CE marking on China-made electronics

The technical file. The description of the product, the design and manufacturing information, the standards applied, the test reports, the risk assessment where one is required, and the reasoning that connects them to the requirements. It is compiled by the manufacturer and has to be available to a market surveillance authority on request for a defined period after the last unit is placed on the market.

The EU declaration of conformity. A single document in which the manufacturer declares, under their sole responsibility, that the product meets the applicable Union legislation. It names the product, the legislation, the standards applied, and it is signed by or for the manufacturer. This is the document you should be asking for and the one most buyers have never seen.

The mark itself, and the other markings. The CE mark goes on the product where possible, with the manufacturer's name and address and the model identification, and the importer's name and address where applicable. Markings that rub off are a non-compliance that arrives with a customer photograph.

The test reports. Necessary, but an input rather than the conclusion. Check the model on the report against the product, and the applicant against the party that is going to sign the declaration.

And note what a report does not do: a report about a sample says the sample met the standard on that day. Production consistency is a separate obligation and a separate practice.

The manufacturer signs the declaration, and "manufacturer" is a legal role rather than a description of who owns the machines. Placing a product on the market under your own name or trademark generally makes you the manufacturer for these purposes, whoever physically made it.

So "the factory has CE" answers a different question. The factory may hold test reports and may have a declaration for its own model under its own name. Whether you may rely on any of it for a product sold under your brand is a commercial and legal question with a separate answer, and it is worth settling before production rather than after a market surveillance letter.

What to negotiate at quotation. That the factory will provide the technical file or the elements of it that you cannot produce yourself; that test reports will name your model; that they will support a conformity assessment for your version; and that they will notify you of design changes that could affect conformity.

The importer's role. Whoever brings the goods into the Union carries their own obligations: checking that the manufacturer did the assessment, that the documentation exists, that the marking is present, and adding their own name and address. An importer who does none of that is not less exposed for having assumed the factory handled it.

Where you sit in that chain decides what you must hold, so decide it explicitly. Buying a factory's own-brand product as an importer is a different position from branding it, and the paperwork differs accordingly.

Products covered by the relevant Union legislation need an economic operator established in the Union — a manufacturer or importer in the Union, an authorised representative, or in some arrangements a fulfilment service provider. That party's name and address go on the product or its packaging, and they are the party a market surveillance authority contacts.

For a business outside the EU shipping direct to consumers, this is the requirement most often discovered late. It is not satisfied by a freight forwarder, and it is not satisfied by a customer acting as importer without knowing it. Establishing who plays that role is a business decision to take before the first shipment.

Marketplaces enforce it independently. Platforms increasingly require the operator details and the documentation before a listing goes live, and a listing removed for a missing operator is removed the same week rather than after an investigation.

And it interacts with the labelling. The operator's details have to appear on the product or its packaging, which means it is a printing decision with a lead time — not something that can be added after the goods are made.

This page names no article numbers and no product-category lists deliberately. The principles above are stable and are what a buyer needs to act on; the precise scope depends on the legislation applicable to your product, and a citation quoted second-hand in a guide is exactly the kind of confident paraphrase that gets a compliance answer wrong.

Ask for the EU declaration of conformity for the exact model, and read it: the product identification, the legislation listed, the standards applied, and the signature block. A declaration that lists legislation irrelevant to the product, or standards that do not exist, is a template somebody filled in.

Ask for the test reports behind it, and check the model and the applicant on each. A report for a similar model is not evidence about yours.

Ask who holds the technical file and where. If the answer is "the factory", ask whether you can obtain it, because you may be the party required to produce it.

Be suspicious of a certificate that looks like an approval. For most consumer electronics no authority issues one, so a document styled as an approval is either a test report presented as more than it is, or a document from a body whose role you should check.

And be suspicious of speed. A conformity assessment that appears in two days for a product that did not exist last week is describing a paperwork exercise rather than an assessment — and the risk of that is not a fine, it is a product that does not do what the file says it does.