A supplier emails you a “CE certificate” for your smart switch. It looks official. It has a number, a stamp, a lab logo. You file it away and place the order — and then EU customs asks for the technical documentation, and you discover the certificate proves almost nothing.
That scenario is routine in electronics importing, because the two most misunderstood ideas in EU compliance are that CE marking is a quality mark (it is not) and that RoHS has a certificate (it does not). This guide explains what importers actually need, document by document.
CE marking: a legal declaration, not a quality mark
CE marking (“Conformité Européenne”) is the most important conformity label for products sold in the European Economic Area. It indicates that a product has been assessed and meets EU requirements for safety, health, and environmental protection. But it is not a quality mark — it is a legal declaration by the manufacturer that the product complies with all applicable EU legislation. It is mandatory for more than 20 product groups, including electrical and electronic equipment.
For a typical mains-powered or USB-powered electronic product, three directives usually apply at once:
- Low Voltage Directive 2014/35/EU (LVD) — electrical safety, for products running on mains voltage (230/400 V AC).
- EMC Directive 2014/30/EU — electromagnetic compatibility, for electronics powered by adapter, battery, or USB, or with a mains power supply.
- RoHS Directive 2011/65/EU + (EU) 2015/863 — restriction of hazardous substances (covered below).
Depending on the product, others can apply too: the Ecodesign rules, the Radio Equipment Directive (RED) for anything with Wi-Fi or Bluetooth, and since December 13, 2024, the General Product Safety Regulation (EU) 2023/988 (GPSR), which replaced the older General Product Safety Directive. Under GPSR, every product on the EU market must have an EU economic operator responsible for it — a manufacturer, importer, authorised representative, or fulfilment service provider based in the EU. If you are a manufacturer based outside the EU, you must appoint an EU-based Responsible Person or Authorised Representative.
CE marking must not be applied to products that are not covered by CE-relevant directives. Doing so is illegal and counts as deception.
RoHS: 10 substances, no certificate
The RoHS Directive restricts hazardous substances in electrical and electronic equipment (EEE) — equipment that needs electric current or electromagnetic fields for at least one intended function, with a voltage rating up to 1,000 volts AC or 1,500 volts DC. The original RoHS Directive 2002/95/EC was replaced by RoHS 2 (2011/65/EU), and the RoHS 3 amendment (EU) 2015/863 expanded the restricted substance list from 6 to 10 chemicals, adding four phthalates (DEHP, BBP, DBP, DIBP). All electronic goods placed on the EU market must comply with the latest RoHS 3 requirements, and RoHS compliance is a mandatory prerequisite for CE marking for most EEE.
The critical point: there is no such thing as a RoHS “certificate.” Compliance is demonstrated with documents — a Declaration of Conformity, technical documentation per EN IEC 63000 (the only harmonised standard still active; EN 50581 was withdrawn), and test reports (XRF screening and/or ICP analysis). A supplier who offers only a “RoHS certificate” and no test report has not demonstrated compliance.
Who is responsible: the role trap
RoHS gives each party in the chain its own duties, and your role decides what you must do:
- Manufacturer — whoever makes the product, or has it designed or made and sells it under their own name or trade mark. If you sell under your own brand, you are the manufacturer, even when a factory in China makes the product. The manufacturer must design and make the product to meet the limits, draw up the technical documentation, carry out the conformity assessment, draw up the EU Declaration of Conformity, affix the CE marking, and keep the documents for 10 years.
- Importer — a party in the EU that places products from outside the EU on the EU market. The importer must check that the conformity assessment was done, that the documentation exists, and that the product carries the CE marking, and put its own name and address on the product.
- Authorised representative — holds a written mandate from the manufacturer, but never takes over the two core duties: designing and making the product to meet the limits, and drawing up the technical documentation.
If you sell directly to EU customers from outside the EU, there is often no EU importer. RoHS is one of the laws listed in Article 4(5) of Regulation (EU) 2019/1020, so the product may then only be placed on the EU market if an economic operator established in the EU is responsible for it. Its name and postal address must be on the product, the packaging, the parcel, or an accompanying document.
For most electronics, conformity assessment follows Module A (internal production control) under Decision 768/2008/EC and does not require a Notified Body. For higher-risk products such as medical devices, pressure equipment, and personal protective equipment, Notified Body assessment is mandatory — you can search for a suitable body in the EU’s NANDO database.
The documents to demand from your supplier
For each product, request this set before you pay the balance:
- EU Declaration of Conformity (DoC) from the manufacturer — a single declaration stating the exact model, signed by the manufacturer, referring to the LVD, EMC, and RoHS directives (with the applicable standards and their year of publication). A DoC in the name of the test lab instead of the manufacturer is a red flag. Keep the DoC for 10 years and be able to present the technical documentation on request.
- RoHS test report — XRF screening and/or ICP analysis covering all 10 substances, for your exact model. Check the report date, the lab, and the model number on the report.
- EMC and LVD test reports from an accredited lab, again for your exact model and configuration. A report for a similar model is not a report for your model.
- Technical documentation per EN IEC 63000 — typically supplier declarations for materials and components, test reports where the risk calls for them, and an assessment of which parts are most likely to contain restricted substances.
- Certificate of Compliance (CoC) from the test lab — recommended as supporting evidence, but a CoC on its own proves nothing.
Red flags to walk away from: only a “CE certificate” or CoC with no test report; a DoC that does not name your exact model; test reports from an unknown lab with no accreditation; a supplier who cannot explain which directives apply to your product.
What to do when the supplier’s paperwork is thin
If the factory’s documentation does not cover your model — common when you changed the housing, the power supply, or the firmware — you have three options: ask the factory to test your exact configuration (and pay for it if needed), commission testing yourself through a lab in China or the EU before shipment, or choose a different factory whose paperwork already matches. What you cannot do is ship and hope: EU market surveillance authorities can demand the technical documentation, and “the factory said it was fine” is not a defense.
Note also that requirements change: the Ecodesign rules and energy labelling (Regulation (EU) 2017/1369) can apply to your product, and for energy-related products you may need to register in EPREL before sale as the importer. Check the current rules for your product category before each new launch — and treat any specific figure in this article as a starting point to verify against the official texts, not as legal advice.
Sources
- Euronorm Advies, “Document check for importers | CE Import Document Guide” — https://www.euronorm.net/en/pages/importeurstool
- ComplianceGate, “EU Restriction of Hazardous Substances Directive (RoHS): An Essential Guide” — https://www.compliancegate.com/rohs-directive/
- TradeAider, “RoHS Compliance Guide | Restriction of Hazardous Substances for EU Electronics” — https://www.tradeaiders.com/wiki/rohs-compliance
- Westwood Sourcing, “RoHS for Sellers Outside the EU: Who Does What” — https://www.westwoodsourcing.com/blog/services-14/rohs-sellers-outside-eu-who-does-what-248
- Ideal Group, “Which Certification Is Required for Products Sold in Europe?” — https://www.ideal-group.de/en/which-certification-is-required-for-products-sold-in-europe/