How to Get CE Certification for Products Made in China
Ask a Chinese factory for a CE certificate and most will send one within a day. It will be a certificate, in the ordinary sense of the word, issued by a testing company or a compliance agent. It will look authoritative. It will also, in the great majority of cases, not be the document European authorities actually require.
CE marking has no central issuing authority. The manufacturer declares conformity and signs. Understanding that oddity is the difference between a compliant file and a folder of decorative paper.
Who is the manufacturer, in EU terms
The manufacturer is the party that places the product on the market under its own name. If you buy from a Chinese factory and sell in the EU under your own brand, you are the manufacturer for the purposes of the directives. The factory is a supplier.
That single point changes who is responsible for the technical file, who signs the Declaration of Conformity, and who answers to a market surveillance authority. Many buyers assume the factory holds all of this, and discover the error when a German authority asks for documents.
Step one is deciding which directives apply
There is no master list. You work product by product.
| Product | Directives in scope | Notified Body needed |
|---|---|---|
| Wired household appliance | Low Voltage, EMC, RoHS | No |
| Bluetooth speaker | Radio Equipment, RoHS | Only if harmonised standards are not fully applied |
| Children’s toy | Toy Safety, RoHS, and REACH restricts | Yes for category one toys |
| Personal protective equipment, category three | PPE Regulation | Yes |
| Cosmetic | Cosmetics Regulation, plus notification | No, but a responsible person is mandatory |
The Low Voltage Directive applies in the 50 to 1,000 volt alternating current range. Below that range, safety still matters but falls under the General Product Safety Regulation instead. Products that transmit need the Radio Equipment Directive, and that directive applies to the whole product, not only to the radio module inside it.
Step two is the technical file
The technical file holds the reasoning behind the declaration: the standards applied, the test reports, a description of the product, drawings, the bill of materials where it affects conformity, and the risk assessment. It must be retained for ten years after the last unit is placed on the market.
The file does not get submitted anywhere for a self-declared product. It gets produced on demand, and market surveillance authorities do ask. A supplier that cannot produce a file structure, only a certificate, has skipped the part that carries the legal weight.
Step three is the Declaration of Conformity
The declaration is a short document, and its contents are prescribed. It names the manufacturer and, where applicable, the authorised representative. It identifies the product by type or serial reference. It lists the directives applied. It cites the standards used. It carries the place and date, and the name, function and signature of the person signing on behalf of the manufacturer.
A declaration that cites standards with no version reference, or that reproduces a template from a compliance agent with the factory’s name inserted, is a document to send back. You can read more about how this differs from other conformity paperwork in our guide to US safety listings, because the same confusion between a report and a declaration appears on both sides of the Atlantic.
The EU responsible person rule
Since July 2021, a product needs an economic operator established in the EU, named on the product or on its packaging or accompanying document. If your manufacturer is outside the EU and you are too, an authorised representative is required.
Since December 2024, the General Product Safety Regulation adds traceability duties for consumer products more broadly, including a responsible person and the ability to identify the product and its origin. Sellers who built a compliance file in 2023 need to check it against the newer rules rather than assuming it still holds.
Cost, time and the Notified Body decision
An EMC and safety package for a straightforward product runs $1,500 to $4,000. Adding radio moves it to $3,000 to $7,000. A Notified Body, where one is required, adds $3,000 to $15,000 depending on the sector and whether a quality system audit is involved.
Two to eight weeks covers most testing. What actually breaks a schedule is a product that fails EMC on first submission. Budget one redesign cycle, because a metal enclosure change or an added filter is common on a first attempt.
Two marks get mistaken for CE. The China Export mark uses a similar glyph with the letters spaced differently and has no legal meaning. A CE mark obtained from an agent who never tested the product is a marking offence regardless of whether the product is sound.
Where a Chinese supply chain usually fails on CE
Three failure modes repeat. The first is a Declaration of Conformity that cites directives without naming the standards used to satisfy them, signed by someone whose function is not stated. The second is a technical file that does not exist beyond the test report, so nothing answers a question about the bill of materials or the risk assessment.
The third is scope creep after approval. A product is tested with one power supply, then the factory substitutes a cheaper adapter, or changes the enclosure from plastic to painted metal. EMC performance depends on both, and the file now describes something the line no longer builds. Requiring written approval for any change to the bill of materials is the control that prevents this, and it costs nothing to operate.
What the file should hold, item by item
A workable technical file contains the product description and photographs, the drawings, the bill of materials with the components that affect conformity identified, the harmonised standards applied with their version references, the test reports from an accredited laboratory, the risk assessment where the directive requires one, and a copy of the Declaration of Conformity.
It is a working document rather than an archive. When a market surveillance authority writes to your responsible person, the answer comes out of this file, and it has to be produced quickly. Building it after the letter arrives is how a routine enquiry turns into a suspension.
How to test a claim before you rely on it
Two checks separate a real file from a decorated one, and both take minutes. Look the laboratory up in the European accreditation database and confirm that its scope covers the test that was run. Then read the Declaration of Conformity against the directive list for your product category and see whether an applicable directive is simply absent.
A missing directive turns out to be more common than a forged report. Suppliers test what they are asked to test, and when nobody asks for RoHS or for the radio directive, the report is silent on both, and the silence reads like compliance until an authority asks.
Preguntas frecuentes
Is there such a thing as a CE certificate?
For most products, no. There is a Declaration of Conformity signed by the manufacturer, supported by test reports and a technical file. Notified Bodies do issue certificates for the categories that require them, and those certificates are EU type examination certificates, not CE certificates.
Can a Chinese factory legally sign the Declaration of Conformity?
The declaration must be signed by the manufacturer, which is the party placing the product on the EU market under its own identity. If the product carries your brand, you sign. A factory declaration is supporting evidence, not a substitute.
Do I need a Notified Body for an electrical product?
Not for a wired appliance covered by the Low Voltage and EMC Directives, where self-declaration against harmonised standards is the normal route. You need one for medical devices, category three protective equipment, pressure equipment, and radio products where the relevant harmonised standards are not applied in full.
How long must I keep the technical file?
Ten years from the date the last unit was placed on the market, and it must be available to authorities on request. Keeping it in a Chinese factory’s folder is not adequate if you are the manufacturer, because you are the party asked to produce it.
Does CE marking cover hazardous substances as well as safety?
Yes, through the RoHS Directive, which restricts ten substances and applies to most electrical and electronic equipment. Chemical restrictions outside electronics come from REACH, which is a separate regulation and applies even to products with no electronics at all.
Send us the product and the EU destination markets. We will confirm which directives apply, whether a Notified Body is genuinely required for your category, and what the file needs to contain before you sign anything. There is no charge for that review. You can see how we coordinate testing and factory documentation on our services page, or send the specification through the contact form. If you are also building a US file, the comparison of agent, trader and factory sets out who carries compliance responsibility in each buying model.
