CE marking for a product made in China: who tests, who signs, what it costs

If you have a product made in China and sell it under your own brand, you are its manufacturer in EU law. You sign the EU declaration of conformity and answer for the CE marking; the factory and a test laboratory supply evidence, and a notified body takes part only when the law for your product requires one.

What it costs depends on how many EU laws apply and whether a notified body is involved. This guide is general information and does not constitute legal advice; a test laboratory or notified body confirms what applies to a specific product.

Which products need CE marking

CE marking is required only for products covered by EU harmonised rules that specifically ask for it. The EU’s Your Europe portal lists, as examples, toys, drones, electrical and electronic equipment, pyrotechnics, recreational craft, certain pressure equipment, gas appliances, batteries, machinery, weighing and measuring equipment, personal protective equipment and medical devices (Your Europe).

The reverse rule matters as much. Regulation (EC) No 765/2008 says the mark goes only on products whose harmonisation law provides for it “and shall not be affixed to any other product” (Article 30(2)). A deck brush falls under general product safety rules and carries no CE mark. Our guide on the GPSR responsible person covers those goods.

The steps, in order

Your Europe sets out the sequence below. Where several laws apply, all of them must be met before the mark goes on.

1. Identify the laws and the harmonised standards. A harmonised standard is a European standard developed by a recognised European standards organisation; its use is voluntary, and once its reference is published in the Official Journal of the EU (OJEU) it gives a presumption of conformity (European Commission).
2. Choose the conformity assessment procedure. Each law sets its own. Under the Low Voltage Directive (LVD), Directive 2014/35/EU, the procedure is “internal production control”: the manufacturer assesses the product itself (Annex III).
3. Build the technical documentation. For electrical equipment this includes a general description, design and manufacturing drawings, a risk analysis, the list of standards applied, design calculations and test reports (LVD Annex III, point 2).
4. Draw up the EU declaration of conformity (DoC). Annex IV of the LVD gives the model: product identification, manufacturer’s name and address, the laws and standards applied, and a signature. Where several laws apply, one single declaration covers them all (Article 15(3)).
5. Affix the mark. It must be visible, legible and indelible, at least 5 mm high unless the product law says otherwise, and on the product where possible (Your Europe).

When a notified body is required

A notified body is an organisation designated by an EU country to assess conformity where a law requires a third party (European Commission). Whether you need one depends on the law and sometimes on the route you take.

The Radio Equipment Directive (RED), Directive 2014/53/EU, shows how. If you apply harmonised standards for its requirements on radio spectrum and other specific points in Article 3(2) and (3), you may assess the product yourself. If you have not applied them, or applied them only in part, or none exist, the product must go through EU-type examination or full quality assurance, both of which involve a notified body (Article 17(3) and (4)).

To check a body, search the NANDO database (New Approach Notified and Designated Organisations), which the Commission now runs within its Single Market Compliance Space. Search by the law that applies to your product and confirm the body is notified for the exact procedure you need. When a notified body is used, its four-digit number appears next to the CE mark.

Who signs: the brand is the manufacturer

The LVD defines the manufacturer as anyone who “manufactures electrical equipment or has electrical equipment designed or manufactured, and markets that equipment under his name or trade mark” (Article 2(3)). An importer who places a product on the market under its own name takes on the manufacturer’s obligations too (Article 10).

So when your brand is on the box, you sign the declaration and “assume responsibility” for compliance (Article 15(4)). Only the manufacturer or its authorised representative may affix the mark (Regulation 765/2008, Article 30(1)). The factory prints it on your behalf and supplies drawings, component data and samples; what it owes you depends on your contract.

You keep the technical documentation and the declaration for 10 years after the product is placed on the market (LVD Article 6(3)). For products under most CE laws, the LVD and the RED included, Regulation (EU) 2019/1020 also requires an economic operator established in the EU to hold the declaration and produce the documentation on request (Article 4). See our guide to the authorised representative and the responsible person.

What an importer must check and keep

If you import a product under someone else’s brand, you are the importer. LVD Article 8 requires you to make sure the manufacturer carried out the conformity assessment, drew up the technical documentation and affixed the CE mark, and that the product carries a type number and the manufacturer’s name and postal address. You add your own name and address and keep a copy of the declaration for 10 years.

When a factory sends you a “CE certificate”

A document headed “CE certificate” is often a test report or a voluntary certificate. Your Europe warns that voluntary certificates “are not legally recognised” for CE marking. The LVD has no notified body step at all, so such a certificate for a mains appliance is at most a summary of tests. Check four things:

• Issuer. Is it a notified body listed in NANDO for that law and procedure, or a testing laboratory? For a laboratory, ask for its accreditation certificate and scope. In China the national accreditation body is CNAS; signatories to the ILAC Mutual Recognition Arrangement (MRA) “agree to accept the results of each other’s accredited conformity assessment bodies” (ILAC).
• Model match. The model number, ratings and photos must match your product, including your colour or component changes.
• Standards listed. The report should list harmonised standards for every law that applies, with their editions.
• Date. Manufacturers must take changes in harmonised standards and in the product’s design into account (LVD Article 6(4)). An old report on a different revision proves little.

What testing costs

We found no laboratory price list for EU CE testing that we could verify, so this section gives the cost drivers. Your Europe confirms that the manufacturer bears the cost of conformity assessment, that it depends on product complexity and procedure, and that affixing the mark carries no fee.

Common mistakes

• Putting a CE mark on a product that no CE law covers.
• Filing the factory’s certificate as your technical documentation.
• A declaration in the factory’s name when your brand is on the product.
• Testing a pre-production sample, then changing components in mass production.

For electrical goods it sources, Aslan checks the certification file against the product before shipment. It has no test laboratory and no engineers, so testing itself is done by an accredited laboratory or notified body you choose.

Document checklist

• A CE law applies to the product
• Notified body need checked, and the body verified in NANDO
• Test reports cover the exact production model
• Declaration signed in your name
• EU-based economic operator named