Do I need to CE mark a product if the components are already compliant?

Yes, you need to CE mark the final product even if you use components, materials, and parts that are compliant with CE marking requirements. That being said, using components that are tested according to CE marking requirements is still crucial.

In this guide, we explain to what extent you can rely on pre-existing test reports for individual components when it comes to CE marking.

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Why do I need to CE mark a product if the parts are already CE compliant?

CE marking is applied to the final product or system rather than individual components. This is also reflected by documentation and labelling.

1. A Declaration of Conformity is issued on a “per product model” basis by a single manufacturer (not multiple component manufacturers).

2. The technical documentation must cover the final product, including all parts.

3. Harmonised standards apply to the final product (and test reports must also correspond to the complete and final product)

4. Product and packaging labels must include information about the product type and batch number of the final product (not individual parts).

5. The labels must also include information on the manufacturer and their address. You can only specify a single manufacturer (and thus not list all individual component manufacturers).

6. Instructions must provide information on usage and precautions for the final product, not only individual parts.

One reason for this is that “compliant” components could be constructed in a way that renders the final product unsafe. Another reason is that there must be a single manufacturer who is responsible for the CE marking process.

Does it still make sense to buy CE marking compliant parts?

Yes, using buying components and materials that comply with CE marking requirements is essential. First, let’s establish what a “CE marking compliant” component or material can be.

Examples

• Lithium batteries compliant with EN 50760
• AC adapters compliant with EN 50563
• Electronic components compliant with RoHS substance restrictions
• Plastic granulate compliant with EN 71-3

As you can see above, CE marking compliance in this context refers to components that comply with harmonised standards. It does not necessarily mean that a DoC and technical documentation has been issued.

Why is this important? Because the individual components don’t need applicable harmonised standards are inherently non-compliant.

For example, if you use an AC adapter that doesn’t meet safety requirements, then the final product is also doomed to failure.

Can I use existing test reports of individual components?

Yes, using parts that comply with CE marking requirements can be beneficial for the following reasons:

1. You reduce the risk of testing failure for the final product

2. You may be able to avoid certain tests if compliance is already demonstrated

Let’s say that you intend to launch an air purifier. These devices can contain hundreds of components, and it can be expensive to test the entire bill of materials for RoHS compliance.

That could potentially be avoided if you can collect RoHS test reports from your component suppliers, resulting in a drastic lab test cost reduction.

Note that collected test reports must be included in the technical documentation. It is also essential that you verify component test reports before including them.

Do I need product testing if the components are already CE marking compliant?

Yes, you will likely need to test the final product even if all individual components are tested as compliant (and appropriately documented, with a test report).

Let’s take a toy as an example. It’s essential to buy materials, such as plastic granules, that comply with the substance restrictions under EN 71-3. However, testing is still needed on the final product as the Toy Safety Directive also requires that a toy is mechanically safe.

You could, for example, use a compliant material to construct a toy that contains small parts or sharp points, which would thus render it non-compliant.

Examples