Is a CE certificate from the Chinese factory enough?

No. CE marking rests on a declaration of conformity drawn up under the responsibility of whoever places the product on the market, not on a certificate issued by a third party. A test report from an accredited laboratory is a useful part of the file, but it replaces neither the EU declaration of conformity nor the technical file, which the importer must be able to produce on request.

What is the responsible person required by GPSR?

An operator established in the European Union, appointed in writing, tasked with verifying that the declaration of conformity and technical documentation exist, keeping them available to the authorities and cooperating in case of risk. For a European importer this role is generally taken by the importing company itself. Their contact details must appear on the product, its packaging or the accompanying document.

Must every imported product carry CE marking?

No. CE marking is required only for products covered by a European text that demands it: toys, electrical and electronic equipment, machinery, personal protective equipment and medical devices, among others. An ordinary garment is not covered. All consumer products, however, fall under the general product safety regulation, CE marking or not.

Which products must carry CE marking?

Only those covered by a European text that requires it. Toys, electrical and electronic equipment, machinery, personal protective equipment, medical devices, radio equipment and construction products are among them. An ordinary garment, a leather article or a non-electrical piece of furniture are not. All of them nonetheless remain subject to the general product safety regulation.

What does a technical file contain?

The material needed to demonstrate the product's conformity: general description, design drawings and diagrams, list of standards applied, results of calculations and tests, risk assessment and test reports. It is not made public but must be producible at the request of market surveillance authorities. The importer must satisfy itself that it exists before placing the product on the market, and be able to access it thereafter.

What is an EU declaration of conformity?

The document by which the person responsible for placing the product on the market attests, under its sole responsibility, that the product meets the requirements of the applicable texts. It names those texts and the standards relied on explicitly, identifies the product and its manufacturer, and is signed. A generic declaration that merely asserts conformity without citing any text does not serve its purpose.

Who is liable if an imported product causes an accident?

The importer in the first place, once the manufacturer is established outside the European Union: European law treats it as the product's point of entry to the market and holds it answerable for its conformity. If the product is marketed under your own brand, you are legally equated with the manufacturer, with all the corresponding obligations. The factory's geographical distance does not soften that liability.

Does a product need laboratory testing?

For most regulated product families, demonstrating conformity rests on testing. What matters is the laboratory's accreditation — ISO/IEC 17025 is the reference — and that the tests bear on the product as it will be delivered, not on a prototype or an earlier version. Certain high-risk categories also require the involvement of a notified body designated by a member state.

What is the risk of importing a non-compliant product?

Withdrawal or recall of the product, detention at customs, administrative penalties, and civil liability in case of damage. On top of which comes the outright loss of the stock, generally unsellable and impossible to re-export. These consequences fall on the importer, not on the Chinese factory, which is not subject to European law.

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Compliance: CE marking and GPSR on import

By placing a product on the European market, an importer does not merely buy goods: it takes on the manufacturer's obligations. That is the point most files discover during an inspection, never before.

Updated September 2026

CE marking is not a certificate

No authority issues the CE marking. It is a declaration by which the person responsible for placing the product on the market states, under its own responsibility, that the product meets the requirements of the European texts applicable to it. The mark on the product is only the visible trace of that declaration.

Hence a consequence suppliers are happy to leave vague: a « CE certificate » issued by an unknown laboratory proves nothing in itself. It may be a useful test report, filed with the documentation — it is neither an authorisation nor, on its own, proof of conformity.

Nor does the marking apply to every product: it is required only for those covered by a text that demands it. Toys, electrical equipment, machinery and personal protective equipment are covered. Ordinary clothing textiles are not.

By importing, you become responsible

European law does not treat you as a mere reseller. An importer placing a product on the Union market takes on obligations of its own: verifying that the manufacturer has carried out the required assessments, holding the EU declaration of conformity, ensuring the technical file exists and can be produced on request, and putting its own contact details on the product or its packaging.

If you market the product under your own brand, you are no longer merely an importer: you are legally treated as the manufacturer, with every obligation that entails.

GPSR, applicable since December 2024

Regulation (EU) 2023/988 on general product safety has applied since 13 December 2024. It replaced the former directive and tightened obligations on four points that bear directly on importing:

A responsible person established in the Union must be identified and appointed in writing for each product. Without one the product cannot be placed on the market — a point that blocks in particular non-Union manufacturers who were selling direct.
Their contact details must appear on the product, its packaging or the accompanying document.
Traceability must be organised: ten years upstream, six years downstream.
An internal register of complaints, accidents, recalls and corrective measures must be kept.

These obligations cannot be met retrospectively: they mean demanding the right documents from the factory before production, not after delivery.

What to demand from the factory, and when

The request must be made before production starts. A factory that has never produced for Europe often holds none of these documents, and finding that out after the mould has been cut is expensive.

The declaration of conformity, naming explicitly the European texts applicable — not a generic formula
The technical file: drawings, bill of materials, risk assessment
The test reports, issued by a laboratory accredited to ISO/IEC 17025, and bearing on the product as it will be delivered
Photographs of the marking as it will be applied, packaging and instructions included

A supplier that produces these four without hesitation has already exported to Europe. That, in itself, is a selection criterion.

Frequently asked questions

Is a CE certificate from the Chinese factory enough?: No. CE marking rests on a declaration of conformity drawn up under the responsibility of whoever places the product on the market, not on a certificate issued by a third party. A test report from an accredited laboratory is a useful part of the file, but it replaces neither the EU declaration of conformity nor the technical file, which the importer must be able to produce on request.
What is the responsible person required by GPSR?: An operator established in the European Union, appointed in writing, tasked with verifying that the declaration of conformity and technical documentation exist, keeping them available to the authorities and cooperating in case of risk. For a European importer this role is generally taken by the importing company itself. Their contact details must appear on the product, its packaging or the accompanying document.
Must every imported product carry CE marking?: No. CE marking is required only for products covered by a European text that demands it: toys, electrical and electronic equipment, machinery, personal protective equipment and medical devices, among others. An ordinary garment is not covered. All consumer products, however, fall under the general product safety regulation, CE marking or not.
Which products must carry CE marking?: Only those covered by a European text that requires it. Toys, electrical and electronic equipment, machinery, personal protective equipment, medical devices, radio equipment and construction products are among them. An ordinary garment, a leather article or a non-electrical piece of furniture are not. All of them nonetheless remain subject to the general product safety regulation.
What does a technical file contain?: The material needed to demonstrate the product's conformity: general description, design drawings and diagrams, list of standards applied, results of calculations and tests, risk assessment and test reports. It is not made public but must be producible at the request of market surveillance authorities. The importer must satisfy itself that it exists before placing the product on the market, and be able to access it thereafter.
What is an EU declaration of conformity?: The document by which the person responsible for placing the product on the market attests, under its sole responsibility, that the product meets the requirements of the applicable texts. It names those texts and the standards relied on explicitly, identifies the product and its manufacturer, and is signed. A generic declaration that merely asserts conformity without citing any text does not serve its purpose.
Who is liable if an imported product causes an accident?: The importer in the first place, once the manufacturer is established outside the European Union: European law treats it as the product's point of entry to the market and holds it answerable for its conformity. If the product is marketed under your own brand, you are legally equated with the manufacturer, with all the corresponding obligations. The factory's geographical distance does not soften that liability.
Does a product need laboratory testing?: For most regulated product families, demonstrating conformity rests on testing. What matters is the laboratory's accreditation — ISO/IEC 17025 is the reference — and that the tests bear on the product as it will be delivered, not on a prototype or an earlier version. Certain high-risk categories also require the involvement of a notified body designated by a member state.
What is the risk of importing a non-compliant product?: Withdrawal or recall of the product, detention at customs, administrative penalties, and civil liability in case of damage. On top of which comes the outright loss of the stock, generally unsellable and impossible to re-export. These consequences fall on the importer, not on the Chinese factory, which is not subject to European law.

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