• CE Marking When Importing From China: A Complete Guide

    Posted on 135 Comments

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    Importing products from China to the European Union? Depending on the product, importers are required to ensure full compliance with all relevant CE directives – a process that is far more complex than requesting a test report from your supplier.

    In this guide, we explain what you must know about CE marking as an importer:

    • What is CE Marking?
    • Documentation Requirements
    • Labeling Requirements
    • List of CE Marking Directives
    • Laboratory testing requirements

    We also answer frequently asked questions about CE marking:

    • Are non-EU companies and exporters required to comply with CE marking rules?
    • Which products must be CE Marked?
    • Must all products sold in the EU carry the CE mark?
    • Is the importer or manufacturer responsible for ensuring CE compliance?
    • What can happen if I importer non-CE compliant products?
    • Are all Chinese manufacturers able to produce CE compliant products?

    What is CE Marking?

    ‘CE marking” is not a product standard, but a conformity marking signaling compliance with all applicable EC directives. The specific directives and technical standards, differ depending on the product type.

    For example, electronic devices with a certain input voltage must comply with the Low Voltage Directive while finger paint must comply with EN 71 substance restrictions. While these products are very different, they must both carry the CE mark to signal compliance with all mandatory directives.

    As each EC directive regulates specific products, their scope of regulation varies. Some EC directives regulate substances, while others regulate energy efficiency and electrical safety. Some directives also cover product and packaging labeling, other than the CE mark itself.

    Product compliance requires more than a printed CE mark. You must ensure that the items comply with all technical standards and requirements, as outlined in the applicable EN and EC directives.

    Importing and selling non-compliant items in the EU is illegal, and may result in both a forced recall and major fines, assuming that the goods make it past the customs check in the first place.


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    Are non-EU companies and exporters required to comply with CE marking rules?

    CE marking is only required if you are either importing or exporting to an EU member state. CE marking is not required when selling into the United States, Australia or any other market.

    Previously, enforcement only targeted EU-based importers. That said, things are changing as the EU is flooded by non-compliant and unsafe products originating from cross border eCommerce companies.

    As a countermeasure, the EU has now implemented legislation forcing third party economic operators in the supply chain, such as freight forwarders and fulfillment centers, to check whether an importer or exporter has the relevant CE documents.

    As a result, CE compliance is therefore critical for both EU-based companies importing goods, and exporters selling to the EU – either as traditional B2B exporters or B2C cross-border eCommerce sellers.

    ce marking example

    Which products must be CE Marked?

    Some EC and EN directives only regulate specific products, but most are applicable to wider groups of products. We introduce the scopes of regulations for various directives further down in this article, but let’s begin by taking a look at the products categories for which CE marking is required.

    a. Electronics

    Essentially all electronic products are covered by one or more CE directives. Here are a few examples:

    • Battery powered devices
    • Cables
    • Power sockets
    • Power banks
    • Laptops
    • Tablet computers
    • Phones
    • Video game consoles
    • TVs and computer screens
    • Household electronics

    b. Toys

    • Soft toys
    • Finger paint
    • Electronic toys
    • Wooden toys
    • Plastic toys
    • Other children’s products

    c. Machinery

    • Machinery (general)
    • Non-automatic weighing instruments
    • Measuring instruments
    • Cableway installations designed to carry persons
    • Lifts
    • Personal protective equipment
    • Pressure equipment
    • Pyrotechnics

    d. Medical Devices

    • Active implantable medical devices
    • In vitro diagnostic medical devices
    • Medical laser devices

    e. Vehicles

    • Recreational craft
    • Bicycles
    • Electric bicycles

    f. Protective equipment

    • Helmets
    • Sunglasses

    g. Other Products

    • Cableway installations designed to carry persons
    • Equipment and protective systems intended for use in potentially explosive Atmospheres
    • Explosives for civil uses
    • Hot-water boilers
    • Noise emission in the environment
    • Simple pressure vessels

    Must all products sold in the EU carry the CE mark?

    Only products covered by one or more ‘CE directives’ should carry the CE mark. All other products should not be CE marked.

    Here are some products for which CE marking is not applicable:

    • Clothing
    • Home textiles
    • Non-electric kitchen utensils

    Is the importer or manufacturer responsible for ensuring CE compliance?

    When products are manufactured overseas, for example in China or Vietnam, the importer is responsible to ensure compliance with the applicable directive. This often comes as a surprise to European importers, as most EU authorities, and their websites, tend to refer to the “manufacturer” as the party responsible to ensure CE compliance.

    However, when items are manufactured overseas, the importer is considered being the ‘legal manufacturer’. Thus, the responsibility to ensure ‘CE compliance’ cannot be shifted to a Chinese manufacturer.

    What this means in practice is that the importer is responsible for the following:

    • Book lab testing
    • Create label files
    • Create the Declaration of Conformity
    • Create the technical file
    • Create the user manual

    Unsafe phone charger

    What can go wrong if I import non-CE compliant products?

    Importing non-CE compliant products to the EU is illegal and can result in fines, a forced recall or even persecution. Here are some scenarios:

    Customs Check: The customs authorities and hold, seize and destroy incoming shipments that are not correctly labelled, or in case the importer cannot provide the required documentation. In recent years, customs authorities also work closer with consumer safety authorities to keep track of certain high-risk product categories.

    National Consumer Safety Authorities: Each EU member state has its own government organizations tasked with implementing and enforcing compliance with EU directives. Here are some measures they take to check non-compliance:

    • Request DoC and test reports from importers
    • On-site inspections
    • Making purchases from eCommerce stores to test product samples
    • Investigate non-compliance reports from consumers

    Personal injury or property damage: While CE compliance can seem overly bureaucratic, these directives and standards are in place for a reason. Products, such as phone chargers or toys, that are not made in conformity with safety standards can be extremely unsafe. Importers are financially liable in case someone is injured or if property is damaged as a result of their non-compliant and unsafe products.

    Are all Chinese manufacturers able to produce CE compliant products?

    Short answer, no. It’s rather the opposite. In most industries, only 5 to 10% of the Chinese manufacturers are able to produce compliant goods. However, that is not saying that an entire factory can be “CE compliant”. CE marking only applies on a ‘product basis’.

    Therefore, even the manufacturers that can show previous compliance, such as previously issued test reports, does not always make ‘CE marked items’ by default.

    Thus, when selecting suppliers, we always look at ‘previous CE compliance’ in order to determine if the supplier has the technical expertise and manufacturing capability to manufacture compliant products. That said, this only serves as an indication of their technical capability.

    There is no such thing as “compliance by default”. Before you place an order, you must make your supplier aware of “your” compliance requirements. If Chinese manufacturers do anything “by default”, it’s manufacturing items that are non-compliant with any foreign standard whatsoever.

    But simply referring to “CE compliance” and assuming that the supplier will know exactly which directives and EN apply to their products is almost certain to result in severe compliance issues.

    You must confirm exactly which CE directives your products, and communicate this to the Chinese supplier. In order to verify compliance, you must also implement a testing and certification procedure. In most cases, importers cannot rely on ‘existing certification’, but must submit reference samples or prototypes to a testing company, before mass production.

    Documentation

    a. Declaration of Conformity (DoC)

    The Declaration of Conformity is a document issued by either the importer or the manufacturer, which includes the following information:

    • Product identification/SKU
    • Product features
    • Name and address of the manufacturer/importer
    • List of EN standards or directives
    • Location
    • Responsible individual

    The DoC is the primary document used to demonstrate compliance to government bodies, retailers and even end-consumers.

    b. Technical file

    In addition to the DoC, the  importer is also required to set up a technical file. This document regards the technical aspects of a product, combined with testing and quality control procedures and documents. Below follows an overview of the information the technical file shall at a minimum include:

    • Description of the items
    • Concept designs, drawings, wiring and circuit diagrams, component schemes, sub-assemblies, part lists, etc.,
    • List of standards applied in full or in part
    • Testing (in house or made by third parties) and quality control procedures
    • Test reports and quality control records
    • Marking and labeling copies
    • Risk assessment

    However, the specific information a technical file shall include is outlined in the applicable EN or EC directive. The technical file, unlike the Declaration of Conformity, must not be made public or shared with retailers, or direct customer. The importer is required to present the technical file, only if requested by EU or local authorities.

    Thus, the importer is legally required to obtain copies of the technical file from the Chinese manufacturer. But, as the technical file contains detailed product information such as circuit diagrams, virtually no suppliers are willing to hand it over prior to the buyer placing an order.

    As such, the only workable way to create a technical file is for you to create it entirely on your own. This is not an issue when concerning custom designed products, but technical files for private label products require a certain degree of reverse engineering.

    user manual

    c. User Manual

    You must create a user manual including the following information:

    1. Instructions on how to install the product

    2. An overview of the relevant parts and part names of the product

    3. Safety instructions

    4. Instructions on how to use the product

    5. instructions how to recharge and/or refill the product and

    6. Instructions on how to dispose of the product in an environmentally friendly manner

    d. Test report

    While the test report is part of the technical file, I also want to highlight that you cannot rely on test reports issued by the buyer. While lab testing is not mandatory for most products, it’s the only way to verify that a product is compliant.

    Further, test reports are ‘de facto’ mandatory in the sense that the customs authorities and national consumer market surveillance authorities often request test reports to verify if the product is compliant. They have the legal right to seize and order a recall for any product they deem unsafe.

    How do I get these documents from my supplier?

    You should not expect your supplier to provide or assist in the creation of the DoC, technical file or user manual. It’s your responsibility as an importer to ensure that the product is technically compliant and that all CE documents are in place.

    Manufacturers in China, Vietnam and elsewhere in Asia, are not product compliance experts and should not be expected to act as such.

    Can I use a test report issued by my supplier?

    Test reports issued in the name of the supplier can in some cases be accepted. That said, this is only the case if the test reports matches the following:

    • Product name/SKU
    • Manufacturer identity
    • Applicable directive/EN standard

    However, it’s extremely rare that a supplier can provide a complete set of verifiable test reports. In virtually all cases, the importer has no choice but to book a lab test.

    Labeling Requirements

    CE compliance label

    The CE mark is essentially a label demonstrating compliance with all mandatory EN standards or EC directives. On the other hand, products that are not regulated by such directives, shall not be CE marked.

    1. The CE mark shall be affixed to the product unit and its packaging and user instructions if any. This shall be done during production, by the manufacturer.

    2. You must create a CE label file (e.g. in .ai format) and submit it to your supplier, along with specifications detailing the print position and dimensions of the CE mark.

    3. The proportions of the CE mark itself shall also be according to the official layout set by the European Union, and a minimum diameter of 5 mm. That said, there are also exceptions. The CE mark shall also be permanent, so a sticker is not enough.

    List of CE Marking Directives

    As explained previously in this article, CE marking is meant to show compliance with all applicable EN or EC directives. Below follows an overview of directives applicable to electronics, machinery, and toys. However, keep in mind that this is not the full list of directives requiring CE marking.

    a. Low Voltage Directive (LVD)

    The Low Voltage Directive applies to electronics, and components, with an input, or output, ranging between 50 to 1000 volts AC, and 75 to 1500 volts DC. Thus, the Low Voltage Directive scope of regulations covers a wide range of products, including chargers, cables, home appliances, and socket outlets. However, LVD is not applicable to battery powered devices, and other electronics with an input, or output, that falls outside of the specified voltage range.

    b. Electromagnetic compatibility (EMC)

    The EMC Directive is applicable to fixed electronic appliances, such as LED displays. The purpose is to ensure that electrical equipment doesn’t interfere with other electronic devices, and signals, in its proximity. While it’s impossible to completely eliminate electromagnetic emittance, the EMC directive sets strict limits – which in turn depend on the type of product, its usage, and intended environment. ‘

    c. Machinery Directive (MD)

    The Machinery Directive is applicable to machinery, interchangeable equipment, and parts. The machinery directive primarily regulates mechanical properties and electrical safety, but also ropes, chains and other safety aspects of machinery. That said, motor vehicles and many types of consumer electronic appliances, are not regulated by the Machinery Directive.

    d. Toy Safety Directive (EN 71)

    EN 71 regulates toys and other children’s products. EN 71 not one single standard but divided into 13 different EN 71 standards. In most cases, more than one EN 71 standard is applicable. EN 71 regulates various aspects of toys and children’s products, including, but not limited to flammability, mechanical and physical properties, chemicals and heavy metals. In addition, EN 71 also stipulates requirements for graphical symbols (e.g., age warnings) and other labeling requirements.

    e. Radio Equipment Directive (RED)

    The Radio Equipment Directive (RED)  is applicable to radio and telecommunication equipment. The scope of regulations includes both final products and individual components. Therefore, products with radio, WiFi and Bluetooth transmitters and receivers are required to comply. This includes, but is not limited to, Android tablets, Smartphones and WiFi routers.

    f. Eco-Design Directive

    The Eco-design Directive was put in place to reduce greenhouse gases. As of today, more than 40 groups of products are covered by the Eco-design Directive, including light bulbs and domestic electrical appliances. The directive also applies to non-electrical products, including windows and insulation materials.

    g. Restriction of Hazardous Substances (RoHS 2)

    The RoHS directive restricts the amounts of certain substances in electronics, including lead, cadmium, and mercury. Starting in January 2013, RoHS is now part of the CE marking directive. Therefore, RoHS compliance is mandatory for all CE marked electrical items. However, there are a few exceptions.

    h. Personal Protective Equipment (PPE)

    The PPE directive is applicable to helmets, sunglasses, protective gloves, work shoes and other related products.

    Laboratory testing requirements

    While lab testing is not necessarily mandatory for most products within the scope of the various ‘CE marking directives’,  it’s the only way to verify that the product is compliant. Further, testing companies can also help you assess which standards and directives apply to a certain product.

    Here’s an overview of compliance testing companies that can help with ‘CE testing’:

    • Intertek
    • Bureau Veritas
    • TUV
    • SGS

    Note that the importer is expected to carry all testing costs, which can vary from a few hundred to tens of thousands of dollars.

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  • 135 Responses to “CE Marking When Importing From China: A Complete Guide

    1. corya at 12:43 pm

      Beware of fake CE certificate also as it is very usual and easy to make for chinese suppliers,
      because it is will cost several thousands USD to make real CE, many suppliers doesnt want spent that money for it and they prefer to take that costing at their own pocket if they think their profits from your order isnt much.

      Corya cheng@sterya Global

      1. Fredrik Grönkvist at 7:28 pm

        Hello Corya,

        Yes, that is a major issue. However, ensuring CE compliance is not always that expensive. The most important factor is the quality of the suppliers engineers.

        1. corya at 10:36 am

          yes, forgot to say the CE charges i mean for the electronic products such as for mobile phones, tablet etc which i know well.

        2. Miguel at 10:59 am

          Hello Fredrik,
          I’m currently negotiating some machinery (small industrial autoclave) from a Chinese company found through Alibaba and in the last step they asked for an additional USD 5000 to pay the CE certification. I was quite surprised for the price of one certification. Is this number near the average prices?
          Thanks

          1. Beth at 3:02 am

            This just happened to us. Finished order and was told we needed to pay for CE Certification. $3000.00. Shocked!

            Do we need to get a CE Certification on everything we ship?

            What does a CE Certification usually cost?
            Thanks,

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    3. Wal at 2:47 pm

      Hello,

      Is there a way, using the CE certification number, to check the organism that made conformity assessment procedure (website, database,…)?

      Thank you very much,

      Regards,

      Wal

      1. Fredrik Grönkvist at 3:04 am

        Hello Wal,

        The testing company is always listed on the certificate / test report. It shall also have an ID number, for the purpose of verification.

        1. Beth at 5:44 pm

          Hello Wal…we ran into the same thing. The items are ready to ship and we have been told it will be $3000 for CE Certification.
          Do we need a CE Certification on EVERY item we ship from China to the European countries?

          1. Fredrik Grönkvist at 7:27 am

            Hi Beth,

            No, you don’t need to test every batch, unless you change the design, materials or components.

    4. Beth at 3:00 am

      Hello Miguel…we ran into the same thing. The items are ready to ship and we have been told it will be $3000 for CE Certification.
      Do we need a CE Certification on EVERY item we ship from China to the European countries?

    5. Bassen at 1:55 am

      Hi All,

      – Is there a way on the Internet to show me according to the sector ..the Chinese companies that have CE or FCC ..so I csn go direct to deal with them ?

      – Another question ..an factory in Shenzhen I go to speak to them about certificate ..after negosiate ..they asked me to pay 4500RMB to got CE certificate within 5 days ..is this true ?

      Thanks ..waiting ur reply,
      Bassem

      1. Fredrik Grönkvist at 4:18 am

        Hi Bassen,

        No, don’t trust them. A supplier cannot simply buy a certificate.. well, they can, but it’s not legit, and the importer would still be held as responsible by the authorities in the target market. First of all, you need to verify if the supplier has any sort of previous experience manufacturing products in compliance with the relevant regulations. From then, you need to implement a strategy, which covers everything from third party testing to documentation. Unfortunately, there’s no easy way to do this, especially when buying electronics.

      2. Edward Cheng at 4:50 am

        It just mean that factory you dealing with are quote you the CE cert cost which is the average cost they are getting from the lab they work with. The biggest question is to prove the lab are quoting a legit DoC rather making a fake one. My experience told me alot factory not even know their lab are making fake DoC cert.

        1. ChinaImportal at 4:16 am

          The DoC is self-issued, so it cannot really be fake. However, the test reports can, of course, be faked.

          And yes, Edward is right. Many suppliers just don’t know anything about the CE Marking process, so they don’t understand they’re taken for a ride by some, less trustworthy, testing companies.

    6. kareem at 6:40 pm

      Hi All

      is there online way to make sure form validity of CE certificate to make sure that’s original ( not fake )

      the factory send to me a copy of his CE certificate i need to make check is certificate is real or fake ?

      Thanks
      Awaiting

      1. ChinaImportal at 3:50 am

        Hi Kareem,

        That depends. If we are talking about a test report or other document issued by a third party (i.e., SGS), then yes. You can contact them to get it verified. However, things get more complex when it comes to documents issued by the supplier. Notice that CE marking compliance requires much more than just a certificate. At a minimum, the following is required:

        1. Declaration of Conformity
        2. Test Reports
        3. Circuit Diagram
        4. Bill of Materials / Component List
        5. Risk Analysis
        6. List of applied standards
        7. Instructions Manual
        8. Labels

    7. Mihai at 4:46 pm

      Hello all,

      I would like to know if is required to have CE mark and declaration of conformity and technical file/testing etc.. for the items that are designed for cars. Ex: Led bars, bulbs,.. the input/output is maximum 30V So I would assume is not needed.

      kindly advise on this matter.

      Best regards,

      Mihai

      1. ChinaImportal at 4:21 am

        Hi Mihai,

        LVD is not applicable. However, RoHS and the EMC directive is still so. R&TTE may also apply.

    8. Don123 at 8:17 pm

      Hi all,

      when importing wrist watches from China, is it necessary to have CE marking on them?
      What needs to be done?

      Thanks in advance :)

      1. ChinaImportal at 5:42 am

        Hi Don,

        Yes, RoHS applies to watches. Hence, CE marking is mandatory. However, we see that many small (EU based) brands still neglect this. Big brands, on the other hand, are better at this.

        1. Don123 at 6:59 pm

          Hi,

          thanks for the answer! For a Quartz watch – does EMV apply as well or can this be neglected? If so, why?

          1. Don123 at 7:24 pm

            I meant Electromagnetic compatibility (EMC). Is that not applciable to wrist watches as well?

            1. ChinaImportal at 5:30 am

              It is, but testing is not mandatory

          2. ChinaImportal at 5:30 am

            Hi Don,

            As the EM signature of a watch is so low, testing is normally not required. However, you would still need to issue a Declaration of Conformity, based on our understanding.

            1. Javier at 12:02 pm

              Hello Fredrik,

              So to sum up, quartz watches should be CE marked but RoHS testing is not required by law, correct? Assuming the purchased movement is RoHS compliant like Miyota movements.

              Is any test documentation needed or just the declaration of conformity?

              Thank you.

            2. Fredrik Gronkvist at 10:10 am

              Hi Javier,

              All electronic components, including quartz movements, must be RoHS compliant. RoHS also requires the CE mark, which is why quartz watches must be CE compliant and labelled.

              But, as you say, Japanese and Swiss movement manufacturers, including Miyota, already make RoHS compliant movements. Thus, I don’t think a RoHS lab test for the movement is necessary.

    9. Enamul Kadir at 2:23 pm

      Which EN Directive is applicable for Submersible Motor-Pump Set for Irrigation Purpose. Actually I want to know the difference in between Declaration of Conformity, CE Certificate & CE Verification of Compliance certificate.

      1. ChinaImportal at 5:34 am

        Hi Enamul,

        Machinery Directive, LVD and EMC should all apply, and RoHS (for electrical components). For the documents, I suggest you read this article: https://www.chinaimportal.com/blog/ce-marking-testing-certification-when-buying-from-china/

    10. Marco at 8:44 pm

      Hello , I have a different question.
      I am about to import 5 machines from China to the UK and resell them to a customer in Sweden.
      I have advised the customer they are not CE marked and my customer said they will get
      the CE mark them self. What is the correct thing to do in this case? Thank you

      1. ChinaImportal at 5:21 am

        Hi Marco,

        As you are the importer, you could be held liable if your import a product without the proper documentation. This sounds very risky.

        Compliance requires a lot more than just the CE mark.

    11. Otto at 5:10 pm

      Hello.
      I would to to order some electric bike or electric scooter from China…but my supplier hasn’t got a Ce certificate. My question is Can I sell this product in UK without that?What is the worst things to happening to me If I sell this items without that Ce certificate?

      1. ChinaImportal at 4:20 am

        Hi Otto,

        No, you cannot. The worst thing? Depends on how creative we get. However, at a minimum, the products will be seized by the customs authorities. This means you’ll lose the products, and you will also be fined.

        If it turns out later on that you lack the certification and other documentation, the same thing will happen.

        But the worst would be if your products injure someone or damage property. Non-compliant lithium batteries are fire hazards, and there were several house fires caused by such batteries in the UK, last year.

        You will be liable for all injuries and property damages caused by your illegal products. This can amount to tens of millions of pounds, and jail time.

    12. Fabian at 3:34 pm

      Nice guide on a complex subject. Thanks for sharing!

    13. Sreeni at 11:17 am

      Hi,
      I want to import a roasting machine into UK, the machine does not have a CE certification. I do not intend to re-sell, it’s just for use in our factory. Do I still get it CE certified?

      Thanks.

    14. Sid at 12:57 pm

      Hi There
      Do non electrical items need any sorts of certificate?
      For example- phone covers, car phone holders, bike pedal etc. that made out of plastic. Thanks.

      1. ChinaImportal at 4:30 am

        Hi Sid,

        Yes, there are regulations that apply to non-electrical products. For example, this includes REACH.

    15. Alex at 12:20 am

      Hi there,

      I’m very confused and wondering if anyone could help me. I am planning to import welding rods from a supplier in China. I asked for CE certificates and was told that they dont have these but instead have Lloyds Register, a notified body. Can I still import these items to the UK and sell on the market or do they still need the CE marking and certification?

      Thanks,
      Alex

      1. ChinaImportal at 4:30 am

        Hi Alex,

        You need to pay a consultant to find out which regulations apply to this specific product.

    16. Joe at 4:32 pm

      Hi,
      I work in China 9 months of the year and own a Morakot electric bike (e-bike) that I bought for £300 ($450) for daily use in the Chinese city I live and work in. I’d like to import this e-bike into the UK at the end of my contract for personal use. Do you think this is a possibility? Are e-bikes difficult to get CE approved? Would it cost a vast sum of money to import it?
      Regards

      Joe

      1. ChinaImportal at 4:26 am

        Hi Joe,

        The procedure is very expensive. You would need to spend at least 20 k USD on consultants and testing to get this through.. and as it’s not made for the EU market, the chance of failure is probably no less than 99.9%

    17. MarlonDr at 7:08 pm

      Very interesting subject, thank you for the thread chinaimportal. Quite helpful in understanding this tricky subject

    18. Sarah at 5:59 pm

      Hello, I have recently bought some kids superhero capes from China that are not CE marked. In my opinion they will be flammable and therefore surely not pass any such testing – would a ‘Warning – fire hazard’ label suffice? Or do I need to get them tested? How much are we talking if i sent them to a lab versus testing myself at home?

      1. ChinaImportal at 10:17 am

        Hi Sarah,

        No, that is illegal. A Warning label is not a shortcut that enables you to sell a dangerous product.

        It’s not just about “getting them tested”. The products must be manufactured according to the right EN standards… which yours are not.

        You must also create all the mandatory documentation.

    19. Sylvia Ley at 10:01 pm

      Hi,
      I am hoping you will be able to help. I imported a shipment of herb cutting scissors from China to Italy. Italy customs is withholding the shipment and asking us to produce a CE Conformity Declaration letter. We have already provided food safety reports under EC guidelines but customs will not release without the CE Conformity letter. Our manufacturer has contacted testing agencies and they are unable to provide or provide CE testing because under their guidelines, CE conformity is not required for herb scissors. Do you know if such is true? If not, is there an agency that I can contact that will be able to help? Thank you in advance for any assistance or guidance that you can provide.

      Best Regards,
      Sylvia

      1. ChinaImportal at 2:08 am

        Hello Sylvia,

        This is very strange. As far as we know, CE is not applicable to this product, and therefore they should not request such documents.

        However, a Declaration of Conformity is mandatory for food contact materials, so maybe this is what they are actually asking for?

    20. Maisam at 10:55 pm

      Hi, i would like to import hoverboards from China to Belgium.
      Which certificates do I need?

      1. Maisam at 10:56 pm

        *electrical self balancing hoverboards

      2. ChinaImportal at 3:34 am

        You should avoid that, given the extreme risks. There are too many regulations to be listed here.

    21. Thanos at 12:13 pm

      Hello.

      Your guide is simply fantastic and covers almost every aspect of importing which took me several hours and a lot of websites to collect the same level of info!

      I want to import disposable latex gloves in Greece(Europe). Through searching on the web I found out that they fall under the PPE Category 1 IF I am not mistaken. Am I right?

      In addition the factories that I have contacted through Alibaba have told me that they have CE certificate.I am thinking of having SGS to test their product for me.But my question is if the factory give them an “approved-good” sample to test positive and then my batch is of lesser quality,what happens then.Is this scenario even possible or am I looking too much into this?

      Best Regards and please keep up the good work!

      1. ChinaImportal at 1:51 am

        Hi Thanos,

        Yes, latex gloves should fall under PPE, but I cannot confirm the class.

        Notice that this most likely depends whether or not the gloves are used for commercial or home use.

        As for compliance.. they may pass a test, but you still need a technical file. If you need assistance with this, I suggest you submit a free enquiry on http://www.compliancegate.com

    22. Xinglin Xu at 12:46 am

      Hello,

      I am planning to import prefab module for hotels to Iceland from China. I’m contacting two factories and both of them provided me ce certificates, which look rather different. One certificate doesn’t have “CE” marking, but it can be verified on sgs website.

      I have read through this blog and you said it could require much more than a CE certificate to prove that all products are in compliance. What document could customs/authorities require? A Technical file as mentioned in this blog?

      1. ChinaImportal at 1:49 am

        Hello Xinglin,

        Yes, you need a lot more than just a CE certificate (DoC). The technical file includes, at a minimum, the following:

        1. Design drawings

        2. Risk assessment

        3. List of applicable standards

        4. Test report/s

        5. Declaration of Conformity

        6. Component list / Bill of materials

        7. Copies of packaging artwork, labels and manuals

        Without all of this, the product cannot be imported and sold legally

    23. VS at 12:18 pm

      I am planning of importing LED light Bulbs from China to supply retailers in the UK.
      Do I need to print a post code or address on the rear of the retail packing or just a email address is enough.

      1. ChinaImportal at 3:25 am

        Not 100% sure about this, but I think a Batch ID, company name and address is required. All CE products must be tractable.

    24. Johnson mudzingwa at 7:04 pm

      Am looking for a company which produces SURGI PLUS brand of disposable medical products can I indentify it using CE number or their iso certification.

    25. Emelia at 8:05 am

      Hi, I have imported an HIFU machine thru Alibaba, however when machine arrived it wasnt the same model and has no markings or labels showing CE or model number. I have opened up a dispute and now the true colours of this Supplier comes thru with them making false statements etc. I requested the CE conformity form and when I verified it on the ENC website there is a different company and models that come up under that reg number. Alibaba has requested I pay for a third party investigation. Now what is my recourse? How can Alibaba allow scammers like these on their site! Im so stressed and have seen on social media how Alibaba seems to side with the Sellers. Please Advise?

      1. ChinaImportal at 3:39 am

        Hello Emelia,

        Unless you specified in a written contract (not email), that the machines must comply with a certain directive (i.e., Machine Directive), then there is no recourse.

        This could also have been discovered during a quality check, before the shipment.

    26. duncan at 1:01 am

      Firstly, great site. Secondly I wonder if you can help.

      I am looking to import into the EU. The product is Mirrors with LED’s on them (battery powered). From my reading of your above content, that looks like to me I require ROHS certification.

      Is this correct or have I got this wrong?

      Thanks in advance for your help

      Duncan

      1. ChinaImportal at 2:51 am

        Hello Duncan,

        RoHS is one directive that you must comply with. You must also comply with the EMC directive, even though it’s more of a formality when it comes to battery powered products.

        That said, it still affects the documents you must issue.

    27. Kam at 5:14 pm

      Hello. Please who knows how can i take a certificate of conformity of mi 5s . Online xiaomi team didnt help

      1. ChinaImportal at 8:30 am

        Probably because they have none. As far as I know, Xiaomi has never officially launched in the EU. Hence, they have no EU compliance documents.

    28. wahab sheikh at 4:23 pm

      hello i am wahab

      i am buying a duplicated copy of a bike from a seller in guangdong china.
      what are the necessary documents that i should ask them to ensure my conformity so that i am not frauded.

      is there any way to check whether the business company is authentic and real or just a fake business???

      please friends help me and tell me the basic points that i should take care of while purchasing and doing payment to them.

    29. Alex at 8:22 pm

      Hi, I am looking at dropshipping an array of consumer electronics to EU and US consumers.
      Will these need to be marked CE considering I am not importing them, as they are addressed to the customer?
      Also what are the requirements for battery items such as iphone case chargers, as you mentioned these were not included in the LVD?
      I would be very grateful for a reply, this article has been very helpful indeed!

      1. ChinaImportal at 5:31 am

        Hi Alex,

        Yes, technically dropshipping makes the customer the importer, but the authorities will go after you – not the customers.

        This is extremely risky, as the products sold on various dropshipping sites rarely, if ever, are made in compliance with EU regulations.

        For charges, I’d say that LVD, EMC and RoHS apply – but additional standards may be added or already be applicable.

    30. Si lwli cymru at 10:52 pm

      Helo we are a new company developing a musical plush toy for sale in EU.

      The site mentions obligations on the factory as manufacturer to comply with safety testing and for importer to conduct spot testing.

      What does spot testing mean here? We are going to conduct all required tests as we need to cover ourselves for customs and import purposes. We are going to conduct the tests on pre production samples only. Will this satisfy spot check requirements and if not, what is the requirements re spot checks? We don’t have the money to pay £3k a go on every 100th product etc.! Thanks in advance your website is very helpful.

      1. ChinaImportal at 5:24 am

        Hi there,

        That probably refers to testing on samples collected from the batch, on a regular basis.

        The purpose is to ensure that the products are actually compliant, and that importers don’t test a pre-production sample that is made to be compliant, while the real product is not.

        I don’t think you need to check every 100th product, but maybe every or every 2nd batch.

        Compliance testing is expensive, and this is a cost that must be passed down to the consumer.

    31. Cyril at 12:37 pm

      Hello,
      We will import a machine in Europe, from China. We made some modification on the model that the factory makes, so they asked to us to pay to pass the CE and ROHS. Which is normal.
      But my question is simple : i made a quotation to SGS, and the price for CE and ROHS is 3 times higher than the Lab that my manufacturer gave to us. Should i be very worried about the chinese lab? My contact who work for me in China, called the lab, and will go to visit them next week.. but i still wondering about the difference of the price. Thanks a lot

    32. Ade at 11:26 am

      Hi,

      First, thanks for this great website! I had no idea CE marking was such an impediment to importing… so my eyes have been opened…

      I do have a question: I’ve been looking at importing a small diesel engine from China, to use in a generator set which I will build myself. I’ve hunted high & low, but I can’t find any mention of engines in the various CE categories – lots of mentions of engine-driven machinery… but not the motor itself.

      Can anyone tell me if I need a CE certificate for a small water-cooled diesel engine?

      Does the fact I intend to import it for my own personal use, and not for resale, make any difference?

      Thanks!
      Ade.

      1. ChinaImportal at 6:08 am

        I think that the Machine Directive may apply

    33. Danny at 4:50 am

      Hi,

      I am producing a new product which uses existing products with a frame around it:
      Tablet
      LED sensor
      LED strips
      Glass

      Slightly modified to function together. The individual components are CE certified. What type of cost would I be looking at to get this CE certified?

      Thank you! Amazing article, i’ve bookmarked it and will refer back to it often.

      1. ChinaImportal at 6:07 am

        That depends. If you only refer to lab testing, you might get away with a few thousand dollars in compliance costs. If you want to hire a consultant to assess all applicable regulations, create all the documents etc in the technical file, it’s counted in the tens of thousands.

        As a startup, you need to learn the process yourself.

    34. Danny at 4:53 am

      And would it perhaps be an idea to ship the CE certified components seperate and assemble it in the EU. Or does this not make any difference?

      1. ChinaImportal at 6:06 am

        Hi Danny,

        It makes no difference in the sense that you must still create a technical file and label the product

    35. Jamie at 3:18 pm

      I want to import a pedal car into the uk. Do I need a CE certificate for this?
      Thanks

      1. ChinaImportal at 9:16 am

        Hi Jamie,

        What kind of pedal car?

    36. Jamie at 12:24 pm

      It’s an adult pedal car with a steel chassis and a fibreglass frame. It seats 4 adults and I plan to start a business hiring them out.
      Thanks,
      Jamie

    37. Raquel at 3:02 am

      Hi all,
      We need to supply to our Italian Buyer a Tablet (Android System) but we have an issue about the Certification but accdg. our buyer in Italy (Importer) all the CE certificates issue from official Chinese Testing Company(i.e. SGS / TUV / INTERTEK) are not recognized by the European Community and or the customs authority unless validated from a company listed on in the “NANDO” Database of the European Commission (http://ec.europa.eu/growth/tools-databases/nando/index.cfm?fuseaction=notifiedbody.main)
      We would to receive your comments and suggestions , because in our opinion this is a sort of
      dumping or blocking the international free trade agreement.
      Thanks in advance for your kind time in reading.

      1. ChinaImportal at 7:24 am

        Hi Raquel,

        No, enforcing product safety standards is in no way dumping or blocking any free trade agreements. Further, there is no free trade agreement between China and the EU.

        This is a way to reduce the number of dangerous and low quality goods from Asia, to western markets.

      2. ChinaImportal at 7:24 am

        One more thing: SGS, TUV and Intertek are European, not Chinese – and their documents are valid in the EU.

    38. Joshua at 3:36 am

      Hey,
      There is a business selling Chinese rip off macbook chargers, they have the complacence mark but they do not have the manufactures name on them, They also are not very safe, often breaking after and month and cause battery damage to the computer that are used. The second you plug one of these into your mac it voides the warranty of your computer. The original chargers have a microprocessor that turns it off and on many times a second to create the correct voltage while these knock offs dont, causing all the electrical energy to be converted into heat, making them extremely hot.
      Is there anyway i can dob them in?

    39. Diogo at 5:12 pm

      I live in Portugal and was sold a smartphone by a company in spain that doesn’t have CE, what can I do?

    40. Paulina at 2:02 pm

      Hi,

      I am interested in selling humidifiers from China in Europe. The product has got a CE Mark and comes with Verification of Conformity ( EMC Directive and EMC Standards). It also comes with an adaptor that has CE Marking, EMC Certificate, LVD Certificate and is TUV Tested.

      Do you think this is enough to sell legally? I’d really appreciate your help. I have been in touch with the UK Government but they said they can’t help.

      1. Fredrik Gronkvist at 12:40 pm

        Hi Paulina,

        No, it’s not enough. You need a technical file i addition to the DoC

    41. Mladen at 12:08 pm

      Dear!
      I want to import homebrew equipment from China to Croatia.
      Because of the specificity of the program, I would need smaller quantities of different items.
      (Stainless pots, stainless ball valves, fittings, quick disconnects, silicone tubes, malt mills etc.)
      According to my knowledge a large number of items are in the field of good engineering practice ..
      If I do not need a CE mark, do I need some other documents?
      Every suggestion is welcome..

      1. Fredrik Gronkvist at 8:58 am

        Hi Mladen,

        Not sure if CE is even applicable for homebrewing equipment.. but other EU regulations may be

    42. Rob at 3:49 pm

      Hi Fredrik,

      Thank you for the very informative video. I am not 100% sure whether we would be responsible for applying for the CE mark so I thought I would ask.

      We are wanting to sell micro routers which are made in China. They are already sold directly by the manufacturer in the EU and they have a CE mark on them. We are wanting to buy some of the routers and then re-sell them with our logo on. Would we need to apply for a new CE mark or could we use the same one as the manufacturer?
      If we are able to use the same one as the manufacturer would we need to hold a copy of the certification and technical file?

      Many thanks

      Rob :-)

      1. Fredrik Gronkvist at 11:38 am

        Hi Rob,

        It’s always the importer that is responsible for ensuring that the product is compliant.

        And yes, CE marking documents (DoC etc) are issued by the importer. Hence, you must issue these documents even if there are similar products on the market

        Further, there is no application involved

    43. Richard at 6:46 am

      if i am buy a special machine for my own use, do i need to show CE to the custom?

      1. Fredrik Gronkvist at 7:30 am

        Hi Richard,

        Yes, if it’s an electronic machine, imported to the UK or other EU state.

    44. Tibor at 11:45 pm

      Hi Frederik,

      Could you please tell me if a gas deep fryer from China required a CE certificate in UK?

      Thank you in advance,
      Tibor

      1. Fredrik Gronkvist at 8:23 am

        Hi Tibor,

        Yes, that should fall under CE, as gas appliances are covered.

    45. Tee at 9:54 pm

      Hi I would like to sell partyware and import all goods from China. I live in the UK, what regulations if any do I need to follow.

      1. Fredrik Gronkvist at 10:54 am

        Hi Tee,

        That depends. Are these partyware products for adults or children?

    46. Bally at 10:11 pm

      Hello, your site has been so useful!!!

      I read on the government site ‘products intended for use for educational purposes in schools and other pedagogical contexts under the surveillance of an adult instructor, such as science equipment. ‘ are not required to have CE marked is this true?

      Does this cover all educational resources as long as it’s for teaching for example flash cards, pretend play costumes, puzzles etc ??

      1. Fredrik Gronkvist at 10:53 am

        Hi Bally,

        Not sure about costumes, but I am quite certain that puzzles, cards and so on must be CE marked.

        Do you have a link to that government website?

    47. Will at 12:29 pm

      Hi Fredrik,
      Thank you for your great, and informative blog!
      I’m trying to import HIFU machines for aesthetic treatment to Argentina. How can I be sure that CE certificate is the right in case I pay for it, and what do you recommend to get an international electric security certificate; I want to know if paying for a TUV certificate from China will be right?
      Best regads,
      Will

      1. Fredrik Gronkvist at 11:15 am

        Hi Will,

        CE marking is only applicable in the EU., not in Argentina.

        You need to research regulations in Argentina.

    48. Ario at 9:20 am

      hello all,

      I got a question…

      In the new EU regulations it is mandatory that products which are purchased and sold have the name of the manufacturer on the the product.

      Is it possible to buy a product from china without placing the name of the manufacturer on the product

      1. Fredrik Gronkvist at 11:13 am

        Hi Ario,

        Which regulation are you referring to?

    49. Stan at 5:12 pm

      Great blog Frederik! and Appreciate the time & effort you put in…

      Quick question on a response received from a Manufacturer/Trader in China saying “Product don’t have CE certificate, but have CE mark on window box. We have 7P, EN71, EN62115, ASTM certificate.” This is for a Qty of toys I ordered. Are the above mentioned certifications enough or we still need the CE certificate to import to the UK/EU?

      Thanks again!

      1. Fredrik Gronkvist at 11:37 am

        Hi Stan,

        Chinese suppliers don’t know how CE works (and it’s not their job to know).

        Yes, for toys, EN 71 is mandatory. This means you need a DoC, Technical file and CE mark on the products.

        The product must also be lab tested.

        Again, I warn you. Do not take compliance advice from a supplier. They don’t know how these things work.

    50. Gilles at 12:02 pm

      Hi

      Does the CE certificate supplier have to be located in the EU? Can I contact a certificate supplier from India for instance?

      Thank you!

      1. Fredrik Gronkvist at 11:56 am

        Hi Gilles,

        A supplier cannot be CE certified. CE compliance is on a product basis.

        CE can be applied to products regardless of where the manufacturer is located.

        Take the iPhone for example. CE compliant, and manufactured in China.

        1. Gilles at 3:40 pm

          Hi Fredrik

          Sorry, I was unclear. What I meant was: can I hire someone in India to test the product, write the technical files and DoC when my company is based in Belgium and I’m importing from China?

          As a start-up, we cannot afford hourly wages in our our country unfortunately.

          Best regards,
          Gilles

          1. Fredrik Gronkvist at 1:04 pm

            Hi Gilles,

            Sure, SGS and Intertek etc have offices in India. That said, they will quote you more or less the same price, regardless of which office you contact

            There are no cheap consultants in India, or elsewhere, that can do it for less

    51. Erik at 9:57 am

      Hi Fredrik,

      We were going to test like many others to import quartz watches from China to sell in Europe. We will use the manufacturer in China’s design and make only minor changes. If I understand correctly, we need to meet RoHS and EMC requirements. The product we are importing meets these requirements according to the manufacturer.

      My question then is if I can use their lab tests or possibly get the information directly from Citizen Miyota who makes movement as a basis in the technical file? The case is not made of stainless steel so it’s just the movement that needs to follow RoHS and EMC?

      Thanks

      1. Ivan Malloci at 4:58 am

        Hello Erik,

        the whole watch shall be compliant; however it’s true that RoHS only concern electronics components. Note that if you buy a Miyota movement, it shall already be compliant!

        Also, I suggest you to have a look at our new case study, where we described how one of our clients was able to successfully import watches from China: https://www.chinaimportal.com/blog/launching-watch-brand-on-kickstarter/

    52. Mike at 6:51 am

      Great article. I have been buried thick of in EU documents relating to CE trying to establish if USB cables without a plug need CE markings. It is very confusing they aren’t electronic equipment but could be considered a component. Any ideas?

      1. Ivan Malloci at 4:51 am

        Hello Mike,

        we would need to do additional researches to be 100% sure, however this is my take on this:

        1. A USB cable contains electronics components, as such it must probably comply at least with the RoHS Directive, which is part of CE framework.

        2. Now, the CE framework says that the CE mark shall be put on the product if there is enough space; while if there is not enough space it can go on the instructions / package. I think that’s the reason for which USB cables usually don’t show the CE mark!

        1. Mike at 5:05 pm

          Thanks Ivan, I have researched and can only find reference to wires and cabling that is installed permanently should be marked CE if it is included with an electronic device there is no need for a separate mark on the cable as far as I can see I will keep digging.

    53. Brian OConnor at 3:26 pm

      Hi, I am pricing a steel roof roll forming machine in China into the EU, what should i look for in regards to CE marking ? and EU conformity requirements ?

      1. Fredrik Gronkvist at 1:20 pm

        Hi Brian,

        Yes, in that case compliance with the Machinery Directive, and possibly also LVD and RoHS, mandatory.

    54. Sali at 6:08 pm

      Hello. We are importing from China to Europe tha lithion batteries. The provider has sent us the certificates. But the problem that we see that in the certificates do not appear the exact models. For example, for a battery of a tablet model 143AA, another model is specified and not the exact model 143AA. in this case should appear more than 100 different models that we normally bought and that it is a lot of money to certify them. I guess that’s why they do not do CE for all models. And the second problem that I see that when they manufacture batteries change the type of cells they use, so even if they have certificates if they change a component, it is supposed to no longer correspond and when someone does the research, this certificate would not be valid. I mean if they change some component for another inside the ceritificate is not valid

    55. David at 9:32 pm

      Hi,

      Great article! I’m looking at some gateways and controllers for light. The manufacturer has Certificate of RED Compliance on them, does that cover the EMC, LVD and RoHS directive?

      Also they have signed a DoC document, can I then sell theyre products in EU without the technical files?

      1. Ivan Malloci at 1:59 pm

        Dear David, RED shall cover EMC and LVD. However, in order to make a better assessment we would need to need more about your product, and do a more in depth research. Note that such assessment is included in our premium services: http://www.chinaimportal.com/electronics

      2. Fredrik Gronkvist at 6:47 pm

        Hi David,

        No, you need a technical file, user manual and valid test reports. A DoC is not a substitute for this.

    56. Daniel at 8:49 pm

      Hi,

      We are due to import from China into Europe diamond cutting discs (for stone, marble, granite, etc) . Is it enough to be comply with the Machinery Directive or we need some other directives compliance measures?
      Thank you

    57. Kenny Neth at 9:30 pm

      Hi,

      I have just purchased some B22 LED light bulbs from China. They are marked HaoTianCheng and have CE and ROHS 03 printed on the plastic base of the bulbs. I am frightened to use them as friends have told me they can catch fire.
      Do you know if they can be trusted and the markings are authentic?
      Thank you

      1. Fredrik Gronkvist at 7:10 pm

        Hi Kenny,

        The markings are just markings. Black ink printed on the LED bulb, and nothing else. A print doesn’t make the product magically become compliant, which you surely know.

        Now, are the products technically compliant with LVD and other directives? Only a lab assessment can tell.

    58. Faraz at 9:50 pm

      Hi

      I am looking to import a backpack with a USB port from China into UK.
      The backpack is nylon material, the USB is only 5V.
      What do I need to get from the supplier?
      Am I right in saying 1) Declaration of Conformity 2) Technical file
      In the Declaration it would be specified that the product is REACH and RoHS complaint?
      Would this product require CE mark even though the voltage is below the threshold?
      If yes then where should the CE mark be? on the USB itself or just the packaging?
      Other than the CE mark, is there any CE document that is required to be produced or is it just mentioned in the Declaration of Conformity?
      Thanks very much

      1. Fredrik Gronkvist at 8:05 pm

        Hi Faraz,

        The DoC is issued by you as an importer. You can request a free quote for CE compliance consulting here: https://www.chinaimportal.com/compliance-consulting/

    59. Iacovos at 2:36 am

      Hi Fredrik,
      Thank you for the informative article.
      I would like to ask if a CE certification is needed when importing windows (aluminium frame & glass) as complete units for personal use (not for selling).
      If not needed please advise what is the usual steps to be taken to prove these are for personal use.
      If needed please kindly advise if frame & glass need separate certification or are they to be certified as a unit?
      Thanks.
      Iacovos.

      1. Ivan Malloci at 12:22 pm

        Hi there,

        first of all, we can’t make such an assessment replying to a comment, as this would more specific information about your product etc. However, I can still provide some advice:

        – It doesn’t matter if you are importing for reselling of for personal use. The importer is still responsible to make sure any imported product is compliant with EU regulations

        – Windows will probably follow under the CE Directive on Construction products (CPD/CPR). However, as said, we can’t do such an assessment and we recommend you to gether more information

    60. Natali at 5:28 pm

      Thank you for your work! I need your help! Have a plan to import an rotating stand (electric) for an artificial Christmas tree from China to Poland. The manufacturer does not have a CE certificate, but he provided me with an VDE certificate for the plug (part of the stand). Is this enough for import to Poland? Thank you in advance

      1. Fredrik Gronkvist at 8:21 pm

        Hi Natali,

        No, I don’t think that’s sufficient.

    61. Narisson at 10:49 am

      Hi Fredrik, thanks for the information that you have provided. I want to import commercial cooking appliance from China to Australia. The manufacturer said they don’t have any CE approval. If i import one product and pay for the lab testing here in Australia and receive the CE certification for this product, can other importer import the same product and use it in Australia? If i own the CE certificate will i be the sole distributor of the product in Australia? What benefit will I get if i own the CE approval for the product? How do i convince the Manufacturer to provide the documents needed for the approval?

      1. Fredrik Gronkvist at 7:45 pm

        Hi Narisson,

        CE is only relevant in the EU, not in Australia. You need to get the product tested according to Australian safety standards.

    62. Giovanni at 2:15 am

      Hi,
      I am planning to import industrial vision cameras from China to Italy, they will be used as components of a vision system which I am developing, and for which I will write a technical file, DoC etc. in order to put the CE marking.
      But the cameras only have chinese certificates, so my question is: should I issue a DoC also for the cameras to be able to import them, even if I am going to write a DoC for the complete system?
      And if this is the case, could I at least import one sample camera for evaluation, or should I write a Doc before having seen even the very first one?
      Thanks
      Giovanni

      1. Fredrik Gronkvist at 10:37 pm

        Hi Giovanni,

        1. You will need the DoC, manual, technical file and test reports. Chinese product standards and certification is not valid in the EU.

        2. It should be okay to buy samples without the compliance documents but you better check with your forwarder

    63. Job at 5:02 am

      Fishing rods and reels don’t appear to require CE Certification?

      1. Fredrik Gronkvist at 2:01 pm

        Hi Job,

        I cannot confirm anything without researching the product first

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