Applying for the CE marking is a mandatory step for many sellers on online marketplaces. Whether you import products from China or manufacture them yourself, you can't sell certain products in the European Economic Area (EEA) without the CE marking. In this comprehensive article, we'll walk you through the CE marking process step by step, explain the costs, highlight common mistakes to avoid, and show you how to stay compliant as a bol.com seller.
What is the CE marking exactly?
The CE marking (Conformité Européenne) is a mandatory certification mark that indicates a product meets European health, safety, and environmental standards. It serves as a kind of passport that allows products to be freely traded within the entire EEA - which includes all EU member states plus Norway, Iceland, and Liechtenstein. It's not a quality certification in the classical sense, but a legal declaration of conformity.
The CE marking is based on the so-called New Approach directives of the European Commission. These directives set out essential requirements that products must meet before they can be placed on the European market. The CE marking gives consumers and market authorities confidence that the product meets these requirements.
Which products require a CE marking?
Not all products require a CE marking, but it does apply to a wide range of product categories. Here's an overview of the main categories where applying for a CE marking is mandatory:
| Product category | Relevant EU directive | Examples |
|---|---|---|
| Toys | Toy Directive 2009/48/EG | Dolls, puzzles, board games |
| Electrical equipment | Low Voltage Directive 2014/35/EU | Chargers, lamps, kitchen appliances |
| Machinery | Machinery Directive 2006/42/EG | Industrial machinery, tools |
| Medical devices | MDR 2017/745 | Thermometers, blood pressure monitors |
| Personal protective equipment | PPE Regulation 2016/425 | Helmets, safety glasses, gloves |
| Electronic devices (EMC) | EMC Directive 2014/30/EU | Computers, phones, Bluetooth speakers |
| Construction products | Construction Products Regulation 305/2011 | Doors, windows, insulation materials |
| Gas appliances | Gas Appliances Regulation 2016/426 | Gas heaters, barbecues |
If you import products via China or Alibaba, there's a good chance that a CE marking is required. Always check which directives apply to your specific product.
The CE marking process in 6 steps
The process of applying for a CE marking may seem complex, but it can be broken down into six clear steps. Here's a detailed step-by-step guide:
Step 1: Determine the applicable EU directives
Identify which European directives and harmonized standards apply to your product. A product may fall under multiple directives - for example, an electric toy must comply with both the Toy Directive and the EMC Directive and the Low Voltage Directive. Use the EU database on EUR-Lex or consult the European Commission's website for an overview of directives.
Step 2: Check product-specific requirements
Each directive sets out specific essential requirements. Study the harmonized standards (EN standards) that apply to your directive. These standards provide a detailed technical framework that your product must comply with. You can request standards from the Dutch Standardization Institute (NEN).
Step 3: Determine if a notified body is required
For some low-risk products, you can perform the conformity assessment yourself (self-certification). For higher-risk products, such as medical devices or personal protective equipment, you must involve a notified body. This independent organization assesses whether your product meets all the requirements. You can find a list of notified bodies in the NANDO database of the European Commission.
Step 4: Test the product
Conduct the necessary tests to demonstrate that your product meets the essential requirements. This can range from physical safety tests to electromagnetic compatibility tests (EMC) and chemical analyses. Keep all test results carefully - they form an essential part of your technical file.
Step 5: Compile the technical file
Document all evidence in a technical file. This file must remain available for at least 10 years and be presented to market surveillance authorities upon request. It includes, among other things:
- Product description and technical drawings
- List of applied harmonized standards
- Test reports and results
- Risk analysis
- Instructions for use and safety instructions
- Quality assurance and production controls
Step 6: Draw up the EU Declaration of Conformity and affix the CE marking
Draw up a formal EU Declaration of Conformity. This document declares that your product complies with all applicable directives. Sign it and then affix the CE marking to the product. The CE logo must be at least 5 mm high, visible, legible, and indelible on the product, packaging, or accompanying documents.
Costs of applying for CE marking
The costs of applying for CE marking vary widely, depending on the product category, risk level, and whether you need to involve a notified body. Below is an indicative overview:
| Component | Indicative costs | Explanation |
|---|---|---|
| Self-certification (low risk) | €500 – €2,000 | Own conformity assessment, minimal test costs |
| External tests (EMC, LVD) | €1,000 – €5,000 | Dependent on product complexity |
| Notified body assessment | €3,000 – €15,000+ | Mandatory for high-risk products |
| Compiling the technical file | €500 – €3,000 | Optional outsourcing to a consultant |
| Hiring a CE consultant | €2,000 – €10,000 | Guidance throughout the entire process |
For simple consumer electronics like a USB charger, you can expect to pay between €1,000 and €3,000. For complex medical devices, costs can run into tens of thousands of euros. Take this into account in your profit calculation.
Responsibilities per role in the supply chain
CE marking has clear responsibilities, depending on your position in the supply chain:
Manufacturer
The manufacturer bears primary responsibility for CE marking. They must ensure the product complies with all applicable directives, perform the conformity assessment (possibly with a notified body), compile the technical file, draw up the Declaration of Conformity, and affix the CE marking.
Authorized Representative
If the manufacturer is based outside the EER, they can appoint an authorized representative within the EER. This representative takes on certain responsibilities, such as making the technical file available to market authorities.
Importer
If you import products, you are legally required to verify that the manufacturer has correctly followed the CE marking process. You must check that the technical file is available and that the declaration of conformity is present. If in doubt, you are not allowed to bring the product to market. This is particularly relevant if you buy products via Alibaba.
Distributor
Distributors must have sufficient knowledge of the legal requirements and be able to identify products that clearly do not meet the requirements. They must be able to provide a statement from the manufacturer or importer that the products are compliant.
CE Marking on bol.com and Amazon
Both bol.com and Amazon require products to comply with all applicable laws and regulations, including CE marking. Both platforms are increasingly strict about compliance:
- Bol.com may request documentation such as a declaration of conformity or test reports. If CE marking is missing, your listing may be removed.
- Amazon has a comprehensive compliance program and may request documents before you can list products. Non-compliant products are removed immediately.
- Market surveillance authorities such as the NVWA and the Inspectie Leefomgeving en Transport regularly check products on online marketplaces.
As a seller on these platforms, you are responsible for the CE conformity of your products. Use product research tools to check in advance which requirements apply to the product categories you are considering.
Common Mistakes in CE Marking Applications
Mistakes are often made during the CE marking process. Here are the most common pitfalls:
Confusion between CE Certificate and Declaration of Conformity
There is no official "CE certificate". Manufacturers who claim to have a CE certificate often refer to test reports (such as EMC or LVD reports). These reports are only part of the technical file. The declaration of conformity (Declaration of Conformity) is the official document - and must always be signed by the person who brings the product to the European market.
Reliance on Chinese Suppliers' Certificates
Chinese manufacturers sometimes provide a "CE certificate", but this is not always reliable. As an importer, you are responsible for verifying that the tests have been carried out by a recognized test laboratory and that all relevant directives are covered. If in doubt, have independent tests carried out in Europe.
Incomplete Directive Application
Many sellers only check one directive, while their product may fall under multiple directives. For example, a Bluetooth speaker must comply with the EMC directive, the Low Voltage Directive, and the Radio Equipment Directive (RED). Always check all applicable directives.
No Technical File Available
The technical file must be available for at least 10 years after the last product has been placed on the market. Many sellers forget to create or maintain this file, which can lead to fines during inspections.
Applying the CE Mark Correctly
Applying the CE mark is subject to strict rules. The logo must:
- Must be at least 5 mm high (unless the guideline specifies otherwise)
- Must be visible, legible, and indelible
- Must be placed on the product itself, or if that's not possible, on the packaging or accompanying documents
- Must meet the exact graphical specifications set out in EU legislation (the right proportions and font)
- Must be accompanied by the identification number of the notified body if it was involved in the conformity assessment
Frequently Asked Questions about CE Marking Applications
How Long Does it Take to Apply for a CE Marking?
The entire process typically takes 4 to 12 weeks, depending on the complexity of the product and whether a notified body is required. Self-certification is faster.
Can I Apply for a CE Marking Myself?
Yes, for low-risk products, the manufacturer can perform the conformity assessment themselves and apply the CE marking. For high-risk products, the involvement of a notified body is mandatory.
What Happens if I Sell Without a CE Marking?
Selling without the required CE marking is a violation of the law. This can lead to fines, product recalls, removal of your listings on bol.com and Amazon, and in severe cases, criminal prosecution.
Is the CE Marking Still Valid in the UK After Brexit?
No, the United Kingdom has its own UKCA marking since Brexit. If you also want to sell in the UK, you'll need both CE and UKCA.
Do I Need to Arrange for a CE Marking as a Reseller?
As a distributor or reseller, you don't need to apply for a CE marking yourself, but you are required to check if the products you sell are properly marked.
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