Your EU partner for CE marking, certification & compliance

CE marking for Chinese manufacturers and sellers

Many CE-marked products sold in the EU are made in China, and Chinese laboratories test a large share of them. What often fails is the paperwork around the product: the EU contact, the Declaration of Conformity and certificates that do not mean what sellers think.

Article 4, Regulation (EU) 2019/1020 EU-established operator Lab certificate ≠ DoC CCC is not CE

An EU economic operator is required

For products under most CE marking legislation - including the Low Voltage, EMC and Radio Equipment Directives, machinery, toys, PPE and RoHS - Article 4 of Regulation (EU) 2019/1020 requires an economic operator established in the EU: an EU manufacturer, an importer, an authorised representative with a written mandate, or - only where none of these exists - a fulfilment service provider. Its name and contact details must be on the product, its packaging, the parcel or an accompanying document.

A Chinese seller shipping directly to EU customers through a marketplace usually has no EU importer, so it appoints an authorised representative.

Certificates that are not what they seem

DocumentWhat it actually is
"CE certificate" from a testing laboratoryA voluntary statement by the lab. It is not a Notified Body certificate and does not replace the manufacturer's DoC.
Test reportUseful evidence for the technical file, if it covers the product as sold and current standards.
CCC certificateChinese compulsory certification. It has no effect in the EU.
EU Declaration of ConformityThe legal document. Signed by the manufacturer.
Notified Body certificateValid only if the body appears in NANDO for that legislation and procedure.

What to prepare

1

Check scope

Identify every applicable act, not just the one the lab tested for.

2

Technical file

Test reports for the exact model, risk assessment, drawings - see the checklist.

3

DoC and label

Correct legal references, model numbers, manufacturer and EU operator details.

4

EU operator

An importer or authorised representative who can answer authorities.

Frequently asked questions

Can a Chinese company sign the EU Declaration of Conformity?

Yes. The manufacturer signs the DoC wherever it is based. What a non-EU manufacturer cannot do is act as the EU economic operator required by Article 4 of Regulation (EU) 2019/1020.

Is a lab's CE certificate enough for Amazon?

Usually not. Amazon and authorities ask for the EU Declaration of Conformity and supporting evidence. A lab's certificate is not a substitute for the DoC.

Are test reports from Chinese laboratories accepted in the EU?

There is no rule against them. What matters is that the tests cover the product as sold, against the right harmonised standards, and are credible.

Related guides

Note: This guide provides general information about EU product legislation, not legal advice. Check the current legal texts on EUR-Lex for your product. Last reviewed 5 October 2026.

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