Do your products need CE marking?

“Do my products need CE marking?” Not a single day passes by that we do not get this question. In this post, we will try to give you some guidance on how you can answer this question yourself. If after you have read the post you still have questions, or need assistance, we will be glad to assist you.

Unfortunately, it can be difficult to determine if a product needs CE marking. Unfortunately, there is no authority that provides a product lists or nomenclature that names the products that require CE. Instead you will need to investigate this yourself. We recommend the following steps.

Do my products need CE marking?
Do my products need CE marking?

Step 1: Do you intend to sell in a country in which CE marking applies?

The CE marking applies to products placed in the market or put into service in the European Economic Area. Even so, it only it applies only for certain product groups or product aspects, as we will see in the next step. To answer the question whether a product needs to be CE marked, you first need to first check if the country or countries in which countries the products are going to be placed in the market or used are countries that require CE.

The CE marking is required only for certain products intended to be sold in the countries of the European Economic Area (EEA)

The CE marking is required in the countries that together form the European Economic Area (EEA):

  1. Austria (became member in 1995)
  2. Belgium (Founder Member in 1957)
  3. Bulgaria (2007)
  4. Croatia (2013)
  5. Cyprus (2004)
  6. Czech Republic (2004)
  7. Denmark (1973)
  8. Estonia (2004)
  9. Finland (1995)
  10. France (FM 1957)
  11. Germany (FM 1957)
  12. Greece (1981)
  13. Hungary (2004)
  14. Ireland (1973)
  15. Italy, (FM 1957)
  16. Latvia (2004)
  17. Lithuania (2004)
  18. Luxembourg (FM 1957)
  19. Malta (2004)
  20. The Netherlands (FM 1957)
  21. Poland (2004)
  22. Portugal (1986)
  23. Romania (2007)
  24. Slovakia (2004)
  25. Slovenia (2004)
  26. Spain (1986)
  27. Sweden (1995)

…as well as three members of the European Free Trade Association (EFTA):

    * Iceland
    * Norway
    * Liechtenstein 

Although Switzerland is member of the EFTA, it does not take part in the EEA.

PLEASE NOTE: Turkey is neither member of the EU, nor is considered a part of the EEA. However, Turkey has fully implemented many of the European CE marking directives. This means that for many products they also require CE Marking.

PLEASE NOTE ALSO: Now that the Brexit has been completed, and after a transition period, the United Kingdom will not longer require the CE marking, but they will require the UKCA conformity marking instead.

If the product is not intended to be made available in the aforementioned countries, it will not need CE marking.

The next step is to determine if the product is covered by one or more of the European CE marking directives or regulations.

Step 2: Is the product covered by the scope of a CE directive or regulation?

The CE marking is required only for products for which a CE marking directive or regulation has been adopted. There are directives/regulations for the following types of products (please note that one or more directive/regulation can apply to a single product):

Are your product within the scope of one of these directives or regulations? If so, they require CE marking.

Products that do not require CE

The CE marking is NOT required for the following products:

  • Chemicals
  • Pharmaceuticals
  • Cosmetics
  • Foodstuffs

Products not covered by the European CE marking directives may still fall within the scope of other EU or national legislation. If no CE directive or regulation applies, the General Product Safety Directive (2001/95/EC) may apply. This General Product Safety Directives requires that products are safe, but is does not require any marking.

Need help?

At CEMARKING.NET, we have developed a Six Step CE Marking Framework that helps companies to do CE self-certification. We offer this Framework as an On-Line Workshop, as a Coaching Program, and as a Done-For-You service. The first step of this Framework is dedicated to determining which directives and standards apply to your products, and how you can do the CE marking efficiently and in a cost-effective way. We now offer this “Step 1” of our framework as a separate service. That means you can get a report with an overview of the applicable requirements and recommendations with the steps you need to take, without investing in the full service package. Contact us for more information on our services, click the Start Now-button.

Further reading

898 thoughts on “Do your products need CE marking?”

    • Dear Natalia,

      No, this is a matter of the certification body. The EU directives require nothing about this.

  1. Han,

    Would recreational vehicles and agricultural equipment fall under the “Machinery” category in part 2 above or would they be subject to different directives?

  2. Good day, Han

    Requirements for CE marking is the same for one-off basis product ? Maybe there is some exceptions ?

    Thanks for Your answer,
    Jūris

    • Dear Jüris. Unfortunately there are no exceptions. Even when you place only one single product on the market it still requires CE if it is covered by one or more of the CE directives.

  3. Dear Han
    We are looking to import a tea weighing and dispensing machine (which would be custom made for us)- does it need the CE mark for customs? It is not for resale (just for our manufacturing) and all their standard machines have the CE mark. They said if we wanted to have it CE certified on their certificate it would be another Eur2000…
    Will customs request CE certification?

    Thanks
    Joerg

    • Dear Joerg,

      Yes, they probably will. These fall under the Measuring Instruments Directive or the Non-automatic Weighing Instruments Directive.

  4. Dear Han, first of all many thanks for sharing your knowledge! And even more for answering specific doubts:).

    My question is: do sunglasses need the CE marking when imported from outside the EU? What about glasses frames for prescription lenses?

    Merry Christmas!

    • Merry Christmas Hugo!

      Yes, sunglasses are covered by the Personal Protective Equipment Directive (89/686/EEC) and therefore require to be CE marked.

  5. Dear Hans may I commend you on a great blog & taking the time to answer questions. I am looking to import writing instruments direct from Japan, mainly pens & mechanical pencils from various distributors. They are all manufactured by reputable brands do they need a C E Mark? and if not can I import on the grounds that I have only bought products manufactured by reputable companies therefore I have covered my obligations regarding duty of care to the consumer?

  6. Hi Han, great website! it’s really fantastic of you to offer such expertise.

    My query is that I’m thinking of importing wall lights (240v one incandescent bulb) from China to the UK – do these need a CE mark?

  7. Hi Hans,
    Is CE Marking necessary if you will only have your product in the German and UK market for less than 12 months during which a demonstration and trial period would take place to see if the product will work in those markets? I am specifically speaking about sending 2 kiosks into each of these markets for a less than 12 month demonstration/trial. Thank you so much!

    • Hello Katichase,

      Yes, also in such trial cases the product needs CE marking, because – as I understand – the kiosks will be used normally by the foreseen end users.

      • thank you so much for your response. Is there any documentation printed that outlines this at all? I have been asked to provide supporting documentation and when I have scoured the internet for some I haven’t really found any. Thank you so much for any guidance you can provide.

  8. Hello Han,
    we are small company building custom made computers. Basically the customer comes to us, says what computer he wants and we build one that suits his specifications. We want to start selling our service to Germany, member of EU, because we have demand from there. From what I read I’m pretty sure we will need to have CE on our computers, the question I got is how to obtain it?

    We build about 3-4 computers a day, every computer is unique so every computer needs to be tested? Sounds unreal to me as testing costs a lot of money. Also I should add that all parts we use are already CE certified. I think I’m missing something here. Thanks for any help or pointing in right direction.

    • My situation is pretty same, just product little bit different, so i waiting answer for this question too :)

    • The fact is that building a computer from only CE approved components does not guarantee that the end-product will be compliant as well.
      The main challenge here is the EMC Directive. Only be testing it can be determined whether the computers comply with EM emission and immunity requirements.
      Are the computer configurations really endless? Is it not so that you could build a few configurations that have all components as a kind of worst-case and test those?
      It also seems to me that your company could gain a lot from investing in its own test equipment, so that you do not need to contract a test lab for every test you need.

      • It is truly endless. Main advantage of our approach is that our computers are really tailored to customer needs. We use every CPU from cheap pentium to i7, gpu of every brand. And of course there are new components announced every month or 2. If we do only few configurations we will be like Dell, selling overpriced year old computers, that is not an option for our company policy. Customer is always on the first place and if EU wants it different, we will simply not go there.

        I’m just curious about how other companies do that. I found a lot of them operationg in EU, lots of them so small that it is one-man bussines. I can only guess that not everyone exactly follow CE rules and they are selling computers without testing it.

      • Maybe can you provide source for this information ? “It also seems to me that your company could gain a lot from investing in its own test equipment, so that you do not need to contract a test lab for every test you need.”

        Because our local test lab, said that we should bring them every unique product for test, but we have quality control area with own test equipment and we can test ourselves. Our company sertificated quality standart ISO 9001, and working with IEC 61439-1 standart

        • I am sure your test lab would hate to see your company go. The fact is that it is not required to go to a third party test lab. Read the EMC directive and you will find no clause that requires you to go to a third party. In fact, a few years ago, the European Commission removed the few requirements for third party testing from the EMC directive altogether.
          The ISO 9001 alone does not do the trick: it depends on the procedures your company has to ensure compliance of its products and the consistency of its manufacturing process. The EN version of the IEC 61439-1 is a harmonised standard under the EMC directive and applies to switchgear and controlgear. If that is the type of product your company manufacturers, you have the right product standard for EMC.

          A company can invest in your own test equipment. If this is economically viable, depends on the number of different configurations and modifications. You can start with the less complicated test equipment and still outsource the tests that require expensive test equipment.
          I would also recommend to invest time in knowledge about EMC compliant electronics design. A lot of EMC problems can be avoided in the design, and that leads to more first time test passes.

          • Thanks, for your answer Han, that was very important to me :) Just for your information, IEC 61439-1 is under LVD (Low voltage directive).

            Or it could be under two different directives (LVD and EMC) ? As i understand there(in LVD) is also no clause that requires me to go to a third party

  9. hi I make rag dolls but not for children, adults ask me to make bespoke dolls that may look similar to them or they want a certain look. do I need to ce test as I have no desire to sell to childrens market. thankyou

  10. Hi Han,
    I make tutu dresses and skirts for children, I advertise them as clothing. Do they need to be CE marked?

  11. Hi Han, how are you? Thanks for this great article. Just want to ask, does network cables like Cat5e and Cat6 requires CE? how about network Patch Panels and Switches? they are not used for radio just for internet and local networks. Thanks in advance.

  12. Dear Han,
    I just want to ask you if an apple lightning cable needs CE. From my point of view. It needs CE. Because it’s not only a cable. As far as I know there is an IC intergrated.

  13. I put together kits for people to make crochet items themselves. Obviously all the components will comply with regulations . Is this sufficient ?

    • No. You need to make a Technical File, a Declaration of Conformity, affix the CE marking and apply labeling requirements.

  14. Hiya – appreciate any advice as would like to sell trainers that have flashing LED lights built into the sole and are re-chargable through a cable via laptop but they don’t have any CE marks on them – legal to sell…? many thanks in advance

  15. Han, if we send a product to Germany that is later changed (reworked) by the customer before being sent to any endusers, do we need to CE Mark ? The product is an IVD medical device.

    • Dear Mary,

      Yes, the device needs a CE marking, because it falls within the scope of the IVD Directive. If the device is intended specifically to be supplied nor as a final product and not to be resold before being reworked, and to be CE certified by the customer, it may be possible. However, if your IVD’s will be used by end users they require CE marking.

  16. Hi Hans – came across your blog as I was searching for an answer to the following question: we have bought a heater/sealer machine from China (we are in Australia) that electrically tests ok, but has no CE marking. If we allow a supplier of ours to use this machine and something happens ie. an electrical fault that hurts someone, are we opening ourselves legally to litigation in your opinion?

  17. Good morning Hans.
    We are trying to help a third party setup a test rig for developing some software. They have specified a particular set of components to be used which are CE marked, a panel mounted computer and its DIN rail PSU. The nature of them means that it makes sense from a safety perspective to mount them in a case, which the supplier of the components has offered to do. When asked if the whole assembly will be CE marked, we were told they wouldn’t do it because to do so would be more expensive than the whole assembly costs. It is considered to be a one-off prototype assembly.
    It will be used in a controlled environment, at our premises and then transferred to the third party’s premises into a controlled ennvironment.
    I was wondering what your view on this was?
    Should the supplier really be CE marking the assembly?
    Should we be doing it ourselves?
    Or is the very controlled nature of the two environments and the prototype nature sufficient reasons to avoid having to CE mark at all? For what it is worth, all equipment is safety checked (PAT) by us before use and again before passing on.

    • Dear Mortimer,

      Thank you for your question. Interesting case. I think your third party is right: probably the CE certification would not make this economically viable.
      It is not easy to answer your questions without knowing the specifics of the case. From a legal perspective, the answer would be that the equipment needs CE. You can contact me if you want to discuss in more detail. Use the support form under the Support link.

      • Thanks for that Han.
        When looking at the EU Blue Guide, I was drawn to section 2.3 “Placing On The Market”.
        When I read this, it suggests to me that the need for CE marking revolves around whether or not there is an intention to place an product on the market.
        There are a set of bullet points in which a product is considered NOT to have been placed on the market:
        * manufactured for one’s own use. I don’t think we can use this one, as the supplier is assembling the box for us.
        There are then four bullets relating to territories and countrys outside EU. So none of these apply.
        * transferred for testing or validating pre-production units considered still in the stage of manufacture. This one is sort of interesting. The actual product being developed is software for which the supplied assembly is required for testing the software against. So this might be tenuous argument at best.
        * displayed or operated under controlled conditions at trade fairs, exhibitions or demonstration; or
        The conditions the assembly will be used in are controlled, it will be a lab at our premises, and then it will be transferred to a lab at the premises of the third party we are assisting. However not a trade fair, exhibition, but there is likely to be a demonstration towards the end of development.
        * in the stocks of the manufacturer (or the authorised representative established in the Union) or the importer, where the product is not yet made available, unless otherwise provided for in the applicable Union harmonisation leglisation.
        Another interesting one, but depends on who is considered to be what in the relationship. I would guess the manufacturer is the company supplying the required components in the box (the whole assembly). My organisation would be the “authorised representative”. But how would the third party be described in this? Also, the assembly is not going to be marketed outside of the relationship between our organisation and the third party organisation where this thing ultimately ends its days.

  18. Hi Han,
    We Design and fabricate bespoke steel fire rated screens and doors so each is different, does this fall under he structural steel category and require CE marking?
    Thank you for you time.
    Joanne

    • These fire safe doors fall under the Construction Products Regulation and do require CE marking. There is a special European standard for windows and doors that I believe applies, and for that reason you need CE marking.

  19. Hi Han,
    I wish to import led wall clocks from china to the UK. I have been told only the mains adaptor has CE marking on but the actual clock does not. The reason the company give is because they are sold worldwide and anyone that orders means clock are manufactured from scratch as they are manufacturer of these. Only if we ordered hundreds could they put the CE mark on otherwise they would come with no marking, only on adaptor.

    Is this correct and if so can I order a box of these in and have them tested myself or where do I take a sample. What are costs to test for CE marking and if it passed would I just put a sticker on myself with CE logo? Any help appreciated.

    • The clocks are electronic? Or simpel quarz clocks?
      It could be that the clocks do not need CE, but the reason they give is nonsense. The adapters do require CE. Be careful, many adapters bear the CE mark, but do not comply.

  20. Hi Han,

    We are looking to start import glass tea cups from China. As far as I can see above these products don’t require CE marking, is that correct?

    Thanks very much for your help.

    Danny

  21. Hi Han, I am looking to import wireless car door logo lights into the UK from China. I ordered samples and the CE mark is on the box and the supplier says it can also be put on the product, but when I actually asked for a copy of the certificate it turned out that the certificate they put on their website is for another led light and the one I need is not certified at all! I believe it is my responsibility as a future distributor to make sure that the product is truly complies with European law, so I asked them to apply for a certificate and we are gonna split the costs. My quiestion is that does this battery operated (3x AAA) led light really requires a CE certificate? I really appreciate your help! Hedi

    • Dear Hedi,

      Yes, it requires CE for compliance with the EMC Directive. You are correct about all your other statements. Be careful, because it will be your responsibility that these comply.

      • Dear Han,

        Thank you for your answer. I have already purchased a draft declaration from an agency in the UK to send it over to the suppliers and also requested them to compile the technical file according to the requirements of the directive. As far as I know self-assassment and declaration is enough in case if EMC and LVD. Am I right?
        Best regards, Hedi

        A Windows Phone-telefonomról küldtem

  22. Hi Han . . .Happy New Year!
    We manufacture breastfeeding support products, including nursing pads and devices to help collect and freeze breast milk (nothing electronic).I am trying to determine if these products require a CE mark. And, even if a CE mark is not required, does it make import easier in any way. Or, are there advantages to having the CE mark, even if not specifically required. Thanks very much!

  23. Hi Han, one question please. For a product (cup warmer, powered through USB), do we need CE aproval?

  24. Hi Han,
    Would CE marking be required on a device that is used for firefighting? Specifically, a device that attaches to things like rails, ibeams, telephone poles, etc.. and attaches to a hose and a nozzle to direct a stream of water at a fire. Your advice is greatly appreciated.
    Best Regards,
    Dan

  25. This is so confusing. I’m sure you have this question a lot so I apologise. What if I’m building custom computers built with existing CE certified components?

    • Dear Richard,

      Building it strictly with CE components definitely will help. There are a few things on the EMC and electrical safety end that you may still need to check. (Not only because the CE mark may not be genuine…) For EMC, putting two CE marked components together does not guarantee that the end product will be compliant.

  26. Dear Han,
    We manufacture of seamless stainless tubes
    Our goods are shipped worldwide. We have a certificate of PED 97/23/EC approval
    Should we (or not) affix the CE marking on our products. Is this legal for us or we need make additional certification
    Our manufacturing facilities are located in Ukraine

    Thx,
    Vladimir

  27. Dear Han, We have a prototype electro mechanical product that we wish to demonstrate to potentioal customers in various countries where CE approvals are needed. If the prototype product is not actually sold and only in the country on a temprary basis will it still need CE approval? Thanks Gary

    • The prototype does not require CE marking if you can ensure that is safe and under complete control and supervision. Controlled conditions would mean expert operators, restrictions to public contact with the product, avoiding inappropriate interaction with other neighbouring products etc.

    • Dear Claire,

      That is possible. It depends on the technology used. The Machinery Directive may apply, as well as the EMC Directive and Low Voltage Directive.

  28. Hi Han,

    Thank you for your informative article.

    I also have a question about CE marking, for a device used in a European research project. I work as a researcher in the UK and I would like to order a portable incubator (with a battery) to transport biological samples abroad (in Europe). The company I want to order it from is based in the US. When I emailed them to purchase one, they said that it was not possible for me to buy one, since their incubators are custom made and therefore that it was impossible for them to carry and obtain the CE mark for every device they make. Are they correct to assume this? Aren’t there any exemptions, especially for research-purposes? For example, I read that some medical devices were exempt from the CE mark (custom-made devices and devices undergoing a clinical investigation) and need only to conform with the relevant essential requirements.

    Thanks!

    Allan

    • Dear Allan,

      Yes, they are correct. There are no exemptions for research, if the devices are used for their regular purposes.
      There is an exemption for prototypes, but I am not sure the device would qualify as a prototype. A prototype does not require CE marking if you can ensure that is safe and under complete control and supervision. Controlled conditions would mean expert operators, restrictions to public contact with the product, avoiding inappropriate interaction with other neighbouring products etc.

  29. Dear Han,

    I am starting a Health care company and I have created a weight loss product, I was wondering what legal requirements I would need to include on the label and if I would need to include the CE mark on as well. My company is based in the UK and I will be selling through retailers and online.

    Thanks

    Mathew

    • Matthew, that depends on what your product is. Your fust step will be to find which product regulation applies. Without knowing more details, I cannot say it is covered by CE legislation. If it is some kind of pill or drink, the CE marking will not apply, but in that case there are other regulations you’ll need to comply with.

  30. My manufacturer has the CE mark for the product which it’s registered my manufacturer’s brand of their company, however I re-brand the same product to under our brand of my company, only logo and label difference. Do I need to re-certify it to under my brand? Is there a CE official website discuss this specific situation? I asked many people regarding to this, some said Yes, other said No. Thank you for your help!

    • Dear James,

      You do not necessarily need to re-certify everything, provided that the product was tested and certified against the correct directives and standards. By applying your private brand and removing the brand of the original manufacturer, your company now became fully responsible for CE marking. You will need to have (access to) a complete Technical File, and you need to ensure that all the requirements are complied with. Also your company will issue the EC Declaration of Conformity.

  31. Very interesting article. So in the end, something as delicate as a baby feeding bottle (milk bottle) would not need any CE marking?

    • Dear Bethem,

      No. These are not covered by any CE directive. But obviously such products need to be safe as well. Please look at the General Product Safety Directive (2001/95/EC)

  32. Hi,
    thanks for this topic. We are looking for CE marks.
    I have question, My wife make (hand home made ) fabric doll.
    there will be around 10-30 items a years.
    do we need CE marking? and if yes can you please tell me more info where to apply for that?
    thank you.

  33. Hi Han, i’m looking to sell sunglasses for my clothing brand, the glasses are UV400 protected and drop ball tested but not CE-Marked. Can we sell these to EEA Countries? The printing company we buy the glasses from (from uk) says “Yes you can sell these in EEA Countries, they are all inspected by customs and approved upon entry” Thanks, Pontus

    • Dear Pontus,

      Sunglasses need to comply with the Personal Protective Equipment Directive, and accordingly must be CE marked before they are placed in the market.

  34. Hi I bought a cabinet with CE compliant. But I Installed non EMC glass door . Still the cabinet can be called as CE complaint

    • Dear Shunmugam,

      This is a modification that is relevant from the point of EMC compliance. The EMC measurements your supplier made will likely not be representative for the product after your modification. In my view, a radiated emission and immunity (re-)test would need to be done to ensure the cabinet is still in compliance.

  35. i Han,

    The panel specification says that the panel should be CE compliant and the the front door should be glassed. The vendor provided CE compliant cabinet with normal front door glass .There is a dispute among us that if the glass is non EMC, then the cabinet cannot be CE compliant.The panel supplier r argues that CE compliant is totally different from EMC requirement . Though the glass is normal the provided cabinet meets the specification .

    Expecting your point on this

    • Dear Shunmugam,

      Unfortunately, there is nothing I can add to what I said without knowing the details in this particular case. You have made your considerations when installing the glass door. The vendot does not want to guarantee compliance after this modification. I can understand that.

  36. Hi Han. I wish to import float glass into the UK/EU to be further processed into furniture glass.
    I also wish to import to UK/EU glass tiles made from float glass. Do any of these items need CE Marking?

    • Shunmugam, the requirement is that the end product must be compliant with the EMC directive. There are no specific requirements for EMC glass doors.
      As you explained me, in your specific case your supplier requires use of EMC glass. If this is the way for your supplier to ensure EMC compliance, you will need to respect that, or provide additional EMC testing yourself.

  37. I am designing’s and printing an activity/colouring book for Children aged 3 – 11yrs for retail. do i need CE Certification?

    • Dear Jo,

      Books are within the grey area. Some books are covered by the Toys Directive, and some are not. Reading books, are not toys, but coloring books, books with unfolding features and activity books are covered by the Toys Directive and require CE.
      If you need help, we can guide you through the process.

      • Thank you for the fast reply! Do you know something about origin rules? The sunglasses are made in China. I heard you can legally use something like Born In *your country*. Or am I also obliged to put “Made In China” on it somewhere? You’ve been of great help already!

    • Daniel,

      What is the intended purpose? Do the filters contain moving parts, pressurised parts, electronic or electrical parts?

      • Hi,
        It is a bacterial medical Filter Used in the medical sector such as in respitory machines in Hospitals, home use ( nebulizers) and other sectors. No moving,pressurised,electronic or electrical parts.

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