CE DOCUMENT WORKFLOW / 01
Verify the route before you judge the paperwork.
Most disputes about CE documents from China are not about forgery. They come from two parties describing different documents with the same words, and from nobody having established which conformity assessment route the product actually falls under. Settle the route first; the rest of the checks then have something to test against.
Name the document you are actually asking for
“CE certificate”, “CE declaration”, “test report” and “certificate of conformity” are used interchangeably in supplier correspondence and mean different things. Record which one you received, who issued it, for which product identification, against which standards, and on what date.
The EU declaration of conformity is a short document drawn up and signed by the manufacturer. It identifies the product, lists the Union legislation claimed, lists the harmonised standards applied, and names the person who signed on the manufacturer’s behalf. It is not issued by a third party and is not something a supplier can purchase.
A glossy document titled “CE Certificate” carrying a CE logo is not the declaration and is often not required at all. Ask for the declaration and the technical documentation by name.
Work out who has to sign it before asking the supplier for it
Establish your own role first. If you buy goods manufactured in China and place them on the EU market under your own name or trade mark, you take on the manufacturer’s obligations for those goods, and the declaration is yours to draw up and sign. If you distribute them under the manufacturer’s brand, the manufacturer signs and you must be able to obtain the declaration on request.
That answers a common deadlock: a supplier who says “send me a sample for reference” or “do you mean REACH?” may simply never have been asked before. What you need from them in that case is the underlying evidence — test reports, product description, drawings, list of standards applied — not their signature on a template you wrote.
Whoever signs the declaration carries the liability for the claims in it. Deciding that question first determines what you are asking the supplier to provide.
Establish the conformity assessment route
Which route applies depends on the product and the legislation covering it. Under the Electromagnetic Compatibility Directive 2014/30/EU, an apparatus assessed against the applicable harmonised standards runs on internal production control: the manufacturer carries out the assessment, compiles the technical documentation, affixes the CE marking and signs the declaration, with no notified body in the process.
This matters because it changes what “missing paperwork” means. On a self-assessed route there is no certificate for the supplier to fail to produce — the test report and the technical file are the evidence, and a third-party certificate is optional decoration. Other legislation and higher-risk product categories do require third-party involvement, so confirm the applicable acts for your specific product rather than generalising from one directive.
The route is set by the legislation covering the product, not by the country of manufacture. Establish the applicable acts for your product before deciding which documents are mandatory.
Verify any notified body claim at source
Where third-party assessment is required, only a body notified for that specific legislation may carry it out. Every notified body is listed in the European Commission’s NANDO database under a four-digit identification number, together with the legislation and product scope it is notified for.
Take the number from the document and look it up. A number that does not appear, or that appears but is notified for unrelated legislation, settles the question on its own. Where the identification number is genuine but you still have doubts about a specific certificate, contact the notified body through a channel you sourced yourself rather than one printed on the document under review.
A notified body certificate does not normally carry the CE logo on the certificate itself. The CE marking belongs on the product, not on the paperwork about it.
Verify the laboratory and its accredited scope
On a self-assessed route the test report does the work, so the question becomes whether the laboratory was competent for that test. A report worth relying on names the laboratory and its accreditation under ISO/IEC 17025, with an accreditation number you can look up.
For mainland Chinese laboratories, the China National Accreditation Service for Conformity Assessment publishes accredited bodies together with the scope each is accredited for. Confirm two things, not one: that the laboratory holds current accreditation, and that the specific testing on your report falls inside its accredited scope. Accreditation for one discipline says nothing about another.
A competent laboratory tested whatever was submitted to it. Nothing in the accreditation establishes that the sample came from your supplier’s production or matches your order.
Match the report to your product and to the standard version
Your exact model or part number has to appear in the report. Where a supplier covers a product family with one report, the grounds for grouping — typically a shared circuit or shared construction — must be argued in the technical documentation, in writing, with the reasoning shown. A message saying “all models use the same circuit” is the beginning of that argument, not the end of it, and whoever signs the declaration is the party who has to defend it.
Then read the year printed next to each standard. Harmonised standards give presumption of conformity only while their references stand in the Official Journal of the European Union. When a version is superseded, the date that governs is the cessation date published there, not the date the standards body withdrew the old text, and a defined period during which both versions remain usable is normal.
Notified body status, laboratory accreditation and standard references all change. A check has a date attached to it, and a check from six months ago is not evidence today.
DOCUMENT MATCH / 02
What each document can and cannot support
| Document | What it can support | What it does not establish |
|---|---|---|
| EU declaration of conformity | The signing party’s claim that the identified product meets the listed legislation | That the claim was independently assessed, or that current production still matches |
| Test report from an accredited laboratory | Results for the submitted sample against the named standard and version | That the sample came from your supplier’s production or matches your order |
| Notified body certificate | Third-party assessment within the scope printed on the certificate | Anything outside that scope, including other models or other legislation |
| “CE certificate” from an unaccredited issuer | Nothing in itself | Compliance, assessment, or that any testing took place |
| Supplier letter covering a product family | A statement of the grouping the supplier proposes | The technical justification, which belongs in the technical documentation |
METHOD AND LIMITATIONS / 03
What this guide is and is not
This guide describes how to read supplier documents against official public sources. It is not legal advice, not a conformity assessment, and not a substitute for professional regulatory support on your specific product. Which Union legislation applies, and which route within it, is a determination about your product that this guide cannot make for you.
Every check described here returns a source, a date and a limit. A verification result records what a named official source showed on a named date. It does not certify that a supplier is reliable, that goods are safe, or that a future shipment will match a past sample.
PRIMARY SOURCES / 04
Official sources used for this guide
Links were checked on 4 August 2026. Re-open the source record before a material decision, because notified body scope, laboratory accreditation and harmonised standard references all change.
- European Commission — Notified bodies (NANDO)Official database of notified bodies, searchable by legislation, listing each body’s four-digit identification number and notified scope.
- European Commission — Notified bodies overviewExplains when third-party conformity assessment is required and what a notified body designation covers.
- European Commission — Electromagnetic Compatibility Directive 2014/30/EUScope and obligations under the EMC Directive, used here as the worked example of a self-assessed route.
- European Commission — Harmonised standardsHow presumption of conformity arises from references published in the Official Journal, and how supersession is handled.
- China National Accreditation Service for Conformity AssessmentOfficial China accreditation body publishing accredited laboratories and the scope each is accredited for.
- National Enterprise Credit Information Publicity SystemOfficial China public-registration system used to match the legal entity named on the document to the entity on your contract.
COMMON QUESTIONS / 05
Keep the paperwork question separate from the supplier question
- My supplier does not know what a declaration of conformity is. Is that a red flag?
- Not on its own. Many factories have never issued one because their EU customers always drew it up themselves. Establish who has to sign yours, then ask for the underlying evidence rather than the signature.
- They sent a CE certificate. Is that the same thing?
- No. On a self-assessed route no such certificate is required, and one issued by an unaccredited body establishes nothing. The declaration plus the technical documentation is what carries the claim.
- How do I tell a real test report from one produced to look reassuring?
- Check the laboratory’s accreditation number and confirm the specific testing falls inside its published accredited scope, check that your exact model appears, and check the standard version against current Official Journal references.
- The report covers a different model in the same series. Is that acceptable?
- Only if the grounds for grouping are argued in the technical documentation with the reasoning written down. The party signing the declaration is the party who has to defend that grouping.
- Am I being overly cautious asking for all this?
- Market surveillance obligations follow the party who placed the goods on the market. Where that is you, the documentation is what you would be asked to produce.