What CE marking and RoHS mean when you import from China into the EU, which documents to request from your supplier and your duties as the importer.
If you import products into the European Union, you are not just a buyer: legally, you are the importer, and you share responsibility for the product’s compliance. CE marking and RoHS are two of the requirements that come up most often with products made in China. This guide explains the basics. It is general information, not legal advice, and the exact rules depend on your product.
What CE marking means
CE marking shows that a product meets the EU requirements that apply to it. It is not a quality mark and it is not issued by an authority in most cases: the manufacturer declares conformity after carrying out the required assessment.
CE marking only applies to products covered by specific EU legislation, for example:
- Electrical equipment (Low Voltage Directive).
- Products that can cause or suffer electromagnetic interference (EMC Directive).
- Radio equipment, including Wi-Fi and Bluetooth (Radio Equipment Directive).
- Toys (Toy Safety Directive).
- Machinery and personal protective equipment.
If no CE legislation covers your product, it must not carry the CE mark, but it must still be safe under the General Product Safety Regulation.
What RoHS means
RoHS restricts hazardous substances such as lead, mercury, cadmium and certain flame retardants and phthalates in electrical and electronic equipment. For products within its scope, RoHS compliance is part of the CE declaration.
Other chemical rules can also apply. REACH, for example, restricts certain substances in many consumer products, not only electronics.
Documents to request from your supplier
- EU Declaration of Conformity naming the product, the legislation and the standards applied.
- Test reports from a recognized laboratory, for the exact model you are buying.
- Technical documentation: description, drawings, components list and risk assessment. The authorities can request it.
- User instructions and safety information in the languages of the countries where you sell.
Red flags in compliance documents
- A “CE certificate” from an unknown body for a product that only requires a self-declaration. It is not necessarily wrong, but it does not prove compliance on its own.
- Test reports for a different model, or with a different company name.
- Old reports that do not cover current standards or later changes to the product.
- Reports that cannot be verified with the laboratory that issued them.
Your duties as the importer
Before you place a product on the EU market, you must make sure that:
- The correct conformity assessment has been carried out.
- The technical documentation exists and can be provided on request.
- The product carries the CE mark (if applicable) and the required labels.
- Your name and contact address appear on the product, its packaging or an accompanying document.
- The product comes with instructions and safety information in the local language.
You must also keep the declaration of conformity available for the authorities, usually for ten years.
Other markets
Other markets have their own systems: UKCA for Great Britain, FCC rules for electronics in the United States and CPSIA requirements for children’s products in the US, among others. Check the rules for each market before production, not after.
How to reduce the risk
- Agree on the required standards and documents in the purchase contract.
- Check documents before production starts.
- Test a sample in an independent laboratory when the product carries real safety risks.
Zyntral can review a supplier’s certifications and documents before you commit through certification consulting, and coordinate the paperwork with customs support.
