EU plans to include digital tourism equipment in CE certification, affecting China's VR navigation exports

On April 7, 2026, the European Commission released the "Digital Cultural Services Security Framework" draft for public consultation, proposing to include immersive cultural tourism hardware such as VR headsets and AR navigation terminals in the CE certification extension directory. The draft requires that from Q1 2027 onwards, products must mandatorily comply with the new safety standards and data localization clauses, directly affecting the export compliance pathways of over 200 smart hardware manufacturers in Shenzhen, Dongguan, and other regions.

Event Overview

According to the European Commission's public documents, the new draft regulation primarily includes two key requirements: First, incorporating public-facing immersive cultural tourism hardware (including VR/AR devices and interactive projection systems) into the CE certification extension directory; Second, mandating that equipment must simultaneously comply with the EN IEC 62368-1:2025+A11:2026 electrical safety standards and newly added data storage localization clauses. The transition period is set from Q4 2026 to Q1 2027.

Impact on Specific Industries

Cultural Tourism Smart Hardware Manufacturers

ODM/OEM manufacturers in Shenzhen, Dongguan, and other regions need to reassess existing product designs, with potential additional requirements for electromagnetic compatibility (EMC) testing of core components like optical modules and sensors. Observations indicate that small and medium-sized manufacturers lacking in-house testing laboratories may face certification cycle extensions of 30-45 days.

Cross-border E-commerce and Overseas Channel Providers

European B2B buyers must confirm Chinese suppliers' certification progress before Q3 2026, particularly for equipment orders involving scenic area leasing services. Notably, some German and French importers have begun requesting early submission of draft compliance statements.

Key Focus Areas and Recommendations

Priority Handling of In-Progress Order Compliance

For orders scheduled for delivery after Q4 2026, manufacturers are advised to immediately initiate pre-communication with EU Notified Bodies, focusing particularly on changes in ergonomic testing requirements for interactive devices.

Establish Data Localization Technical Contingency Plans

From an industry perspective, differentiation is needed between pure hardware exports and cloud-service-integrated solutions. The latter requires assessing the compounded impact of GDPR and the new regulation, with recommendations to pre-deploy edge computing storage solutions.

Monitor Standard Iteration Dynamics

The EN IEC 62368-1:2025 standard remains under revision and should be interpreted as a precursor signal for technical trade measures. Subscribing to standard interpretation seminars by TÜV and other institutions is recommended.

Industry Observation

Analysis suggests this draft signifies the extension of EU digital cultural product regulation from content to hardware safety. Although currently in the consultation phase, considering recent EU IoT device regulatory trends, the likelihood of final implementation remains high. The industry should note this represents not just certification process changes but potentially a restructuring of supply chain cost frameworks for China-EU digital tourism equipment.

Conclusion

The draft reflects the ongoing tightening of EU digital market access rules, imposing higher export compliance requirements on China's cultural technology enterprises. Currently, it's more appropriate to view this as early warning of technical trade barriers. Relevant enterprises should promptly initiate compliance gap analyses while monitoring potential follow-up actions in non-EU markets like the UK and Switzerland.

Sources

1. European Commission official website "Digital Cultural Services Security Framework" consultation draft (April 7, 2026)
2. Note: EN IEC 62368-1:2025+A11:2026 final version expected to be released in September 2026