How to get CE marking: the steps and the importer's obligations

MONDAY, 12 OCTOBER 2026

No authority issues it and it cannot be bought: the manufacturer affixes it. Directives, notified bodies, the declaration of conformity and what importers from China must check.

How to get CE marking: you do not apply to an authority and you cannot buy it; the manufacturer affixes it after showing that the product meets the European rules that apply to it. For anyone importing from China, the task is to check that those steps were really carried out, because when the manufacturer is not based in the European Union the importer answers for the product before the authorities.

This guide follows the process from the point of view of a buyer sourcing abroad: which products must carry the marking, who does what, which documents to request from the supplier and which obligations remain with the importer. In short, the steps are these:

• Identify the European directives and regulations that apply to the product.
• Check the harmonised technical standards used to demonstrate the requirements.
• Establish whether the manufacturer's internal control is enough or a notified body is needed.
• Gather the technical documentation, including the test reports.
• Draw up and sign the EU declaration of conformity.
• Affix the marking to the product, at least 5 millimetres high, and keep the documents for 10 years.

What CE marking is and what it is not

CE marking is a declaration by the manufacturer: with those two letters it states that the product meets the requirements of the European rules that cover it. It lets goods circulate freely across the single market, wherever they were made, so also when they come from a factory in Shenzhen or Ningbo.

It is not a quality mark and it is not a certificate. There is no European office that issues it, and affixing it involves no fee: you only pay for the tests and, where required, for the body that assesses the product. So-called voluntary CE certificates, offered by some companies often at low prices, have no legal value and do not replace the procedure required by law. They are among the documents Asian suppliers send most often, and the first to treat with suspicion.

Which products must carry CE marking

The marking is mandatory only for products covered by a harmonised European rule that requires it. The most common families for importers are:

• Toys.
• Electrical and electronic equipment, including power supplies, lamps and small household appliances.
• Machinery, gas appliances and some pressure equipment.
• Personal protective equipment, such as work gloves, helmets and sunglasses.
• Medical devices, weighing and measuring instruments, drones and pyrotechnics.

A product can fall under several rules at once: a table lamp plugged into the mains must meet the rules on electrical safety as well as those on electromagnetic compatibility and hazardous substances. Products outside all these families, such as mugs, bags or promotional textile items, carry no CE marking but must still be safe: they are covered by Regulation (EU) 2023/988 on general product safety, applied since 13 December 2024.

How to get CE marking: the manufacturer's six steps

The first step is to work out which rules apply. For an electrical appliance, for example, the Low Voltage Directive 2014/35/EU covers products designed to work between 50 and 1,000 volts alternating current and between 75 and 1,500 volts direct current: any product that plugs into a 230-volt household socket falls within it.

The second step is to choose the harmonised technical standards, whose references are published in the Official Journal of the European Union. A product that complies with those standards is presumed to meet the essential requirements they cover: that is why laboratory tests always cite a specific EN standard.

Then come the conformity assessment, the technical documentation and the EU declaration of conformity signed by the manufacturer. Only at the end is the mark affixed; it must be visible, legible and indelible, at least 5 millimetres high unless the rules for the specific product say otherwise, with the proportions of the official drawing. It should preferably go on the product; where that is not possible, on the packaging or the accompanying documents.

Self-assessment or notified body

For many products the law lets the manufacturer assess conformity on its own, through the procedure called internal production control (module A). This is the case for the Low Voltage Directive and for the RoHS Directive on hazardous substances in electrical and electronic equipment. The Electromagnetic Compatibility Directive 2014/30/EU leaves a choice between internal control and EU type examination.

For higher-risk products, such as medical devices, construction products or some machinery, a notified body is needed instead: an independent body authorised by a Member State. Notified bodies are listed in the European Commission's NANDO database, where you check that they are authorised for that exact rule and procedure. When a notified body is involved, its four-digit identification number must be printed next to the marking.

A change of rules is coming for machinery: Regulation (EU) 2023/1230 will replace Directive 2006/42/EC and will apply from 20 January 2027. Anyone ordering machines today for delivery in 2027 should ask the supplier which of the two rules the declaration will be drawn up under.

The importer's obligations

When the manufacturer is outside the Union, Regulation (EU) 2019/1020 on market surveillance requires that for many CE-marked products there is an economic operator established in the EU who is responsible to the authorities: the European manufacturer, its authorised representative or, indeed, the importer. Taking the Low Voltage Directive as an example, before putting the goods on sale the importer must:

• Check that the manufacturer has carried out the conformity assessment and drawn up the technical documentation.
• Check that the product bears the CE marking and comes with the required documents.
• Show on the product its own name or registered trade mark and a postal address, or on the packaging or an accompanying document if there is no room.
• Provide instructions and safety information in a language consumers can easily understand, which in Italy means Italian.
• Keep the EU declaration of conformity for 10 years after placing on the market and be able to show the technical documentation when the authorities ask.

The importer must also make sure that transport and storage do not compromise the product's safety and, if it finds a non-conformity, take corrective action at once, up to withdrawal or recall. If it has reason to believe the product does not comply, it must not place it on the market until it has been brought into conformity.

When the importer becomes the manufacturer

Anyone who sells a product under its own name or trade mark is treated as the manufacturer in every respect, even if the goods are made entirely in China. This is the typical private label situation: the Italian company that has its logo printed on a charger or a toy must hold the full technical documentation and sign the declaration of conformity in its own name, not just keep the supplier's.

Checks at customs

Checks do not only come after the sale. With circular no. 16 of 10 July 2025, the Italian Customs Agency issued instructions for product safety checks at release for free circulation: if the goods are suspected of being dangerous, release is suspended pending verification. For the importer this means containers held up, storage charges and late deliveries: having the declaration, test reports and labels in order before the goods leave China costs much less than proving it with the cargo already stuck in port.

A worked example: LED desk lamps from China

Take a hypothetical case: an Italian company orders 2,000 LED desk lamps that plug into a 230-volt socket, made under the Chinese supplier's brand. The voltage falls within the 50 to 1,000-volt range, so the Low Voltage Directive, the Electromagnetic Compatibility Directive and the RoHS Directive apply. All three allow the manufacturer's internal control, so no notified body is needed and there will be no four-digit number next to the marking.

Before paying the balance, the importer requests the EU declaration of conformity in the manufacturer's name, citing the exact model, the three directives and the EN standards applied, together with the test reports. It has its company name and address printed on the label or the box, and prepares the instructions in Italian. If the goods are placed on the market in November 2026, the declaration must be kept at least until November 2036. If the company decided to sell the same lamps under its own brand, it would become the manufacturer and would have to sign the declaration in its own name. Assuming 2,000 euros of repeat tests at a European laboratory as an independent check, the cost would be 1 euro per lamp: a figure to set against the value of a blocked container or a recall.

The most common mistakes

The mistakes that recur in orders from Asia are few and predictable: a CE certificate issued by a company that is not a notified body, a declaration of conformity in the name of the trading company instead of the factory, test reports for a different model from the one ordered, superseded EN standards, a mark printed with the wrong proportions or smaller than 5 millimetres, instructions only in English. Each of them shows up when the documents are read before production, not after arrival.

With La Merce, getting CE marking on a product made in China means having the declaration, test reports and a label with the importer's name and address checked before shipment, and a file ready to keep for the 10 years required by law.

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