An importer asks a supplier for the CE certificate. A PDF arrives with a CE logo on it, a reference number and a date. It looks like a certificate, and in most cases it is not one. The CE mark is a declaration the manufacturer makes under its own legal responsibility – there is no central EU certificate and no EU body that grants it. Knowing which document you actually have is the difference between a compliance file and a folder of paper.
What CE actually is
CE marking is the manufacturer’s declaration that the product meets the EU legislation that applies to it. To CE mark a product, the manufacturer identifies the applicable directives or regulations, carries out the conformity assessment each one requires, compiles a technical file, signs an EU Declaration of Conformity, and affixes the mark. The responsibility is the manufacturer’s, and it is not shared with a lab, an agency or a marketplace.
Two qualifications matter. First, CE applies only to product groups covered by EU harmonisation legislation. A product outside those groups is not CE marked at all. Second, not every CE product is self-declared: in higher-risk categories – medical devices, most personal protective equipment, certain machinery, pressure equipment and some radio equipment – an independent notified body must assess conformity before the mark may be affixed. In those categories the assessment is a commercial service at a commercial price, and it is the manufacturer’s cost to carry. If the legislation for your product lists notified bodies, budget for one.
So the document a supplier emails you, labelled “CE certificate”, is in practice one of three things: a test report from a laboratory, a self-declaration on a template, or a document issued by a commercial agency. A certificate in the strict sense exists only where a notified body has been involved. None of the three is worthless – but only one of them is the declaration you are legally relying on, and it is not the one with the logo.
What the records actually name
We read 12,951 company records out of public B2B export listings. 7,551 of them – 58.3% – name at least one certification. This is what they name:
| Named in the record | Records | Share of those naming any |
|---|---|---|
| ISO 9001 | 4,444 | 58.9% |
| CE | 3,989 | 52.8% |
| ISO 14001 | 1,513 | 20.0% |
| RoHS | 1,387 | 18.4% |
| ISO 45001 | 880 | 11.7% |
| BSCI | 598 | 7.9% |
| FDA | 516 | 6.8% |
| REACH | 428 | 5.7% |
| UL | 417 | 5.5% |
| FSC | 195 | 2.6% |
| SEDEX | 156 | 2.1% |
| LFGB | 122 | 1.6% |
| GRS | 119 | 1.6% |
| EN71 | 118 | 1.6% |
| CPC | 37 | 0.5% |
Basis: the 7,551 records in our index that name at least one certification, out of 12,951 read in September 2026. These are self-declared listing fields. The full disclosure table is downloadable from our data section.
Two things stand out. The most-named item in the whole index is ISO 9001, which certifies a quality management system – how a company runs its processes – and says nothing about whether your product conforms to anything. It is a useful signal about the supplier and a useless one about the goods.
The second is that the standards which actually gate a shipment are the least named. EN71, the European toy safety standard, appears on 118 records. LFGB, the German food-contact framework, on 122. CPC, the US children’s product certificate, on 37. That is not evidence that nobody holds them; it is evidence that you will have to ask, and that a supplier who can produce a general certificate may still have nothing for the product you are buying.
The four documents that actually matter
- The EU Declaration of Conformity. On the manufacturer’s letterhead, naming the legal entity that issues it, identifying the product precisely, listing every directive or regulation that applies and the standards applied, and signed by someone with authority to sign. If the list of legislation and standards is missing, the document is a page with a logo on it.
- The test report. Which laboratory, which standard, and which sample. A report on a similar model is not a report on your product, and a report issued by a laboratory that is not accredited for that standard is a report you cannot lean on.
- The technical file. Who holds it and where. The declaration is only as good as the file behind it. If nobody can say who keeps it, the declaration is an assertion rather than a record.
- Your own position as importer. In the EU the importer has duties of its own: to satisfy itself that the manufacturer has carried out the conformity assessment and drawn up the technical documentation, to keep a copy of the declaration – ten years is the usual retention period – and to put its own name and address on the product or its packaging, with instructions in the language or languages required where you sell. If you put the product on the market under your own brand, you take on the manufacturer’s role, and the declaration has to be yours.
Five things that look like compliance and are not
- An ISO 9001 certificate. A management-system certificate. The most-named item in our index, and not a product document.
- A “CE certificate” from a commercial agency. No EU body issues CE marking, so a document that presents itself as an official certificate is describing something that does not exist in that form.
- A test report for a similar model. The product has to be identified. “Same design, different size” is a different product.
- A declaration with no standards listed. The list is the substance of the document. Without it, nothing has been declared.
- A certificate for a different product line. Check the model and the factory address against the goods you are buying.
What to put in the enquiry
Six lines, written before the order rather than after it:
- The market you are selling into, and the sales channel.
- The standard you expect the product to meet, named.
- A request for the Declaration of Conformity and the test report as part of the quotation, not after it.
- Which laboratory produced the report, and whether it is accredited for that standard.
- Who holds the technical file, and whether they can produce it if a market surveillance authority asks.
- A statement that the documents must name the model and the factory that actually ships the goods.
Asking for these with the quotation changes the conversation, because it makes the documents part of the specification rather than a favour at the end. What a supplier can produce without hesitation tells you as much about them as what the certificate says.
Where the risk actually sits
The exposed buyer is not the one who received no document. It is the one who received a document, filed it, and never checked whether it names the product. Compliance paperwork fails quietly – it is fine until the day a customs officer, a marketplace or a customer asks a question, and by then the goods are on the water or on the shelf.
An honest note about the limits of what a sourcing partner can do here. We are not a certification body and we cannot certify a product. What we can do is ask for the documents, read them against the specification, and tell you plainly what arrived and what is missing – and then tell you which gaps need a laboratory or a compliance adviser rather than a supplier. Our position on the boundaries of what we take on is on compliance, and the checklist for verifying a supplier’s other claims is in how to verify a Chinese supplier.
Not legal advice
This page is a purchasing note. It describes what the documents are and what to ask for; it is not legal advice, and it does not cover the legislation for every product group. Confirm the requirements for your specific product and market with your own compliance adviser before you commit to packaging artwork or a production run.
Where to start
Before the next enquiry, decide two things: which legislation applies to your product in the market you are selling into, and which of the four documents you already have. Everything else follows from those two answers. If you would rather not work that out alone, send the product, the market and the channel through the enquiry form, and the first reply will be a list of the documents that apply – and the ones that will have to come from a laboratory rather than from a supplier.