Chinese Export…?

I have to admit it: I’ve used this lame joke. But I have heard other CE marking consultants use it on many occasions. In fact, I think it is one of the most used jokes in presentations about CE marking:

“What do the letters CE in CE marking stand for?”

The presenter then should proceed with a smile and say:

“Some people think it means Chinese Export…”.

(For those of you who do not know the right answer: CE originally stood for Conformité Européenne or European Conformity)

The video below shows that the joke has gotten completely out of hand, and that the story of “Chinese Export” has started to live a life of its own. The video was posted by a Czech member of the European parliament a while ago. She must have participated in one of my colleagues’ sessions and taken the joke seriously.

Let’s end any misunderstandings

1. There is no certification scheme or program that will result in the affixing of a “Chinese Export”-mark. The “Chinese Export”-mark does not exist (at least its not a formal marking);
2. In the market you can find many products that have the CE marking with the wrong dimensions. However, this does not automatically mean that the product is not compliant with the requirements (ok, except for the requirement to affix the CE marking with the correct dimensions);
3. Also you may find the CE marking affixed to products that do not require CE. A good illustration I gave in this video:

See also here: https://cemarking.net/video-busted-this-is-a-false-ce-marking/

Every month I get emails from manufacturers or distributors that are under great pressure from their customers to affix the CE marking to products that are not covered by any of the CE marking directives.

Sometimes the manufacturer forgets to affix the CE marking:

This video was originally posted here: https://cemarking.net/two-examples-of-ce-marking-one-good-one-bad/

I think the whole story with the “Chinese Export” mark may have started when some Chinese manufacturers, who did not have CE certification for their products, wanted to disclose this and affixed the marking with the altered dimensions. When confronted with the non-compliance they could reply that it was not a CE marking at all, but a marking that indicates “Chinese Export”.

UPDATE: The European Commission has answered the formal questions of Ms. Zuzana Roithová. The reply reads as follows:

Answer given by Mr Verheugen on behalf of the Commission

The Commission is aware that there exists the misconception attributing CE marking the meaning ‘Chinese export’. The Commission is not aware of the existence of a ‘China export mark’ but considers that the mark the Honourable Member refers to constitute the CE marking as foreseen in the European legislation without, however, respecting the dimensions and proportions prescribed therein.

The Commission is aware that CE marking, like any other mark, is misused, e.g. CE marking is affixed to products which do not fulfil the requirements and conditions for its affixing or it is affixed to products for which the affixing is not foreseen. There are also cases where, whilst the product is in compliance with the applicable requirements the CE marking itself does not respect the formal requirements, namely the form of the CE marking or the dimensions and proportions prescribed in the legislation.

The Commission considers market surveillance to be the crucial element to prevent CE marking from being misused. According to the principle of subsidiarity market surveillance is primarily a task of the Member States. Products bearing CE marking although they do not comply with the applicable requirements must be identified by the national competent authorities and subsequently be withdrawn from the market.

As market surveillance does not work on a uniform level throughout the EU the Commission deems it necessary to establish a comprehensive Community legislative framework in order to ensure coherent market surveillance. The Commission, therefore, proposed a draft Regulation setting out the requirements for market surveillance relating to the marketing of products(1). This draft Regulation aims at strengthening market surveillance for industrial products and making it more effective and more efficient in all Member States, consumer goods already being covered by the General Product Safety Directive(2). The proposal sets out minimum requirements in terms of resources and surveillance activities and establishes cooperation and information obligations between authorities, both on a national level and across borders. Furthermore, it will establish an obligation for Member States to execute appropriate checks on the characteristics of a product on an adequate scale before it is released for free circulation. In addition it will introduce the possibility for national authorities to destroy non-compliant products. It also provides for the legal basis for Member States to impose sanctions in the case of misuse which should serve as a deterrent. However, it is up to Member States to actually use this power.

The Commission is in constant discussion with Chinese authorities in order to ensure that Chinese exporters respect Community legislation.

The Commission has already initiated the procedure to register CE marking as a Community collective trademark. National market surveillance authorities will have an additional means to take legal action against manufacturers providing non-compliant products and misusing CE marking. In addition, economic operators/competitors will be entitled to bring proceedings for infringement and to claim for compensation.
(1) COM(2007)37 final.

(2) Directive 2001/95/EC of the Parliament and of the Council of 3 December 2001 on general product safety, OJ L 11, 15.1.2002.

The answer can also be found at the following url:

https://www.europarl.europa.eu/sides/getAllAnswers.do?reference=P-2007-5938&language=FR

37 thoughts on “Chinese Export…?”

  1. its doesnt have any clue with some kind of joke. these two signs are DIFFERENT. the chinese mark have nothing to do with the european conformity. they use that sign, which is very similar to the real one, only to confuse the consumers…

    Reply
  2. Andrej, you must have VERY good eyes. I really don’t see the difference between the two markings she shows.

    Trust me, this is “Chinese Export” story is used as a joke, because so many products manufactured in China carry the CE marking.

    Reply
  3. To see the difference, you have to imagine that each letter forms half of one circle.

    If the circles don’t collide, it’s a European Conformity mark.

    If the circles collide, it’s a China export mark.

    Reply
  4. I know this joke but I do have to agree with Andrej & Gary ; this lady is totally right. The Chinese came up with a slightly different, misleading logo and importers and consumers have to be aware of that.

    Please check https://en.wikipedia.org/wiki/CE_mark section Fake Mark for your reference.

    (I do agree with her that the EU should try to do something against this misleading confusion.)

    Reply
  5. Marieke. The only information I can find on the Chinese Export mark is only information that refers back to the Czech lady. There is no website that confirms the existing of an official “Chinese Export” mark. If you found such a website, let me know. And excuse me of disqualifying Wikipedia. It is hardly an independent reference source.

    What the whole story proves is the following:
    You cannot just trust the CE logo on a product. In particular when you are importing products with the intension of reselling in Europe. Importers are recommended to check supporting compliance documents (such as the Declaration of Conformity).

    Reply
  6. It’s a joke or not? How can we verify if there is such China Export marks exist? Searching with the key words “CE China Export” in Yahoo I found the site of a Hong Kong based commerce consultant firm, https://technology.hktdc.com , and they do not seem to take it as a joke.
    Please offer some guidance to verify if it is joke. Thank you.

    Reply
  7. Adrian, my point is that

    1. I know CE marking consultants even 15 years ago in their training sessions were making this joke: “What does CE stand for?” Some people think it stands for Chinese Export, because a lot of the products that have the CE marking are produced in China”. Even I have made that joke.

    2. Before publishing this post, I have searched everywhere on the internet to find an organization or body or company that offers services that will get you the “Chinese Export Mark”. I haven’t found it. Not even when I tried again just now.

    3. The page of the ‘consulting’ company you refer to, does nowhere offer services to get the Chinese Export Marking. On the contrary, they have an article on their website in which they warn for the MISCONCEPTION that CE may be perceived as Chinese Export Marking: https://toys.hktdc.com/toys/suc-e-toys10.htm?w_sid=194&w_pid=1429&w_nid=&w_cid=&w_idt=1900-01-01&w_oid=203&w_jid=

    This ‘Chinese Export’ mark has started with a joke, more than 15 years ago. And now some people believe that there really is such a mark. The lady in the video is a good example. She notes that there is a Chinese Export mark that is causing confusion. THERE IS NO SUCH MARK. However, there ARE misuses of the CE mark. There are cases in which the official format of the CE mark is not respected. That is serious. That is not a joke. I agree with you.

    I hope this clarifies what I intended to say with this post.

    Reply
  8. Han Zuyderwijk, you are wrong. Here you can read the document that EU produced when launching the CE marking in 1993. There you will see for yourself that they have stated that the C forms a circle that meet the E in the end. If the two letters are closer together it is a fake.

    https://ec.europa.eu/enterprise/mechan_equipment/ppe/of_journ/93-68-eec.pdf

    Where as this pirated version is in use by Chinese (hardly on their own anyway) is harder to tell because I don’t think they have produced a official goverment document on how they can pirate their way in on the European market. If they have, it’s probably in Chinese.

    The joke probably came up as someone misunderstood something or it was remembered wrongly when it went from person to person. But you said it started 15 years ago when the CE marking started so a good guess would be that the joke was true at first then the pirated version was actually created in reality!

    All things aside: there is a pirated version and now you have the proof.

    Are you a CE marking consultant? If so, why haven’t you even read the official documents and rules governing CE marking?

    Reply
    • Sebastian,

      I am not saying there are no false CE markings. I know there are many products that are false CE marked. Even products that have a CE marking with the right dimensions.

      I am familiar with this document. It shows how the CE marking should be designed. If the letters C and E are too close to eachother, it means that they are not in accordance with the rules, that much is true.

      However, I restate what I have said before: there is no official Chinese Export marking. And when a product has a C and an E which are to close to eachother, that is no proof of the fact that a Chinese Export marking exists! It only proves that the manufacturer did not read the requirements carefully enough. And it is an indication that the product itself may also not be in conformity with the CE requirements.

      Reply
  9. Sorry for the misunderstanding. Yeah it sounds quite possible that their is no official Chinese Export mark made to look like the official CE marking. And if their is an unofficial one it demands quite a lot of research to prove it.

    That said it’s quite safe to say that China is one of the large producers in this world and also one of the large producers of pirated products (i’m just guessing here) so they should most likely also be one of the worlds largest users of pirated CE marking (more guesses). Which, in a humorous way, should earn the false CE marking the name “Chinese Export”. Just to confuse everyone ;) But maybe that was the joke?

    So there are actually legit manufacturers of CE products who misprint the CE marking? If they can’t even get the logo right it sounds like they probably haven’t got anything right :D

    Reply
  10. Han: You are missing the point. It is totally unimportant if there is a “official” CE-lookalike or if not. The undisputed fact is, that many many products from China carry those fake CE marks and are also not certified as CE conforming. Some suspect that those fake CE signs are different from the “real” CE sign by purpose so that nobody can claim that they have faked the CE sign (which is, as you know, strictly specified). You are ranting here to no good, because the important message is that people need to watch out for fake CE signs which are a fact. Oh and btw. the czech politican has not claimed that the fake CE sign is a official chinese sign. You should rewatch the video.

    Reply
    • Hi Hans,

      Thank you for your contribution in this discussion.

      Like I stated before, I agree that it is serious that there are products on the market that do not comply. There are simply too many, as you can see from the notifications published by the European Commission: https://ec.europa.eu/consumers/dyna/rapex/rapex_archives_en.cfm.

      The politician says: “…I discovered another marking that symbolizes something completely different. This marking said that the product was produced in China.” If her point is to warn that some manufacturers do use a slightly different CE marking to confuse consumers, then she presented it not very clear. Maybe her point got lost in the interpretation…

      But even if that is her point, its not useful to focus on the “Chinese Export” logo. Because there are many products in the market that have a CE marking with the correct dimensions that do not comply. There are also a lot of products that do not have a correct CE marking that do comply with the rules (except for the rules about how to display the CE marking ;) ).
      Moreover, intentionally affixing a fake CE marking to confuse consumers is not very smart: any marking that resemble the CE marking and that could cause such a confusion is prohibited. The current rules already provide the authorities with the competence to take measures against such confusing markings.

      But Hans, I realize that you are right I shouldn’t make fun of an attempts to protect against unsafe and non-compliant products. On the contrary, I should support it. And perhaps you and other readers are willing to help? If you see a product that clearly does not comply and that has a CE marking, or if you see a product with a fake marking, take a picture of it and send it to me or post it here. Of course you may also report it that to one of the following authorities: https://ec.europa.eu/consumers/safety/rapex/contact_points.pdf

      Reply
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  12. Youtube is blocked in China so can’t see video.
    There is lot talk regards “Fake CE Marking” or better put manufacturer declaring to meet a relevant directive when in fact he has not.

    Regards the regulators it appears the Notified Body is Danish Institute of Fire and Security Technology Notifed Body number 0845. The maker is not displaying certificates on the site. If they should ahve a Module B (Type Examination) Certificate and one for ongoing or manufacture such as Module D. Also as part of the Directive requirement the maker must issue a DoC (Declaration of Conformity) which should accompany each product. Also it is likely they would have annual factory inspection under Module D (thats if they chose this route) as for a copy of last report, they not abiliged to give if though but it just shows there is on going assessment going on.

    As a buyer many just accept a DoC or copies of Certificates really not looking further than that they get fingers burt when then realise they not real. Look deeper if they are half decent company they will give you supporting documents if they want you business. Not all Chinese companies are out to mislead they themselves have been mislead in getting incorrect certficiation. Buyer needs to be aware.

    Reply
  13. What is the difference between fake and real CE? I am dealing with a company which is CE and ISO 9001 certified and received shoddy workmanship. Now 4 months on I still try to get them to replace a wrong gearbox and all they do is delaying tactics….

    Reply
    • The only thing that really matters to you is whether a CE marking (which is really an indication of the manufacturer that the product complies with European requirements) is genuine and that the manufacturer really assessed the conformity. If you feel the workmanship is shoddy, and the product is not safe, the CE marking is probably just affixed without caring about compliance. A reliable company that truly went through the CE marking process and that assessed its product’s conformity will be glad to provide you with any information that confirms compliance. When they are dragging their feet, it is suspicious.

      There are a few things you can do to get more clarity about the CE compliance:
      1. Always ask the manufacturer for a copy of the Declaration of Conformity. This is basically a statement on behalf of the company and it specifies the European regulations (directives) and standards that the product is declared to comply with.
      2. Familiarize yourself with the applicable CE directives and standards. In this way you can verify when the manufacturer gets it wrong or when the manufacturer is using obsolete directives and standards (which would mean that the CE marking is not longer valid).
      3. When you know which standards the manufacturer claims compliance with, get a copy of the main product specific standards (if any). With the standard in hand, you can do a conformity assessment yourself. If you find one or more non-conformities, you’ll know the CE marking is bogus.
      4. Ask the manufacturer if he can show a certificate or test report that shows compliance with the standards and/or directives. Check carefully if the product in the report is the same as your product and that the standards and directives are still in force.

      I hope this helps. If you need assistance, contact me and we’ll discuss how I can help you.

      Han

      Reply
  14. Thanks for the reply Han, but what do you do if the certification is genuine and the company just drags their feet and does not reply to emails? That is what I mean – if you have no recourse what is the difference between a fake and a real CE certification if you are a long way from China. Of course you can say don’t deal with them any more – but as I am not an importer or a big company which regularly imports goods that does not help.
    Uli

    Reply
    • What do you do if the CE marking is genuine, and they’re just delaying…? I feel your pain. I understand that as a small importer you don’t see many options. But as a New Zealand exporter, your European customers are looking at you for the answers. If you have a manufacturing partner that is not really cooperative, I understand that is really, really frustrating. But as a CE expert, I can just say that the CE regulations will not provide you with a solution for that (other that you can familiarize yourself with the requirements, so you’ll know what you can expect and which questions you can answer. As an outsider, I can only say that it seems to me that only you hold the key to a better situation. Is the price level what is keeping you from changing your supplier? Ask yourself how much money these delays are costing you and add them to the price the manufacturer is giving you. Maybe you’ll find that other providers who can give you all the guarantees you need are better priced in the end…

      Reply
  15. Thanks, Han, but you are confirming what I said is correct for small importers. If you don’t have economic muscle the company can do what they like – CE certified or not. Like Wuhan Chancay Machinery and Electronics – the company I was dealing with. You can even order a positive audit report on them for US$39.- through the Internet from a reputable company. However they denied the problem (wrong gearbox) until I provided a video. And then no response any more. Of course I won’t deal with them any more and I think nobody else should deal with a company acting like that – even if they have the economic muscle.
    There is the China International Economic and Trade Arbitration Commission (website https://www.cietac.org/index.cms, email info@cietac.org) however they don’t answer any emails either. Whether it is deliberate or whether they don’t understand any English or whether my emails happened to end up in a spam filter – I don’t know. However for smaller companies I can only recommend not to deal with Chinese companies unless there is a working Arbitration Commission.

    Reply
    • Thank you very much for sharing your story Uli. You are absolutely right that small importers have less possibilities to verify the CE marking is genuine, and that their requests and demands can simply be ignored by the manufacturer if the volume of the trade is small. Your story reminds me of a great book that read just the other day. In the book, Poorly Made in China: An Insider’s Account of the Tactics Behind China’s Production Game, Paul Midler tells many stories of his experiences assisting companies of all sizes working directly with hundreds of manufacturers in China. The book gives an excellent behind-the-scenes look at China’s manufacturing sector. It is a ‘must read’ for anyone who is (thinking about) outsourcing manufacturing to Chinese companies, importing products from China, or in general doing business. You can get a copy of the book at Amazon here (aff link). They also have a Kindle version. I plan to do a blog post about this book later.

      Reply
  16. At one time, Made in Japan was considered poorly made. The situation has now changed.

    Made in China is not necessary good or bad. It is your choice to buy or not to buy based on price and other considerations.

    To say Made in China is bad is not a fair and objective statement.

    As for the China Export joke, I believe it started with a company that had to squeeze warning statements on a small label thus compressing the CE symbol. Just joking!

    Funny that life is so funny.

    Reply
  17. A machine made in China does not come with a CE mark… can I still get it shipped to the United States? Will it past Customs?

    Reply
    • Arthur, the CE mark is not a requirement in the US. The CE mark is a European compliance marking. To be allowed to enter the US, the machine would have to comply with US regulations such as OSHA.

      Reply

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