CE marking for small electronics sold in the EU

Short answer. Before you pay for a first order you need a signed European Union declaration of conformity, test reports from an accredited laboratory and a technical file for your exact product. If the product has a battery you also need battery and air transport papers. The company that puts the product on the EU market under its own name is responsible for all of it. A certificate from the factory does not move that responsibility away from you.

This page is general information and not legal advice.

Which rules apply to your product

CE marking is the mark a manufacturer puts on a product to declare that it meets every European Union rule that applies to it. Which rules apply depends on what the product does.

• Radio Equipment Directive 2014/53/EU. Applies if the product sends or receives radio signals: Bluetooth, Wi-Fi, GPS tracking, mobile data. It covers safety, electromagnetic compatibility and use of the radio spectrum. Connected devices also face cybersecurity requirements that have applied since August 2025.
• Electromagnetic Compatibility Directive 2014/30/EU. Applies to electronics without a radio. The product must not disturb other devices and must work near them.
• Low Voltage Directive 2014/35/EU. Applies to electrical equipment between 50 and 1,000 volts alternating current or 75 and 1,500 volts direct current. A mains charger usually falls here.
• Restriction of Hazardous Substances Directive 2011/65/EU. Limits lead, mercury, cadmium, hexavalent chromium, two flame retardant groups and four phthalates.
• Batteries Regulation 2023/1542. Applies if the product contains or comes with a battery.

A radio product is normally assessed under the Radio Equipment Directive alone. A product with a radio and a mains charger can still need several of these. Your laboratory or your sourcing partner should confirm the list before testing starts.

Documents to ask the factory for

Ask before you approve a sample. Ask again before bulk production.

1. EU declaration of conformity. A signed statement naming the product and listing each directive and standard applied, with the legal manufacturer's name and address.
2. Test reports from an accredited laboratory. Each report must name your exact model and the standards tested. Check that the laboratory is accredited for those tests.
3. Technical file. Drawings and circuit diagrams, parts list, risk assessment, test reports, user manual. Kept for 10 years after the product is placed on the market.
4. Restriction of Hazardous Substances report or material declaration for the product and its parts.
5. Battery papers. Battery type and chemistry, a safety data sheet and the UN 38.3 test summary for lithium batteries, which is needed to ship them by air.
6. Manual and labels in the language of each country you sell in. Radio products must state frequency bands and maximum radio power.

Who is responsible in the European Union

If you put your own name on the product you are treated as the manufacturer and carry the main duty. If the factory is outside the EU the importer takes on duties too: checking that the CE marking and documents exist and keeping the declaration for 10 years. The General Product Safety Regulation 2023/988 has applied since 13 December 2024 and requires an economic operator established in the EU for every consumer product. Equilinq Limited is a Hong Kong company run from Amsterdam and does not act as your responsible operator; you or an authorised representative in the EU does. See the responsible person guide.

Common traps with certificates from China

• A certificate for a different product. The report covers a similar model or an older version. Compare the model name and the board revision.
• No accredited laboratory. A factory letter or a self-written test sheet is not a laboratory report.
• A declaration with no standards listed. It must list the directives and standards.
• Old or wrong standards. Check they are current for the directive.
• Battery cells tested, not the pack. Transport tests are done on the pack as shipped.
• Only the radio module tested. A tested module helps. The finished product still needs its own assessment.
• Design changes after testing. A new battery or board after the test makes the report invalid for that version.
• Replaceable batteries. From 18 February 2027 portable batteries in most products must be removable by the user, with exceptions. Check at the design stage.

Checklist before the first order

List the directives that apply. Confirm who the legal manufacturer is on the declaration. Get the signed declaration, the laboratory reports for the exact model, the hazardous substances report, the battery papers and UN 38.3 summary, and the technical file or a written plan to build it. Agree who the responsible operator in the EU is. Check the manual and labels. Re-check everything on the pre-production sample.

Further reading

Read the GPSR responsible person guide and how to read a China quote. New products start with Build; existing ones go through Source. Equilinq collects and checks this document set before the factory is paid; the compliance pack is priced on Pricing.