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Six steps to CE marking for goods sold within the EU

What is the CE mark?

The CE mark is a symbol that a manufacturer (see definition below) affixes to a product so that it can be sold in Europe. The mark is mandatory for products which fall under one of 24 European directives. The CE mark means that the manufacturer takes responsibility for the compliance of a product with all applicable European health, safety, performance and environmental requirements. CE stands for "Conformité Européenne", the French for European conformity.

The mark is required in all 27 member states of the EU, as well as Iceland, Norway, and Liechtenstein. Switzerland accepts the CE mark for some products and Türkiye actually requires that many products be CE marked.

Definition of manufacturer:

The natural or legal person with responsibility for the design, manufacture, packaging and labelling of a device before it is placed on the market under its own name.

The bottom line: CE marking provides access to a market of over 500 million consumers.

CE is not like other certification marks.

The Canadian Standards Association (CSA) or the Underwriters' Laboratories (UL) marks, for example, can only be used when those organizations have determined that a product meets applicable standards. European organizations do not grant authorization to use the CE mark as it is not owned by any particular body. The manufacturer is responsible for its proper use.

The manufacturer, whether established inside or outside the EU, is ultimately responsible for affixing the CE mark and is also responsible for its proper use. The manufacturer established outside the EU may appoint an authorized representative established in the EU to act on his behalf. CE marking is about more than affixing a symbol to a product.

The following six steps bring together insight on CE marking from experts and Trade Commissioners alike, as well as key EU resources:

  1. Find the CE directive(s) that applies to your product
  2. Know the essential requirements for your product
  3. Determine if you need third-party certification
  4. Assess product conformity
  5. Create and maintain technical documentation
  6. Declaration of conformity & affixing the CE Mark

Please note: this guide is not comprehensive and companies are strongly encouraged to consult the web resources section for additional information.

Step 1: Find the CE directive(s) that applies to your product.

How do you know if your product requires a CE mark? The first step is to see if your product is covered under one or more of the 24 CE directives below. If your product falls under any of these directives, it needs to be CE marked.

24 CE directives
Directive NumberProduct Category
2006/95/ECLow Voltage
2009/105/EC, (ex. 87/404/EEC)Simple Pressure Vessels
2009/125/ECEcodesign for Energy-related Products
2000/14/ECNoise Emission for Outdoor Equipment
2009/48/EC 88/378/EEC, 93/68/EECToy Safety
89/106/EEC, 93/68/EECConstruction Products
2004/108/ECElectromagnetic Compatibility
89/686/EEC, 93/68/EEC, 93/95/EEC, 96/58/ECPersonal Protective Equipment
2009/23/EC (ex. 90/384/EEC)Non-automatic Weighing Instruments
2009/142/EC (ex 90/396/EEC)Appliances Burning Gaseous Fuels
92/42/EEC, 93/68/EEC, 2004/8/EC, 2005/32/ECHot-water Boilers (liquid or gaseous fuels)
93/15/EECExplosives for Civil Uses
93/42/EEC, 98/79/EC, 2000/70/EC, 2001/104/EC,Medical Devices
90/385/EEC, 93/42/EEC, 93/68/EEC, 2007/47/ECActive Implantable Medical Devices
98/79/ECIn Vitro Diagnostic Medical Devices
94/9/ECEquipment Explosive Atmospheres
94/25/EC, 2003/44/ECRecreational Craft
97/23/ECPressure Equipment
99/5/ECRadio Equipment and Telecommunications Terminal Equipment
2000/9/ECCableway Installations to Carry Persons
2004/22/ECMeasuring Instruments
2007/23/ECPyrotechnic Articles

What is a directive?

A directive is a legislative act of the European Union which requires member states to adapt their national laws to achieve a particular result that is harmonized to EU rules in this area.

For example, the EU directive for products which fall under the electromagnetic compatibility category calls for member states to ensure that electrical devices that fall under this category meet certain requirements:

The EMC directive first limits electromagnetic emissions of equipment in order to ensure that, when used as intended, such equipment does not disturb radio and telecommunication as well as other equipment. The directive also governs the immunity of such equipment to interference and seeks to ensure that this equipment is not disturbed by radio emissions when used as intended.

European Commission

Be prepared:

Determining whether your product falls under one or more directives can be difficult. For example, if you manufacture electronic packaging machines with a conveyer belt, several directives will impact you. If you want to know which directives apply, you will have to go through each of the 24 directives (product coverage is sometimes found in an annex). There is no reference tool or database that lists which directives might be applicable to certain products. A trade commissioner can help you navigate these complexities.

Once you have figured out if your product falls under one or more directives, it's time to assess if your product conforms to the applicable directive(s) and, if not, how you will achieve conformity.

Step 2: Know the essential requirements for your product

Each directive details what the EU legally requires for your product to be compliant. These are formally referred to as "essential requirements" in the directive. These requirements are very general in nature. The directives do not detail how to design a product in a way that it meets the essential requirements.

Harmonized standards

The European Commission often provides mandates to European organizations (CEN, CENELEC and ETSI) to develop standards which are harmonized with the essential requirements of the directives.

A product which conforms to harmonized standards is deemed to comply with the essential requirements of applicable directives.

For information about the content and availability of these harmonized standards, contact the following organizations:

Other standards

In many cases, manufacturers may rely on standards other than harmonized standards in order to demonstrate compliance with the essential requirements in the directives. One notable exception to this rule is the Construction Products Regulation which makes the use of harmonized standards mandatory.

European Commission guidelines

The European Commission often provides detailed guidelines on the application of specific directives, including details on the interpretation of the essential requirements of the directive. While these guidelines do not have legal value (only the official text of the directive does), they are often written in consultation with Member State authorities that enforce the directives.

Be prepared:

A harmonized standard can cost anywhere from 300 to 1,500 Euros. These may be expensive but could be worth the investment. While a manufacturer does not need to buy these documents to meet the essential requirements of the directive, European authorities often use them to determine whether a product meets the essential requirements. Working from the same document can help you to avoid potential technical disputes over whether your product meets the essential requirements of the directive. Again, essential requirements are often vague – leaving lots of room for technical interpretation.

Below is an excerpt of a table of harmonized standards for construction products, though not all tables have the same format:

Harmonized standards for construction products
ESOReference and title of the harmonised standard
(and reference document)
Reference of superseded standardDate of applicability of the standard as a harmonised European standardDate of the end of the co-existence period Note 4
CENEN 1:1998
Flued oil stoves with vaporizing burners
EN 1:1998/A1:2007Note 301/01/200801/01/2009
CENEN 40-4:2005
Lighting columns - Part 4: Requirements for reinforced and prestressed concrete lighting columns
EN 40-4:2005/AC:2006N/A01/01/200701/01/2

Once you have identified the essential requirements in the directives and harmonized standards applicable to your product, you need to determine whether your product meets the applicable requirements, and whether you need to have a conformity assessment body test and certify your product to ensure that this is the case.

Step 3: Determine if you need third-party certification

Some directives require that products be tested and certified by a third-party organization in order to ensure their conformity with applicable essential requirements. Whereas these organizations are known worldwide as conformity assessment bodies, they are also known in Europe as notified bodies (NB). If applicable directives do not require the use of an NB, manufacturers may rely on their own in-house facilities to assess their product's conformity.

A notified body is an entity authorized by European authorities to assess a product's conformity to the essential requirements set out in the applicable directives. An NB also conducts an audit to make sure manufacturers have completed steps 1 and 2 – that they have identified the directives and essential requirements applicable to their product.

Some directives indicate that a manufacturer must use an NB for some products. These directives include:

Other directives do not require that manufacturers rely on NBs if the manufacturer uses a harmonized standard (see step 2) to determine conformity with applicable essential requirements. On the other hand, the use of an NB is required for some of the products covered under these directives if a manufacturer does not use the applicable harmonized standard. These directives include the Machinery directive and the Toy Safety directive.

The EU has reduced the number of products that require NB assessment. The Low Voltage directive, for example, does not require the use of an NB. European authorities are increasingly putting the onus on manufacturers to prove their products are compliant.

Be prepared:

To find the notified bodies appointed by European authorities to carry out conformity assessment, use NANDO - the New Approach Notified and Designated Organisations database. Manufacturers can search for a notified body by country and by directive. While the vast majority of notified bodies are located in Europe, a number of them have subsidiaries or contractual relations with certification bodies or testing laboratories located in Canada or in the United States to service North American clients.

Step 4: Assess product conformity

How do you know that your product complies with the essential requirements in the applicable directives? You will have to test and document that your product actually conforms. Each directive outlines which conformity assessment procedures - also referred to as modules - a manufacturer can undertake. There are 8 conformity assessment modules. The applicable directives outline which module(s) apply for a particular product category.

Using module B as an example, the chart below gives an overview of the tasks that a manufacturer and the notified body must carry out, as well as the tasks that the manufacturer can delegate to an authorized representative. Generally, the closer a product gets to Module H, the more important an NB becomes.

Module: B

These 8 procedures can be boiled down to two approaches:

  1. Assessment of conformity by the manufacturer:

    The manufacturer can hire a service provider for their access to test facilities but will pay simply for testing or other elements of conformity assessment, not consulting and certification, which is also what an NB is hired to do. A company can assess conformity of products by itself if it has the required facilities to test its product. This method is much less expensive.

  2. Assessment of conformity by an NB:

    The manufacturer is required to use an NB to assess conformity and certify its products, but it ultimately remains responsible for their conformity with EU essential requirements.

    Conformity assessment to the European directives for CE marking may consist of different activities, including product testing, visual inspection, risk analysis as well as a review of product labels and instructions.

Typical steps which may be involved in the assessment of conformity include:

Be prepared:

Many directives allow the manufacturer to choose among different conformity assessment procedures for the same product. Knowing all your options can yield significant savings in time and money.

Your product has been tested and meets all relevant European Community standards, your technical documentation must be in order.

Step 5: Create and maintain technical documentation

All CE marking directives impose an obligation for the manufacturer to create and make available technical documentation (or a technical file) containing information that demonstrates that the product conforms to the requirements of the directive.

Technical documentation relevant to a CE-marked product must be kept for at least 10 years from the last date the product was manufactured, unless the directive provides for a later date. The technical documentation must be provided on demand to enforcement authorities, often within short timelines. The technical documentation needs to be kept up-to-date, especially when the product is modified or is subject to updated conformity assessment procedures.


Although several of the CE marking directives and European national laws impose that user information (e.g., user manuals) be translated into the official languages of the countries where they are sold, the rest of the technical documentation can be maintained in any EU language (including English or French).

Location of the technical documentation

EU law does not require that the technical documentation be located in Europe. The situation is different for the Declaration of Conformity (See step 6). However, EU importers must ensure that the exporter provides that file to EU enforcement authorities. Furthermore, EU importers or distributors marketing products under their own names are required to have a copy of the complete technical documentation.


Technical Document Required for the Low Voltage Directive

Technical Document Required for the Electromagnetic Compatibility Directive (EMCD)

Step 6: Declaration of conformity & affixing the CE mark

The document certifying compliance with CE marking directives is the Declaration of Conformity. The Declaration of Conformity is an acknowledgement by the manufacturer that they are responsible for the compliance of its products with the applicable directives.

This document is the manufacturer's sole responsibility, and the establishment of the Declaration of Conformity is a legal obligation.

The declaration should be available to authorities at the EU point of entry. Contrary to the complete technical documentation (which does not necessarily need to be shared with importers and distributors in some cases – see step 5), the Declaration of Conformity should be made available to EU distributors, who may be required to provide it to national authorities immediately upon request.

The Declaration of Conformity is generally a one-pager that includes the following:


Note: The Declaration of Conformity required for your product may be different from the example below. Check your directive for guidance.

Model of EC Declaration of Conformity

Affixing the CE mark

The CE mark must be affixed to all new products, whether manufactured in the Member States or in third countries; to used and second-hand products imported from third countries; and to substantially modified products that are subject to directives as new products.

Directives may exclude the application of the CE mark on certain products (specified below), even if the directive otherwise applies to the product. These specific exceptions vary from directive to directive.

The CE mark may not, in principle, be affixed until the conformity assessment procedure has been completed to ensure that the product complies with all the provisions of the relevant directives. This will usually be at the end of the production phase. However, if the CE mark forms an inseparable part of the product, or of a component, for example by stamping or casting, the mark can be affixed at any other stage of the production phase, provided that the conformity of the product is verified as appropriate throughout the production phase.

The CE marking shall, as a rule, be affixed to the product or to its data plate. However, it may instead be affixed to the packaging or to the accompanying documents if:

  1. affixing the mark is impossible
  2. it's not possible under reasonable technical or economic conditions, where the minimum dimensions could not be respected
  3. it could not be ensured that the CE mark was visibly, legibly and indelibly affixed (manufacturers may not do so on purely aesthetic grounds)

The CE mark consists of the letters 'CE', sometimes followed by the identification number of a notified body, as below. The identification number of the NB is added only when that NB has been involved in the production phase of the product.

Sometimes several notified bodies are involved in the production phase, where more than one directive is applicable. In these situations, several identification numbers follow the CE mark.

Be prepared:

The CE mark must be easily seen and accessible for all parties. It could, for instance, be affixed on the back or underside of a product. A minimum height of 5 mm is required to ensure that it is legible. It shall also be indelible so that it cannot be removed under normal circumstances without leaving noticeable traces. (For example, some product standards use a rub test with water and petroleum spirits). However, this does not mean that the CE mark must form an integral part of the product.

Web resources

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