Ask a Chinese supplier for proof that a product is compliant and you will usually receive a "CE certificate" within the hour: a smart-looking PDF with a logo, a certificate number and a list of standards. It proves much less than it appears to. For most products the CE mark is a declaration the manufacturer makes itself, and as the importer you carry legal responsibilities that no supplier's PDF can take off your hands.
How CE marking actually works
For most consumer and industrial products sold in the European Union, including those covered by the low-voltage, electromagnetic compatibility and restriction of hazardous substances rules, the manufacturer assesses conformity itself, compiles technical documentation and signs an EU declaration of conformity. No outside body issues a certificate. Only certain higher-risk categories require a notified body, an organisation designated by an EU member state, to be involved: for example higher-risk personal protective equipment, gas appliances, pressure equipment and medical devices.
The documents that matter are therefore:
- The EU declaration of conformity, signed by the manufacturer, naming the exact product and the legislation and standards applied
- The technical documentation, including test reports against the relevant harmonised standards
- For categories that need one, a notified body certificate, from a body whose four-digit number can be checked in the EU's official NANDO database
What the supplier's certificate usually is
The PDF labelled "CE certificate" is typically a certificate of compliance or verification of compliance issued by a testing laboratory or certification company. It is a voluntary document. At best it summarises a real test report. At worst it covers a different model, cites withdrawn editions of standards, names a company that did not make the product, or is simply fabricated. It is not a declaration of conformity and it is not a notified body certificate, whatever its wording suggests.
| Check | What to look for |
|---|---|
| Product and model | The exact model you are buying, not a "series" or a similar product |
| Company name | The manufacturer you are dealing with, or a documented relationship to it |
| Standards | Current editions of the harmonised standards for this product |
| Test report | Ask for the full report, not the certificate: sample photos, test results, dates, and the product in the photos must be yours |
| Laboratory | Accreditation to ISO/IEC 17025 for the tests performed, confirmed with the accreditation body |
| Authenticity | Contact the laboratory directly with the report number; genuine laboratories will confirm |
| Notified body claims | If a notified body is claimed, check its number and scope in the NANDO database |
Your obligations as the importer in the EU
The person who first places a product on the EU market from outside the EU is the importer, with duties of their own. Before placing it on the market, the importer must make sure the conformity assessment has been done, the technical documentation exists and can be provided, the product carries the CE marking and the required information, and the importer's own name and address appear on the product or its packaging. A copy of the declaration of conformity must usually be kept available to the authorities for ten years.
Two more rules raised the stakes:
- For products covered by many of the harmonised rules, the EU market surveillance regulation has required since July 2021 that an economic operator established in the EU is responsible for the product.
- The General Product Safety Regulation, in application since 13 December 2024, extends similar responsibility to consumer products generally and sets out the information that must be shown when products are sold online, including the manufacturer and the responsible person in the EU.
One point surprises many private label buyers: if a product is placed on the market under your name or trademark, EU law treats you as its manufacturer, with the manufacturer's full obligations. Our private label sourcing guide covers the commercial side; the compliance side starts here.
The United Kingdom
Great Britain accepts the CE marking indefinitely for most product regulations, following legislation in force since 1 October 2024, so the UKCA marking is optional for the large majority of goods. There are exceptions, notably medical devices, and Northern Ireland continues to apply EU rules. The UK has its own importer obligations, including the importer's details on the product or packaging.
The United States
- Electronics. Radio transmitters such as Wi-Fi and Bluetooth devices need FCC certification through a recognised certification body and carry an FCC ID. Many other digital devices use the supplier's declaration of conformity, for which the responsible party must be located in the United States.
- Children's products. These must be tested by a laboratory accepted by the Consumer Product Safety Commission, and the importer or manufacturer issues a Children's Product Certificate based on that testing.
- Other consumer products subject to specific safety rules need a general certificate of conformity from the importer.
A checklist before you pay for production
- List the rules that apply to the product in each destination market.
- Ask for full test reports for the exact model, not certificates.
- Verify the laboratory and, where claimed, the notified body.
- Decide who signs the declaration of conformity and who holds the technical file.
- Agree labelling: CE or other markings, your name and address, warnings and instructions in the required languages.
- Make compliance part of the pre-shipment inspection: markings, labels and documents checked against the approved sample (inspection checklist).
A supplier's certificate is a starting point for questions, not an answer. If you want the documents for a product checked before you commit, send us the product and the paperwork; the same background checks we describe in supplier background checks apply to the laboratories named on it.