CE and Compliance Documents to Demand When Importing from China

Do not ask a Chinese supplier for “the CE certificate” and assume the job is finished. CE marking applies only to product categories covered by specific EU legislation, and for many products there is no official CE certificate issued by an authority. The core legal document is usually the manufacturer's EU Declaration of Conformity, supported by technical documentation and appropriate conformity evidence. What you must obtain depends on the exact product, how it is sold and whether you import it under the supplier's brand or your own.

1. Start with the product and the applicable EU rules

• Define the exact product. Record the model, variants, intended use, users, power source, radio functions, materials, installation method and markets. Small differences can change the applicable requirements.
• Identify all applicable legislation. A product may simultaneously fall under electrical safety, electromagnetic compatibility, radio equipment, machinery, ecodesign, RoHS, batteries or other EU rules.
• Confirm whether CE marking applies. CE marking is required only when the product is covered by legislation that requires it. It must not be placed on products outside that scope.
• Check non-CE requirements too. Consumer products may be subject to the General Product Safety Regulation, chemical restrictions, traceability, labelling, language, packaging and national obligations even when no CE mark is required.
• Use the European Commission's official CE-marking guidance and product-specific legislation rather than the supplier's certificate list as your starting point.

2. Manufacturer, supplier and product identity

• Legal manufacturer details. Obtain the full registered company name, address, Chinese business licence and contact details. Confirm whether the factory, trading company and declared manufacturer are the same entity.
• Model correspondence. Create a table linking your purchase-order reference, commercial model, factory model, test-report model, label model and Declaration of Conformity model.
• Variants and families. If one report is claimed to cover several models, demand the technical rationale showing why the tested representative is valid for every variant.
• EU economic operator. Confirm whose name and postal/electronic address must appear as importer, authorised representative or other responsible person under the applicable rules.
• Reject documents issued to an unrelated company unless the legal and technical relationship to your product is documented.

3. EU Declaration of Conformity — not a generic “CE certificate”

• Demand a product-specific EU Declaration of Conformity containing the manufacturer, product identification, applicable EU legislation, standards or specifications used, responsible signatory, place, date and signature.
• The declaration should cover every applicable CE-marking act, not only the easiest one. An electrical product may require several legal references.
• Check that the legislation and standards are correctly identified and appropriate to the product. A long list copied from another declaration is not evidence of conformity.
• The signatory must be authorised to bind the manufacturer. A laboratory report does not replace the manufacturer's signed legal declaration.
• Some product regimes use another document, such as a Declaration of Performance for construction products or a Declaration of Incorporation for partly completed machinery. Obtain the document required by the actual legislation.
• The European Commission describes the EU Declaration of Conformity as a mandatory manufacturer-signed legal document for products subject to the relevant rules.

4. Test reports and conformity-assessment certificates

• Request full reports. A cover page, certificate, screenshot or supplier spreadsheet is not enough. Obtain the complete report with product photos, model identification, test methods, results and conclusions.
• Check scope and edition. Confirm that the standards, amendments and test clauses match the product and the applicable requirements at the time it is placed on the market.
• Check the sample. Product photos, ratings, PCB, components, construction and accessories in the report must correspond to the goods you will receive.
• Check the laboratory. Verify the issuing body's identity, report number and relevant accreditation scope. Contact the laboratory directly when authenticity or model coverage is material.
• Understand third-party involvement. Many CE regimes permit manufacturer self-assessment; others require a notified body. Demand a notified-body certificate only when the applicable conformity-assessment procedure requires one, and verify the body and scope in NANDO.
• Record all failures, deviations, conditional results and supplier-provided components. “PASS” on the first page does not cancel limitations inside the report.

5. Technical documentation and risk assessment

• The technical file should explain the product's design, manufacture and operation and demonstrate how every applicable essential requirement is met.
• Typical content includes a product description, intended use, drawings, schematics, bill of materials, critical-component list, calculations, standards applied, risk assessment, test reports, labels, instructions and manufacturing-control evidence.
• Ask for a technical-file index and the key documents needed to evaluate your risks. Contractually require the manufacturer to maintain and provide the complete file to you or authorities within a defined deadline.
• If you sell under your own name or brand, modify the product or sign the Declaration of Conformity yourself, supplier promises are insufficient: you need control of the documentation that supports your manufacturer responsibilities.
• Ensure the file reflects the production version, not only an early sample. Establish change control for critical components, firmware, materials, suppliers and manufacturing sites.
• Official EU guidance explains that technical documentation must demonstrate compliance and support the Declaration of Conformity.

6. Product marking, labels and traceability

• CE marking. Verify the design, minimum size, visibility, legibility and permanence. A notified-body identification number must appear only where the legislation and assessment procedure require it.
• Product identification. The product should carry a type, batch, serial number or other element allowing it to be traced to the documentation and production record.
• Economic-operator details. Check the required manufacturer, importer, authorised representative or EU responsible-person name and postal/electronic contact information.
• Technical ratings. Confirm voltage, frequency, power, capacity, pressure, load, ingress protection and other safety-relevant ratings against the tested product.
• Other required marks. Depending on the product, these may include WEEE, battery, recycling, energy, radio, food-contact or hazard information.
• Approve final artwork before production and verify the actual labels during pre-shipment inspection. A compliant PDF does not prove that the factory applied it correctly.

7. Instructions, warnings and safety information

• Obtain the complete user, installation, assembly, maintenance and disposal instructions required for safe use.
• Instructions and safety information must be supplied in the languages required by each country where the product is sold. Machine translation without technical review is a product risk.
• Check that warnings address the residual risks identified in the risk assessment and match the product labels, intended users and foreseeable misuse.
• Verify model references, drawings, accessories, technical ratings, maintenance intervals and troubleshooting information against the production product.
• Control the final language files and printing revision. Do not let the factory replace approved manuals or labels without written approval.

8. Chemical, environmental and sustainability evidence

• RoHS. For electrical and electronic equipment in scope, obtain a supplier declaration supported by material or component evidence and risk-based analytical testing. “RoHS compliant” on an invoice is not enough.
• REACH and SVHC. Ask for material declarations, candidate-list screening and substance information relevant to the product. There is no universal official “REACH certificate”. Consider laboratory testing for high-risk materials.
• Persistent organic pollutants and restricted substances. Identify additional restrictions relevant to plastics, coatings, textiles, flame retardants or other materials.
• Batteries. Obtain battery specifications, safety test evidence, transport test summary where applicable, markings, removability information and supply-chain data required by current battery rules.
• Environmental schemes. Determine WEEE, packaging, batteries, furniture, textiles, energy labelling, ecodesign, EPREL or other producer-responsibility obligations in each target country. Supplier documents do not replace the importer's registrations and reporting.

9. Product-specific documents to add

• Radio products: radio test reports, frequency bands, output power, software/firmware identification, antenna configuration and cybersecurity evidence where applicable.
• Electrical equipment: safety, EMC and RoHS evidence; critical-component certificates; ratings; insulation and construction details.
• Machinery: risk assessment, drawings, control-system and safety-function evidence, instructions, Declaration of Conformity and, where relevant, documents for partly completed machinery.
• PPE, pressure equipment, gas appliances and other regulated products: the required notified-body certificates, surveillance documents and product-specific markings.
• Construction products: applicable harmonised specification, Declaration of Performance, CE information and evidence for declared performance.
• Food-contact materials, toys, cosmetics, medical devices and other specialised categories: obtain the declarations, testing, registrations and responsible-person documentation required by their own legal regimes.
• Energy-related products: ecodesign evidence, energy-label data, product information sheet and EPREL registration where required.

10. Red flags in supplier document packs

• A colourful “Certificate of Compliance” is offered as the only CE evidence, with no Declaration of Conformity or technical file.
• The applicant, manufacturer, factory, brand or model differs between the quotation, label, declaration and reports.
• Only the basic model was tested, but the supplier claims every size, power rating, material and electronic configuration is covered without analysis.
• Reports are cropped, password-protected, unsigned, missing pages or too blurred to identify the sample and results.
• Standards are unrelated to the product, important legislation is omitted or dates predate major design changes.
• Product photos show different plugs, components, enclosures, ratings or PCB layouts from the ordered version.
• The supplier refuses direct laboratory verification, technical questions or change-control commitments.
• A document says “CE approved”, “CE registered” or “EU certified” without identifying the legal assessment route behind the claim.

11. Importer document checklist before shipment

• ☐ Product classification and every applicable EU and national requirement are documented.
• ☐ Manufacturer, factory, importer and model identities are consistent across all records.
• ☐ The correct signed declaration — EU DoC, DoP or other required document — is complete.
• ☐ Full test reports cover the production model, variants, ratings and current design.
• ☐ Required notified-body involvement and certificates have been independently verified.
• ☐ The technical-file index, risk assessment and critical supporting evidence are available.
• ☐ Product, packaging and online-offer markings have been approved and inspected.
• ☐ Instructions and warnings are technically reviewed in every required language.
• ☐ Chemical, environmental, battery and product-specific evidence is complete.
• ☐ Changes between the tested sample and production goods are identified and assessed.
• ☐ Document-retention, authority-response and supplier change-control obligations are contractual.
• ☐ Remaining gaps are closed before paying the balance or authorising shipment.

12. If the product carries your own brand

• EU rules generally treat you as the manufacturer when you have a product made and place it on the market under your own name or trademark.
• Do not merely replace the brand on the label and reuse the supplier's declaration. Establish a documented link between your model and the tested construction, then prepare the legally correct declaration and technical file for your role.
• Obtain design and test-document rights, component specifications, supplier declarations, change notifications and continued access to evidence after the commercial relationship ends.
• Control every variant and future production change. A valid assessment can become invalid when the factory substitutes a power supply, radio module, material, firmware or safety-critical component.
• Use a competent laboratory or compliance specialist when the legal scope, conformity route or technical evidence is uncertain. Document review is not a substitute for required testing.

What this looks like in practice

Panda United collects the supplier's document pack in China, builds a model-and-document consistency matrix, checks declarations, reports, labels and manuals for obvious gaps, and follows clarification or laboratory verification with the supplier. We do not issue CE certification or replace the manufacturer's or importer's legal assessment. Our role is to make missing, inconsistent or unsupported evidence visible before the balance is paid and the product is shipped to Europe.