Ask a Chinese supplier whether a product has CE and the answer is almost always yes, often with a PDF attached within minutes. The document usually proves less than the buyer assumes — and occasionally proves nothing at all. This article is for companies importing commercial batches into the EU, or into markets whose rules mirror the EU model, and explains what CE marking actually is, what evidence stands behind it, and how to check that evidence rather than trust it.
CE is a declaration, not a certificate
The core misunderstanding: CE marking is self-declared by the manufacturer. For most product categories no external body issues anything. The manufacturer performs or commissions the required assessment, compiles a technical file, draws up an EU Declaration of Conformity, and applies the mark on their own responsibility.
So there is frequently no such thing as "the CE certificate." What exists is:
- the EU Declaration of Conformity — a document the manufacturer signs, naming the product, the directives and regulations applied, and the standards used;
- the technical file — drawings, risk assessment, test reports, manual — held and produced on request;
- and, only for certain products, a certificate from a notified body.
A supplier who sends a glossy one-page "CE Certificate" from a laboratory with no traceable identity has sent you a marketing artefact. A supplier who sends a Declaration of Conformity naming the exact directives, harmonised standards and model, plus the test reports behind it, has sent you evidence.
When a notified body is required
Some directives require a third party — a notified body — to be involved: type examination, quality system assessment or product verification. This applies to higher-risk categories such as certain machinery, personal protective equipment, pressure equipment, medical devices, some radio and gas equipment. Where a notified body was involved, its four-digit identification number appears next to the CE marking and on the certificate it issued.
That four-digit number is the single most useful thing on the document, because it is verifiable.
How to verify a notified body in NANDO
The European Commission maintains NANDO — the database of Notified and Designated Organisations — at ec.europa.eu/growth/tools-databases/nando. Only bodies listed there may issue EU certificates.
Three checks, each taking a minute:
1. Does the number exist, and does it belong to the organisation named on the certificate? 2. Is the body still designated, or was its designation withdrawn or suspended? 3. Does its scope cover your legislation and product type? A body notified for one directive cannot validly certify under another — a common and entirely checkable fraud.
If the certificate names no notified body but the product's directive requires one, the marking is not valid, regardless of how confidently the supplier states otherwise.
The "China Export" logo: a myth worth retiring
The most repeated story in importing circles is that a lookalike "China Export" mark exists, with the C and E spaced more tightly, deliberately designed to be mistaken for CE. It is a persistent internet legend: the European Commission investigated and found no evidence of any such mark being systematically used or registered.
What is real is simpler and more serious: manufacturers applying CE marking without doing the work behind it, and intermediaries issuing fabricated certificates. The threat is not a secret rival logo with narrower letter spacing — it is a genuine-looking mark with nothing behind it. Measuring the gap between the letters tells you nothing; verifying the declaration, the standards and the notified body tells you everything.
What to request from a Chinese supplier
- The EU Declaration of Conformity, on the manufacturer's letterhead, signed and dated, naming the model, the applicable directives and regulations, and the harmonised standards
- The test reports behind it, naming the standard and its edition, from an identifiable laboratory with an accreditation number
- The notified body certificate, where one is required, with the four-digit number
- Photographs of the actual marking and rating plate on production units
- The user manual and safety information in the language of the destination market
- A written statement that the certified configuration equals the produced configuration — component substitution voids the evidence, which is why this belongs in the contract with the factory
Red flags on the document itself
- No standards named, or standards named without edition or year
- A directive referenced by an outdated number — a giveaway that the template was reused
- The certificate is issued to a different company or a different model than the one you are buying
- The issuing body is a consultancy or trading company, not an accredited laboratory or a notified body
- A QR code or verification link that does not resolve — fabricated certificates have historically been paired with sham verification sites
- The document says "CE certificate" for a product category where no certificate exists at all
Deeper verification techniques — accreditation registries, laboratory scope checks, direct confirmation with the issuer — are in how to check whether a Chinese certificate is genuine.
Who carries the risk after import
The importer. Under the EU framework the importer must ensure the manufacturer carried out the conformity assessment, must hold the declaration, and must be identifiable on the product or accompanying documents. Newer EU legislation keeps extending this logic — the Packaging and Packaging Waste Regulation, for instance, makes importers verify supplier declarations and hold them for years, with obligations biting from 12 August 2026, which reaches into how your goods are packed as well as what they are. See packaging development in China.
The same principle underpins the Ukrainian system, described in technical regulations in Ukraine and the declaration of conformity, and the broader picture is in which documents you actually need to sell goods from China.
"We have CE" is not a fact about a product. It is a claim about paperwork you have not seen, made by the party with the least interest in your reading it carefully.
Verifying compliance evidence before the money moves
We check declarations against the directives that actually apply, verify notified bodies in NANDO and laboratories against their accreditation scopes, confirm the tested configuration matches the produced one, and arrange real testing where the evidence does not stand up. That runs alongside the factory checks in our verification protocol — seven years, 3,500+ deliveries, 340+ verified suppliers, with real projects in our case studies.
Start with supplier verification or document support.
