A CE Certificate of Conformity (CoC) essentially states that a certain product is compliant with one or more regulations, directives or standards. It also includes information about the conformity assessment performed, the issuing company, product information, and supplier.
In theory, this certificate is issued based on the issuing company reviewing or creating certain documents. This includes test reports and technical files.
However, as I will explain in this guide, far from all documents titled ‘Certificate of Conformity’ are valid and based on an actual conformity assessment. In short, many of these documents are invalid and can result in your products being subject to a recall, fines, or other penalties.
What is a CE Certificate of Conformity?
A CE Certificate of Conformity is a third-party issued document stating that a certain product is compliant with one or more directives, regulations, and harmonized standards. In general, it also states that the issuing company has tested or reviewed the complementary technical documentation – which is the basis for them issuing the Certificate of Conformity.
What is the purpose of this document?
CE Certificate of Conformity serves as a confirmation that your products and their documentation is compliant. At least that’s what it’s supposed to mean. That being said, a CE Certificate of Conformity is not a replacement for a Declaration of Conformity (DoC), technical file, and valid lab test report.
That said, it is not necessarily mandatory to obtain a third-party issues Certificate of Conformity. But, it is valuable to have a qualified partner manage to test and review the documentation. That way you can feel more confident that it’s been done correctly.
CE Certificate of Conformity Summary
This information is often included in a Certificate of Conformity:
Registration/Report Number: The report or certificate number can be used to verify if the document is valid. All certificates have some sort of registration or report number.
Issuing Company: The company that issued the Certificate of Conformity, including their contact details, and address.
Certificate Holder: The company for which the certificate was issued. This is usually the importer or manufacturer which intends to sell the product.
Product Information: Product name, SKU, or model number. One certificate can sometimes cover more than one product.
Regulations/Directives/Standards: Summary of the regulations, directives, and standards to which the product is certified to confirm. Here are some examples:
- EN 71-1
- EN 71-2
- EN 50581
- EN 50065
- EN 13637
Statement: Explains the basis for issuing the company. This is one example from a certificate issued by TUV Rheinland:
This certificate of conformity is based on the evolution of a sample of the above-mentioned product. Technical report and documentation are at the License Holder’s disposal. This is to certify that the tested sample is in conformity with all provisions of Annex I of Council Directive 2004/108/EC.
This certificate does not imply an assessment of the production of the product and does not permit the use of a TUV Rheinland mark of conformity.
The holder of the certificate is authorized to use this certificate in connection with the EC declaration of conformity according to a.m. Directive.
In short, the certificate of conformity is at the core an evaluation of the sample and its complementary documentation. This can, in turn, be used to support the DoC.
Signature: The certificate is usually signed, stamped, or both.
Certificates of Conformity Sample
Fake Certificates of Conformity
A certificate of conformity is in principle a good concept. However, there are many companies out there (does not include TUV Rheinland) that issue these certificates without any lab testing and document review taking place.
In short, some companies sell these certificates for products that lack test reports, technical documentation, and a Declaration of Conformity. The certificate is therefore issued based on nothing – but is still accepted by manufacturers and importers that don’t know better.
As mentioned, a certificate of conformity is not a substitute or replacement for the following:
- Declaration of Conformity (DoC)
- EU-type examination certificate*
- Technical file
- User manual
- Test report
We have conducted hundreds of supplier screenings in Asia, and elsewhere, in the last decade. This procedure involves that we request and verifying compliance documents held by the supplier. We frequently receive certificates of conformity without any complementary lab test report or other support documents.
Personally, I think most non-EU suppliers simply don’t understand what the CE marking process means in practice. Some may genuinely believe that it’s only a matter of paying a fee for the sake of obtaining a certificate.
Fake certificates were also reported by the European Safety Federation in 2020 and 2021. I recommend that you read this article on fake certificates concerning medical devices and PPE.
*Issued by a notified body
Other Certificate Titles
We have also encountered identical product certificates with the following titles:
- CE Certificate
- Attestation of Conformity
- Verification of Conformity
- Certificate of Compliance
How do I know if a CE Certificate of Conformity is valid?
TUV Rheinland, and other companies of good repute, generally offer databases where you can search and verify certificates and other documents. For example, the screenshot below is taken from the TUV Rheinland certificate database.
How can I check if a CE Certificate of Conformity is fake?
You can either search the certificate number in a database or email the issuing company. You can also contact the issuing company by email. You can assume that the document is invalid if the issuing company cannot provide any method of verification.
That being said, the verification itself doesn’t prove that the certificate itself was issued based on an actual conformity assessment. You should therefore ask the issuing company and your supplier to provide supporting documents. Chances are that they don’t have any.
Which products require a CE Certificate of Conformity?
In theory, a CE Certificate of Conformity could be issued for any product which requires CE marking. Here are a few examples:
- Consumer electronics
- Electrical equipment
- Children’s products with play features
- Other personal protective equipment
- Medical devices
How do I obtain a CE Certificate of Conformity?
You can obtain a certificate of conformity from a third-party, such as TUV Rheinland. That said, you’re more likely to receive a certificate of conformity from your supplier. As mentioned, many of these documents are invalid and do not serve as any proof of compliance.
Why do some suppliers provide invalid or fake certificates?
Most likely because inexperienced importers keep falling for it. These certificates often look legit and official – and for some buyers, that’s enough to assume that the certificate they’ve received is all they need to ensure compliance.
I think it ultimately comes down to wishful thinking. Spending time and money on lab testing, certification, user manuals, and labeling is painful.
From their perspective, It sure would be great if a certificate of conformity could serve as a substitute or replacement for an expensive and time-consuming compliance process.
That said, there are no shortcuts, and it doesn’t matter how official a certificate may seem if it’s not based on testing and a review of the actual technical documentation.
What kind of risks do I face if we’re selling products based on an invalid CoC?
Products that are ‘certified’ based on nothing at all (other than payment) are potential safety hazards. Importing products without prior safety testing and the mandatory documentation (e.g. DoC and technical files) can result in recalls and fines.
Further, I know for a fact that market surveillance authorities in some EU countries have categorically rejected certificate of conformity documents as acceptable substitutes for a proper DoC, test report, and technical file.
Importing products based on a CoC alone will therefore put both consumers and your business at risk.
What is the difference between a Certificate of Conformity and a DoC?
A Declaration of Conformity (DoC) is a document issued by the importer or manufacturer ‘placing the product on the market’. Issuing a DoC is mandatory when manufacturing or importing products that require CE marking.
A Certificate of Conformity on the other hand is issued by a third party.