EU Smart Glasses & Wearables
Smart glasses and camera wearables have their own EU compliance path
RED/CE certification, a conditional battery-removability derogation in force from 11th November 2026, and GDPR-driven design choices around cameras and biometric data — layered, not swapped out from a normal wearable.
Last updated 24th October 2026 · By Vas Parshin and Anabel Amar
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.
Layer 2: the battery-removability derogation
The general EU Battery Regulation (2023/1542) Article 11 requires portable batteries to be user-removable and replaceable from 18th February 2027. On 14th July 2026 the Commission adopted a delegated act adding six product categories to the existing derogation list, including wearable devices — but read the conditions before assuming your product is covered. The act does not name smart glasses as a category. What it adds is wearables designed to operate in environments regularly subject to water, and wearables where consumer access to the battery would compromise safety, durability or water resistance. The Commission's accompanying guidelines (C(2026) 5032) do name smart glasses, as an example of a wearable that may qualify under the wet-appliance derogation in Article 11(2)(a) if it meets the stated indicators, or under Article 11(2)(c) on miniaturisation grounds. So this is a conditional derogation to argue for on your specific design, not a blanket carve-out.
Two further caveats. The derogation is partial: qualifying products still need to be designed so an independent professional can replace the battery — what's removed is the requirement that the end user personally be able to do it. And it applies from 11th November 2026: the delegated act was published in the Official Journal on 22nd October 2026 as Commission Delegated Regulation (EU) 2026/1770 and enters into force twenty days after publication.
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).
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 either meets end-user removability or genuinely satisfies a derogation condition, with professional-repairer replaceability either way. 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?
Conditionally, from 11th November 2026. A delegated act adopted by the European Commission on 14th July 2026 adds wearable devices to the derogation list from the general Article 11 end-user-removability mandate that otherwise applies to portable batteries from 18th February 2027 — but only wearables designed for environments regularly subject to water, or where consumer access to the battery would compromise safety, durability or water resistance. Smart glasses are not named as a category in the act; the Commission's accompanying guidelines cite them as an example of a wearable that may qualify under Article 11(2)(a) or 11(2)(c). Qualifying products still need to be designed so an independent professional can replace the battery. The act was published in the Official Journal on 22nd October 2026 as Commission Delegated Regulation (EU) 2026/1770 and enters into force on 11th November 2026.
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 derogations (like the July 2026 battery delegated act, in force from 11th November 2026) change faster than most product teams can track. We scope which of the three layers actually apply to your specific design, arrange the RED/EMC testing, and manage the programme end to end.
Contact usSources
- Directive 2014/53/EU (RED); Commission Delegated Regulation (EU) 2022/30, Article 1 (EUR-Lex)
- European Commission, 14th July 2026; Commission guidelines on removability and replaceability of portable batteries, C(2026) 5032, sections 3.2.1 and 3.2.3. See also our general EU Battery Regulation page for the removability rule this derogation sits inside
- 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