Do you intend to import or distribute products that require CE marking? Then you need to check that the manufacturer has affixed the CE marking correctly. This, in turn, requires that certain documentation can be obtained and verified.
Note: I assume that you are intending to import or distribute an existing product. If you are having a new product manufactured, then there are no pre-existing CE marking documents to check.
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1. Determine what you need
The first step of the process is to determine what you need to request from the manufacturer. This means that you must assess which CE marking regulations and directives apply to a certain product.
Here are two examples:
Bluetooth speaker
RoHS Directive 2011/65/EU
Electromagnetic Compatibility Directive 2014/30/EU
Radio Equipment Directive 2014/53/EU
Batteries Regulation (EU) 2023/1542
Toy
Toy Safety Directive 2009/48/EC
Once this is established, you can then review the importer obligations article to identify the documentation you need to obtain.
Example
Standards
It can also be a good idea to research which standards may apply to your product. This will be useful once you review the documentation.
2. Request documents from the manufacturer
In most cases, you need to request the following documents and files when checking if a product is correctly CE marked:
- Declaration of Conformity (DoC)
- Product test reports
- Product label files
- Packaging label/artwork files
- Technical documentation
- Instructions
You may also need an EC-type examination certificate if the product must be certified by a notified body.
3. Declaration of Conformity Check
The manufacturer must provide a Declaration of Conformity. This is what you must look for:
- Is the product name or model correct?
- Is there a product image present?
- Does the image show the correct product?
- Is the manufacturer name matching?
- Are all applicable EU regulations and directives listed?
- Are all applicable standards listed?
- Are the standards up to date?
Depending on the product, information about the notified body may also be required.
4. Test Report Check
The Declaration of Conformity must be supported by test reports that demonstrate compliance with the applicable harmonised standards. This is what you must look for:
- Is the test report issued in the last year or two?
- Has the manufacturer made changes since the last test?
- Is the product name or model correct?
- Is there a product image present?
- Does the image show the correct product?
- Is the manufacturer name matching?
- Are all applicable standards included?
- Are the standards up to date?
- Are these the same standards as in the DoC?
- Is the test report issued by a known testing company?
It is essential that the test reports match what’s written in the Declaration of Conformity.
You should also contact the testing company to verify that the test report is authentic. Fake test reports are not unheard of.
5. Label Check
You must also obtain product and packaging label files to determine if the product is correctly labelled. This is what you must look for:
- Is the product name or model correct?
- Is a serial or batch number present?
- Is the manufacturer name matching?
- Is the manufacturer’s address and contact point present?
- Is the CE mark present?
- Is the CE mark of the correct proportions and size?
- Are the required warnings, instructions, and safety information present? (if required)
- Is the notified body number specified? (if required)
Note that additional information, such as importer details, may need to be included as well.
6. EC-type examination certificate
Certain products must be certified by a notified body, which may need to issue an EC-type exemption certificate. This is what you must look for:
- Is the product name or model correct?
- Is the manufacturer name matching?
It is important to establish that the certificate is valid for the particular product you intend to procure. Once this is confirmed, you can proceed to verify the certificate by contacting the issuing notified body.
7. Other files
Here are other files you may need to obtain:
Technical documentation
The manufacturer should also provide the technical documentation. The exact information that must be included in the technical documentation can often be found in the Annexes of the applicable EU regulations and directives.
That being said, manufacturers are often reluctant to provide the technical documentation, as this can require giving up sensitive information.
Instructions and warnings
Certain products may also be accompanied by instructions or warnings. For example, sunglasses and other PPE must be accompanied by instructions detailing the protective properties of the product.
Likewise, you may need to provide instructions for installation, maintenance and disposal of electronic products.
Your job is to request the instructions and then ensure that the instructions and warnings listed in the applicable EU regulations and directives are present.
FAQ
Are importers required to check the CE marking?
Yes, importers are obliged to check the documentation that supports the CE mark. You cannot accept a printed CE mark at face value and plead ignorance in case of a recall.
Can Declaration of Conformity files be checked online?
No, Declaration of Conformity files are generally issued by the manufacturer. As such, there is no third party that can provide verification.
Instead, you must check that the Declaration of Conformity contains the required information and that it matches the test report data.
How can CE marking test reports be checked online?
Yes, you should be able to verify test reports by contacting the issuing company.
I would personally not trust test reports that cannot be verified by a third party.
How can CE marking certificates be checked online?
Yes, in some cases, notified bodies and other entities provide online databases where you can search the certificate number.