party assessment required solely for risks unrelated to health and safety does not satisfy that condition. AI used only for non-safety assistance or efficiency is not automatically a safety component; failure risks and the amended definitions still need analysis. An employment or biometric use can require a separate Annex III assessment. Workplace emotion inference is subject to an existing prohibition, with the Act's medical/safety exceptions. AI Act, Articles 5 and 6

For conversational features, Article 50's interaction disclosure includes an exception where the AI interaction is obvious in context. Synthetic audio or other generated content can raise additional obligations. A voice interface is therefore not evidence that “only transparency” applies. Request the upstream model information appropriate to the provider's role, but do not demand a fictional universal “GPAI certificate” from every importer. AI Act, Articles 50 and 53

5. Map personal data and connected-product security

GDPR applies where personal data are processed within its scope. Identifiable video, voices or linked user logs may qualify; non-personal motor telemetry does not become personal data merely because it leaves a robot. Processing can occur without permanently storing a recording. GDPR, Articles 2–6, EDPB video guidance

Before deployment, record:

The purposes, lawful basis, controller/processor roles and any Article 28 processing agreement.
What cameras, microphones, logs and training uploads collect; who is identifiable; retention and deletion arrangements.
User notices, access controls, remote support, subprocessors and onward sharing.
Whether the actual processing is likely to create high risk and needs a completed DPIA before use—not simply a template.

A DPIA is particularly required for large-scale systematic monitoring of publicly accessible areas; other high-risk processing and national supervisory-authority lists also matter. Workplace deployments require a separate check of applicable local employment and consultation rules. GDPR, Articles 28 and 35, EDPB video guidance, §10

Map overseas access as well as server location. Where personal data are transferred to a recipient outside the EEA, identify a valid Chapter V route. Applicable SCCs may be a safeguard, but their use requires the relevant transfer assessment and, where necessary, additional measures. EU hosting or an on-prem setting alone does not establish the absence of overseas access or complete GDPR compliance. EDPB transfer guidance, SCC Decision, Clause 14

Cybersecurity is a separate procurement check. Relevant RED cybersecurity requirements have applied to defined categories of radio equipment since 1 August 2025. For products within the Cyber Resilience Act, applicable manufacturer reporting obligations for actively exploited vulnerabilities and severe security incidents started 11 September 2026; the main CRA product requirements apply from 11 December 2027. Ask who receives vulnerability reports, supplies security updates and performs the applicable reporting duties. RED delegated requirements, CRA, Articles 14 and 71

6. Prepare the customs and shipment file

Ask the customs representative to review the actual configuration, function, origin, value, entry date and proposed CN/TARIC classification. Check ordinary duties and any applicable trade-defence measures or restrictions. This guide does not assign one code or rate to robots, or guarantee that Chinese-origin goods face no additional measures. TARIC does not contain national VAT rates; confirm import VAT and other costs separately. Identify the declarant and required EORI. TARIC scope, EORI requirements

Before shipment	Evidence or decision to record
Exact product	Model/revision, software, accessories, intended use and complete/partly completed status.
Applicable product rules	Manufacturer's assessment and configuration-matched declarations, reports, instructions and marking plan.
EU responsibility	Importer/responsible-operator identity; any required representative mandate; document-access arrangements.
AI scope	Function-by-function classification, provider/deployer roles, applicable dates and change-control process.
Data and security	Data-flow record, processing contracts, DPIA decision, transfer safeguards and security-support responsibilities.
Customs and battery transport	Broker-reviewed classification/cost assumptions and carrier-required documents for the actual batteries and shipping mode.
Commercial scope	Written quotation identifying included goods, freight, tax assumptions, support and unresolved document gaps.

Use the research-robot procurement checklist to describe the configuration and the shipping guide to prepare carrier questions. A supplier questionnaire or catalog listing is not product conformity approval.

Request an EU sourcing review: submit the model, destination member state, intended use, configuration and documents already available through the RFQ form. The response can identify quotation requirements and documents to request; conformity conclusions, shipment eligibility and final costs require the relevant evidence and responsible parties.