Many importers treat the CE mark as a quality seal that someone official has checked. It isn't. The CE mark is the manufacturer's own declaration that a product meets the EU rules that apply to it. And when that manufacturer is in China, a large part of the responsibility for making sure it's true falls on you, the importer.

This article is general information, not legal advice. Requirements depend on the product; confirm them for your specific case.

What the CE mark actually says

By affixing the CE mark, the manufacturer states that the product complies with all applicable EU harmonisation legislation and that the required conformity assessment has been carried out.

Three things follow:

  • Not every product carries CE. It applies only to categories covered by specific EU legislation, such as electrical equipment, electronics, radio equipment, toys, machinery and personal protective equipment. Clothing, furniture and many household goods don't carry CE, although other rules, including general product safety rules, still apply.
  • For most products, no authority checks it in advance. For much consumer electronics, the manufacturer assesses conformity itself. Only certain higher-risk products require an independent notified body.
  • A “CE certificate” from a test lab is not the legal document. Labs issue test reports and certificates of their own. The legal document is the EU Declaration of Conformity, issued and signed by the manufacturer.

The documents behind the mark

A CE-marked product must be backed by two things:

  1. Technical documentation: the evidence that the product complies. It typically includes a product description, design drawings, a risk assessment, the list of standards applied, and test reports.
  2. The EU Declaration of Conformity: a short document in which the manufacturer names the product, the legislation and standards it meets, and signs for it.

The declaration is the claim. The technical documentation is the proof.

What the importer is responsible for

If you bring a product from outside the EU onto the EU market, you are its importer, and EU product legislation gives you specific duties. In broad terms, before placing the product on the market you must make sure that:

  • the manufacturer has carried out the conformity assessment and drawn up the technical documentation;
  • the product carries the CE mark and is accompanied by the required documents;
  • the manufacturer's name and contact address appear on the product;
  • your own name and contact address appear on the product, or where that's not possible, on the packaging or an accompanying document;
  • instructions and safety information are provided in a language consumers in the country of sale can easily understand.

Afterwards, you must keep a copy of the Declaration of Conformity for ten years, be able to provide the technical documentation to authorities on request, and act if you have reason to believe a product doesn't comply.

One further point matters for anyone selling under their own brand. If you place a product on the market under your own name or trademark, you are treated as the manufacturer, with the full manufacturer's obligations.

Where it typically goes wrong

  • Test reports for a different model. The report covers the supplier's model A; you're buying model A-2 with a different charger.
  • Reports from labs that can't be traced, or reports whose number the lab doesn't recognise.
  • A declaration naming the wrong legislation, or outdated standards.
  • No technical documentation at all, just a PDF certificate.
  • Components changed after testing. The report is genuine; the product in your container isn't the one that was tested.
  • Missing importer details or local-language instructions.

What this means in practice

Before production, ask your supplier for the Declaration of Conformity and the underlying test reports, and check that they name your exact model. Verify the test reports with the laboratory that issued them. Keep copies of everything. If the documentation doesn't exist or doesn't match, you want to know before you pay, not when authorities ask for it.