AI Technology
The EU AI Act: trustworthy, transparent, and secure AI in electronics
By Iain Bowes, head of management system assurance for TÜV SÜD Business, a global provider of auditing and certification services that help organisations to gain in-depth insights of how corporate systems affect business performance
T
he European Union’s (EU) AI Act is the world’s first comprehensive legal framework for artificial intelligence (AI). It mandates that organisations must integrate technical safeguards with ethical and legal compliance across the entire AI lifecycle. Organisations must therefore take a risk-based approach to comply with legal requirements for AI applications. This places the heaviest compliance burdens on systems that pose threats to health, safety and fundamental rights. For the electronics and manufacturing sectors, this is not merely an IT challenge; it is a fundamental governance mandate.
The impact on UK supply chains A common misconception is that the AI Act is confined only to the EU. However,
18 October 2026
UK-based businesses are fully bound by its requirements if their AI systems are placed on the EU market, or if the output of those systems (e.g., a prediction or decision) is used within the EU. Consequently, UK organisations trading with or supplying EU partners must align their operational practices with the Act.
The AI Act categorises entities based on their interaction with the AI system across the value chain of providers, importers or distributors, and deployers/users. It applies to users located in the EU, and third country users where the AI system’s output is used in the EU. Providers are developers and manufacturers who train or place AI models on the market, and they face the most severe compliance obligations. If a UK organisation deploys AI tools internally, for example for supply chain
Components in Electronics
logistics, managing business functions or for assembly operations, it is acting as a deployer and is subject to obligations relating to responsible use, human oversight and record keeping. Importers must guarantee that non-EU systems satisfy European requirements before market entry, while distributors that sell or supply AI systems without modifying them must ensure systems are supplied safely.
Classifications and the double compliance burden
The manufacturing and electronics sectors are greatly impacted by the Act’s high-risk classifications, particularly regarding embedded AI. Under Article 6(1), an AI system is automatically classified as high- risk if it acts as a safety component of a product covered by existing EU product
safety laws (listed in Annex I), and that product requires a third-party conformity assessment.
If a company manufactures smart machinery or industrial IoT devices, they must follow both the AI Act and the relevant existing safety laws. This creates a complex double compliance burden for manufacturers, and directly impacts: Industrial machinery – AI used to control robotic arms, automated assembly lines, which falls under both the AI Act and the Machinery Regulation
Electronics and radio equipment - AI integrated into smart devices or industrial IoT sensors subject to the Radio Equipment Directive.
Medical devices – hardware using AI- powered diagnostic algorithms
Lifts and pressure equipment – AI
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