This post is by Fredrik Gronkvist, the co-founder of Chinaimportal.com.
What is CE marking? What kind of products need CE marking? And who is actually responsible for making sure the product gets CE marked?
These are questions I see in my inbox on a daily basis.
CE marking is misunderstood, but not necessarily as complicated as you might think.
In this article, I will explain what every importer and online seller must know about CE marking, what it takes to make a product compliant and how much it’ll cost you.
View Top Product Sourcing ToolsWhat is CE marking?
CE is a compliance mark, that signals to the consumer that the product is compliant with all applicable safety standards and directives.
Some of these directives regulate electrical safety, while others regulate radio communication standards, toy safety or eye protection in sunglass lenses. I wrote about the regulations in detail in Complying with EU Product and Labeling Regulations: A Complete Guide.
The CE mark itself is not a standard or directive, but only a signal that the product is safe for the consumer to use. This is also why the CE mark is found on everything from bicycles and power banks, to watches and toys.
They may be regulated by completely different standards, yet they all have the same compliance mark.
But, a product isn’t magically compliant simply because it carries the CE mark.
In addition to the printed CE mark itself, the following requirements must be met:
Technical compliance
The product must be technically compliant. For example, a power supply must be designed according to strict safety criteria, and toys must not contain lead or other regulated substances. If the product is not made to comply with these rules, it doesn’t matter how many CE marks it has, as the CE mark itself cannot make the product compliant.
Documentation
The importer must issue a set of documents for each product, this includes:
- Declaration of Conformity
- Design drawings
- PCB design (for electronics)
- Bill of materials
- Risk assessment
- List of applicable EN standards / directives
- Packaging layout file
- Manual
- Test reports
Lab testing
Third party lab testing is not mandatory for most products. Yet, it’s the only way to be sure that the product is compliant.
As an importer, you should get the product lab tested before the goods are shipped.
Should the products fail lab testing, you can’t make them compliant. Instead, the supplier must remake the entire order.
Which products must be CE marked?
The CE mark is, for example, applicable to the following product categories:
- Electronics
- Sunglasses
- Quartz watches
- Toys
- Bicycles
- Protection equipment (such as safety helmets and gloves)
- Machines
- Medical devices
A product that is not covered by a specific CE marking directive doesn’t need to be CE marked.
Why do I need to make sure that my products are CE marked?
When importing from countries outside the EU, such as China, it’s always the importer’s responsibility to ensure that the products are fully compliant with all applicable EU regulations.
If you import non-compliant products, customs (or other authorities) have the right to seize and destroy your products – without compensating you.
Here are a few scenarios that could occur if you don’t follow the CE marking process properly:
- Customs have the right to fine importers that cannot provide a technical file. This means you need to have your documents in order, even if it’s only a matter of providing documents you created yourself.
- Consumer product safety authorities have the right to collect and test product samples. They can issue a recall if the product fails testing. We have seen this recently with hoverboards and other risky products. To avoid this happening, make sure you always get your products lab tested.
- Customs can seize any product without a CE mark, that should carry one.
In short, you need to make sure that you cover all requirements from technical compliance, to documentation and labeling.
Will my suppliers make sure that the product is compliant?
Many importers want to take shortcuts, and that’s when things go wrong.
No, you cannot use your suppliers “CE certificate”. It doesn’t work like that, because there is no such thing as a “CE certificate”. Yet, many importers take their supplier’s advice, and act like these regulations don’t exist.
The truth is that many non-EU suppliers don’t know what CE marking really is (beyond printing a logo at least).
In addition, many suppliers cannot even make compliant products. Hence, you must do background checks to find out if they have experience making products that comply with all of the relevant CE marking directives for your product.
How do I make sure my product is compliant?
In order to make a product compliant, you must fulfill these requirements:
- Make sure the product is technically compliant. This requires two steps:
- Confirm which EU directives apply to the product, and learn the specifics in each one. Which substances are banned? How should the product be designed to comply?
- Submit a sample for third party compliance testing. It’s the only way to be sure.
- Issue the documentation
- Create the label files
The last two parts are actually really simple!
How much does it cost to make your products “CE compliant”?
The CE mark itself doesn’t have to cost anything. Go on Google.com, search for CE marking and send the file to your supplier. Done.
