EU Smart Glasses & Wearables

Smart glasses and camera wearables have their own EU compliance path

RED/CE certification, a July 2026 battery-removability carve-out, and GDPR-driven design choices around cameras and biometric data — layered, not swapped out from a normal wearable.

Last updated 11 September 2026

days to 18 Feb 2027 battery deadline
Jul 2026delegated act exempted smart glasses from end-user battery removability
3regulatory layers: RED/CE, Battery Regulation, GDPR/AI Act

Layer 1: RED and CE marking

Any smart glasses with Bluetooth or Wi-Fi connectivity are radio equipment under the Radio Equipment Directive (2014/53/EU) — the same regime as any other wireless consumer device. That means EMC, radio spectrum and EN 62368-1 safety testing, plus the RED cybersecurity requirements under Delegated Regulation (EU) 2022/30: network protection, Article 3(3)(d), if the glasses can communicate over the internet; personal-data protection, Article 3(3)(e), because wearable radio equipment that can process personal, traffic or location data is covered even without an internet connection, which nearly every camera-equipped pair of glasses can; and fraud protection, Article 3(3)(f), only if they let the wearer transfer money.

Source: Directive 2014/53/EU (RED); Commission Delegated Regulation (EU) 2022/30, Article 1 (EUR-Lex).

Layer 2: the battery-removability exemption

The general EU Battery Regulation (2023/1542) Article 11 requires portable batteries to be user-removable and replaceable from 18 February 2027. A July 2026 Commission delegated act carved out smart glasses, smartwatches and fitness trackers from that end-user bar — but the exemption is partial, not a free pass. These products still need to be designed so an independent professional repairer can replace the battery; what's removed is the requirement that the end user personally be able to do it without tools or a workshop visit.

Source: European Commission, 14 July 2026. See also our general EU Battery Regulation page for the removability rule this exemption sits inside.

Layer 3: cameras bring GDPR into scope

Nothing in EU product-safety law mandates a physical recording light — but data-protection authorities have made clear that always-on camera glasses are a live compliance risk under GDPR's lawfulness and transparency principles. Regulators including France's CNIL have specifically flagged camera-equipped smart glasses, pushing manufacturers toward visible recording indicators and opt-in consent flows for bystanders. If the glasses also do on-device face or eye tracking to power AI features, that biometric processing can additionally trigger EU AI Act obligations depending on the specific use case (biometric categorisation is treated more strictly than simple gaze-based UI).

Source: CNIL public guidance on connected/camera-equipped devices; EU AI Act (Regulation (EU) 2024/1689), Article 5 prohibited-practices and Annex III high-risk use cases for biometric categorisation.

Why this needs its own checklist

A standard wearable compliance review stops at RED + Battery Regulation. Add a camera and the review has to also cover: whether the recording indicator/consent design is defensible under GDPR, whether any on-device processing counts as biometric categorisation under the AI Act, and confirming the battery design still meets professional-repairer replaceability even though end-user removability is exempted. Missing any one of the three leaves a real gap a general "wearables" checklist won't catch.

Questions

Do smart glasses need CE marking in the EU?

Yes. Smart glasses with wireless connectivity (Bluetooth, Wi-Fi) fall under the Radio Equipment Directive (RED, 2014/53/EU) and need CE marking covering EMC, radio spectrum, health/safety (EN 62368-1) and, since RED Article 3(3)(d)/(e)/(f), cybersecurity for anything that processes personal data or connects to the internet.

Are smart glasses exempt from the EU Battery Regulation's removability rule?

Partially. A July 2026 European Commission delegated act exempted smart glasses, smartwatches and fitness trackers from the general Article 11 end-user-removability mandate that otherwise applies to portable batteries from 18 February 2027. They still need to be designed so an independent professional repairer can replace the battery — the exemption removes the end-user bar, not the repairability requirement.

What GDPR obligations apply to camera-equipped wearables?

There is no EU product-safety law that mandates a physical recording indicator, but data-protection authorities have pushed manufacturers toward visible recording indicators and opt-in consent flows to manage covert-recording risk under GDPR's lawfulness and transparency principles. Regulators in France (CNIL) and elsewhere have specifically flagged always-on camera glasses as a compliance risk area. This is a design decision that reduces regulatory and reputational exposure, not a single named regulation to certify against.

What's different about smart glasses versus a normal wearable?

The camera. A fitness tracker or smartwatch is a RED + Battery Regulation product. Add a camera and you add GDPR/data-protection scrutiny (recording indicators, consent, on-device vs cloud processing) and, if the glasses process biometric data (face/eye tracking), potential EU AI Act obligations depending on the use case. The certification path is layered, not swapped.

Where we fit

Smart glasses sit across three separate regulatory regimes at once, and the exemptions/carve-outs (like the July 2026 battery delegated act) change faster than most product teams can track. We scope which of the three layers actually apply to your specific design, bring in the right accredited lab for RED/EMC testing, and manage the programme end to end.

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