I think that's a but of a legal gray area... not quite sure.
PS:
Good to see you on HN still after all those years, cool to see you interested in my little project. :)
Just in case you have something on the top of your mind... I am kind of looking to build a bit of a hardware - boostrapper support network for myself, do you know anyone I should reach out to? Just other people working in the space... I am not too sure about hardware incubators but I would also be open to ideas there..
I wasn't talking about sourcing parts, OP was talking about certification for sales in the EU which I think can be sidestepped selling as a kit of disparate electronic parts. I can receive Mouser shipments from the US to Germany, for example, as long as they're not development boards (which require a declaration of usage) or certain batteries.
I can't imagine why OP would be unable to ship those parts as a kit if they so chose.
Like, you need to rent out a lab for a day or so. And probably want to pay an expert to write the docs for you.
Even though it contains a fully certified esp32-WROOM WIFI module, CE requires me to bring my own lab reports.