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One of the costliest mistakes when importing is assuming every product carries CE marking — or, the other way round, adding it “just in case”. Neither is right. CE is only mandatory for products that fall under a CE directive or regulation; for everything else, affixing it is actually an infringement. Here is how to tell whether yours needs it and what that means.
What CE marking is (and is not)
CE marking is the manufacturer’s or importer’s declaration that a product meets the EU legislation that applies to it and can circulate in the European Economic Area. It is not a quality mark or a third-party certificate: in most cases it is a self-declaration, backed by a Declaration of Conformity and a technical file. A CE mark does not make a product safe by magic; it means someone has declared — and must be able to prove — that it complies. How that DoC is built, we cover in our CE Declaration of Conformity guide.
Does my product need CE marking?
The rule is simple: it needs CE only if a CE directive or regulation covers it. If your product falls within any of the rules below, it carries CE. If it falls under none — much of textiles, furniture, tableware or stationery — it does not carry CE, but it must still be safe under the GPSR and meet labelling and sector rules. Putting a CE mark on a product that does not need one is an irregularity, not extra reassurance.
The CE directives that most affect an importer
- Low Voltage (2014/35/EU): electrical equipment between 50-1000 V AC or 75-1500 V DC: appliances, chargers, luminaires.
- Electromagnetic compatibility, EMC (2014/30/EU): the device must not cause or suffer interference.
- Radio equipment, RED (2014/53/EU): anything with connectivity (Wi-Fi, Bluetooth, radio frequency).
- Toy safety (2009/48/EC): toys for children under 14, with specific tests.
- Personal protective equipment, PPE (EU 2016/425): gloves, masks, safety footwear.
- Machinery: the new Regulation (EU) 2023/1230 replaces Directive 2006/42/EC and applies from 20 January 2027; until then, Directive 2006/42/EC applies.
There are more (construction products, gas appliances, pressure equipment…). One product can fall under several at once: an appliance with Bluetooth meets Low Voltage, EMC, RED and RoHS.
RoHS and electrical goods
RoHS (2011/65/EU) restricts hazardous substances (lead, mercury, cadmium, phthalates…) in electrical and electronic equipment, and compliance is part of the CE marking of those products. It is one of the most overlooked points when importing electronics from outside the EU.
And if my product does NOT need CE?
You are not off the hook: the GPSR (Regulation (EU) 2023/988) requires the product to be safe, traceable, to have an EU responsible person and correct labelling — even without CE. Working out which framework your product falls into is exactly what we do in the product conformity review.
What the importer must check (the logo is not enough)
If your supplier says the product “has CE”, that does not cover you. As an importer, you must hold — and be able to show —:
- The product-specific Declaration of Conformity, signed, citing the directives and standards applied.
- The technical file behind it (tests, risk assessment, drawings).
- The manufacturer and importer details on the product, and the EU responsible person.
A printed CE with no file behind it is worthless in an inspection: the authority asks for the documents, not the logo.
How we solve it
We tell you which framework your product falls into (CE, GPSR or both), which directives and standards apply, and we build the Declaration of Conformity and technical file behind it — signed by an ASC technician. If an authority, customs or a marketplace stops you, we answer. We do not list requirements: we resolve them.
Frequently asked questions
Do I as the importer affix the CE, or the manufacturer? The manufacturer is responsible for affixing it; but as importer you answer for the product you place on the market carrying it legitimately and with its file. If the manufacturer is outside the EU, much of that responsibility is yours.
Do I need a notified body? For most low-risk products, no: CE is self-declared with your technical file. Only certain higher-risk products require a notified body.
My product has no CE — can I sell it? Yes, if no CE directive covers it. But it must meet the GPSR and its labelling. Adding a CE that does not apply is an infringement.
What if my product is a medical device? Medical devices carry CE under their own framework (MDR/IVDR), separate from consumer goods.
Does your product need CE? We will tell you
Tell us what you import and we will tell you whether it needs CE marking, which directives apply and what documentation you need.
You can also reach us through our contact page.