Selling electronics, toys, PPE, and medical devices on Amazon in the European Union requires that your products are correctly CE marked – or you face the risk of immediate and permanent product removal.
In this guide, we explain what Amazon sellers must know about CE marking, and why it also affects companies located in the UK, US and China – that are selling certain product types on Amazon in the EU.
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Is CE marking mandatory for Amazon sellers?
Amazon requires that all products sold by its third-party sellers comply with product safety standards and labelling requirements in each respective marketplace. Products that require CE marking in the European Union must therefore be CE marked to be sold on Amazon’s European marketplaces.
Here are a few examples of EU directives and regulations that require CE marking:
- EMC Directive
- Low Voltage Directive (LVD)
- RoHS Directive
- Radio Equipment Directive (RED)
- Battery Regulation
- Toy Safety Directive
- Personal Protective Equipment (PPE) Regulation
- Machinery Regulation
- Medical Devices Regulation (MDR)
As such, Amazon only sets the same requirements as the EU member states when it comes to CE marking. Amazon does, as far as I am aware, not impose CE marking requirements in countries and markets were this is not a requirement already.
Which products require CE marking on Amazon?
As mentioned, products that fall within the scope of one or more “CE marking directives” must carry the CE mark. Here are a few examples.
- Electronics
- Batteries
- Toys
- Helmets
- Sunglasses
- Protective gloves
- Machines
- E-mobility devices
- Medical devices
Product claims
We have also seen cases in which product marketing claims have triggered Amazon to take action and require CE marking for certain products. For example, claiming that a device provides protection – could classify the product as Personal Protective Equipment (PPE) which means that CE marking is required.
We have also noticed other cases when Amazon took action due to sellers claiming that the product could provide treatments of various kinds, resulting in the products being due to non-compliance with the Medical Devices Regulation.
Which products should not be CE marked on Amazon?
Products that are not covered by one or more CE marking directives or regulations should not carry the CE mark. Generally speaking, this includes most clothing textiles and furniture.
That said, other compliance requirements may apply to such products sold on Amazon.
Examples
Which Amazon marketplaces may require CE marking?
CE marking is mandatory in all EU countries. As such, CE marking is required when selling certain products on any of the European Amazon marketplaces:
- www.amazon.de
- www.amazon.it
- www.amazon.fr
- www.amazon.es
- www.amazon.nl
- www.amazon.pl
- www.amazon.se
Is CE marking required when selling on Amazon UK?
The UK initially intended to completely phase out CE marking and replace it with UKCA marking. However, in 2023, the UK government announced indefinite CE mark recognition beyond the 2024 deadline – for certain products.
We are still waiting for more definitive guidelines. However, it is likely that Amazon will also accept CE marking for the products that the UK government accepts CE marking for.
Is CE marking required when selling on Amazon in Northern Ireland?
Our understanding is that Amazon requires companies selling in Northern Ireland to follow EU rules. For example, Amazon has requested companies selling in Northern Ireland to ensure compliance with the EU Battery Regulation, which in turn requires CE marking.
Do Amazon sellers need an authorised representative for CE marked products?
Companies selling products that require CE marking from outside the EU to consumers in the EU must generally speaking have an authorised representative. The detailed requirements can be found in the EU Market Surveillance Regulation from 2021.
For example, companies selling CE marked products from the UK, US or China to consumers via Amazon in the EU must have an authorised representative.
When does Amazon check if a product is CE marked?
Amazon can take action when a new product is listed for sale in the EU, or years later. Compliance checks can also be triggered by reports from consumers, or third-party investigators.
It is essential that you do not wait until Amazon takes action, as you will only be given at most 30 days to demonstrate compliance. If your product is not correctly CE marked, documented and tested at this time – then it’s already too late to do anything about it.
Which CE documents does Amazon check?
A product is only correctly CE marked if supported by valid documentation and correctly labelled. Hence, Amazon tends to request the following documents for verification when checking if a product is correctly CE marked:
Declaration of Conformity
The DoC is normally issued by the Amazon seller and contains the following information:
- Product name/model/serial number
- Company name and address
- Compliance statement
- Additional product details and image
- List of EU directives and regulations
- List of applied harmonised standards
- Name and signature
Product test reports
Test reports that clearly list the product name and model must be provided. These should also be fairly recent and correspond to the current harmonised standards.
If not, then these will be rejected by Amazon’s compliance team. It is essential that the test report can be connected to your specific product. As such, sending random test reports valid for different products will not convince them.
Product label images
Product label images must clearly show the CE mark and traceability text.
They may also want to see that WEEE symbols and other marks, when applicable, are present.
Packaging label images
The exact same principle as the product label images, but for the packaging instead.
Other documents
Amazon can also request the user instructions, which are for most CE marked products, for review. In theory, they could also request the technical documentation – but I am not personally aware of any instance in which Amazon’s compliance team has done this.
Amazon CE verification email
Below is an example of an email sent by Amazon when conducting a compliance check concerning CE marked products.
Hello from Amazon Selling Partner Support,
Thank you for your interest in selling [PRODUCT]. We have reviewed the information you provided and determined that it does not meet our requirements. To allow us to continue processing your application, please address the following issues:
Invoice:
– We were not able to verify the supplier information listed on the invoice provided. Please provide an invoice with valid, verifiable supplier information.
Product Packaging Picture:
– The images provided do not meet the EU labelling guidelines, which state that address on the label must be that of an EU country. Please provide product images that meet this requirement.
– The images provided do not meet the labelling requirements, which state that any information added to the product packaging must be securely adhered and not easily removable. Please provide images that meet this requirement.
– The images provided do not meet the labelling requirements, which state that the label must contain a certification mark. Please provide images showing all sides of the product packaging including appropriate certification mark.
Please respond to this case and provide updated document(s) that remedy the issue(s) indicated above. You can respond to this case within the next 14 days or create a new application at a later time.
Amazon and many other brands do not make clear the difference between a genuine C E mark as discussed,and the CE mark used by the Chinese to indicate a China Export. They look very similar in the only difference is the spacing on the EU marque, and the absence on the China Export badge, which is clearly designed to be confusing to purchasers.
Hi Phil,
I don’t think that “China Export” mark is official in China. They have their own CCC mark and while I have heard this story before, I think it’s something suppliers just make up. The “China Export” mark not real.
Can amazon be my importer / authorised representative should I sell my product to the EU as ignorer to carry the CE mark one of the things I must have is a company based in that territory as appointed to represent the manufacturer (myself).
Hello Jen,
No I don’t think Amazon can act as your importer. I think they might have some kind of authorised representative program, but I am not sure if this is provided by Amazon or one or more third parties.
Hi there
Just wondering do I need an EU/UK rep for my DoC if I am only selling in the UK?
Ive sent some product to Amazon UK that are CE marked, but they have removed my listing. I’m waiting to see what further information Amazon UK need from me….
Hi Ashley,
Probably a test report and Declaration of Conformity
hi Ashley, were you able to sell the product, i am facinng similar issue when selling a travel adpater, will it be possible to get any help from you please.
Do I need to mark CE products (which need to be CE Marked in the EU) produced in the EU but exported in Asia where there is no CE Marking requirement?
Hi James,
CE marking is required when “placing products on the EU market”. That said, I would not be surprised if the market surveillance authorities would still require CE marking, even if the products are not intended for sales in the EU.
Thank you…