--- title: "A retailer asks for proof that the CE mark is real" description: "The CE marking is the manufacturer's own claim, and there is no general CE certificate to send. The proof is the EU declaration of conformity under the Low Voltage, EMC or Radio Equipment Directive, backed by technical documentation and test reports, and a notified body certificate only where the act required one. Send the declaration for the exact model, explain the evidence and show the marking on the product." type: "problem" url: "https://www.conphora.com/solutions/problem/retailer-asks-ce-proof/" markdown: "https://www.conphora.com/solutions/problem/retailer-asks-ce-proof.md" locale: "en" language: "en" updated: "2026-10-05" author: "Conphora compliance team" publisher: "Conphora" source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0035-20260530" tags: ["LVD", "EMC", "RED", "marketplace-retailer"] license: "Free to quote with attribution and a link to the page" --- # A retailer asks for proof that the CE mark is real The CE marking is the manufacturer's own claim, and there is no general CE certificate to send. The proof is the EU declaration of conformity under the Low Voltage, EMC or Radio Equipment Directive, backed by technical documentation and test reports, and a notified body certificate only where the act required one. Send the declaration for the exact model, explain the evidence and show the marking on the product. ## Why this happens The CE marking is a declaration, not a seal from a third party. Under Regulation (EC) No 765/2008, only the manufacturer or its authorised representative affixes the CE marking, and only to products for which a Union act provides for it (Article 30(1) and (2)). By affixing it, the manufacturer indicates that it takes responsibility for the product's conformity with all applicable requirements of those acts (Article 30(3)). The CE marking is the only marking that attests that conformity, and markings likely to mislead about its meaning or form are prohibited (Article 30(4) and (5)). The Commission's Blue Guide calls it a key indicator, but not proof, of compliance (section 4.5.1.1). [4] [6] The evidence is the declaration and the file behind it. Under the Low Voltage Directive 2014/35/EU, the manufacturer draws up technical documentation, carries out the conformity assessment and, once compliance is demonstrated, draws up the EU declaration of conformity and affixes the CE marking (Article 6(2)). For low voltage equipment that assessment is internal production control: the technical documentation includes the standards applied and test reports (Annex III, point 2). The declaration follows the model in Annex IV, and where several acts require a declaration, there is a single one naming them all (Article 15(2) and (3)). The EMC Directive 2014/30/EU and the Radio Equipment Directive 2014/53/EU have the same structure (EMC Article 15; RED Article 18). [1] [2] [3] A notified body takes part only in some routes. Under the EMC Directive, the manufacturer may choose EU-type examination followed by conformity to type instead of internal production control (Article 14). Under the Radio Equipment Directive, EU-type examination or full quality assurance is mandatory for the requirements in Article 3(2) and (3) where harmonised standards were not applied, were applied only in part or do not exist (Article 17(4)); under full quality assurance, the notified body's identification number follows the CE marking (Article 20(3)). Radio equipment must also be accompanied by a copy of the declaration or a simplified declaration with the internet address of the full text (Article 10(9)). [2] [3] Retailers ask because they carry a check of their own. Under the Low Voltage Directive, distributors verify before selling that the equipment bears the CE marking and is accompanied by the required documents and instructions, and must not sell equipment they have reason to believe does not conform (Article 9(2)). At the border, customs suspend the release of products bearing a CE marking affixed in a false or misleading manner (Regulation (EU) 2019/1020, Article 26(1)(c)). [1] [5] ## How to solve it 1. **Ask what kind of proof the retailer needs** Find out whether the retailer wants the declaration of conformity, a summary of the evidence, or access to test reports. Its own requirements are set by agreement; the legal evidence is the same whatever it asks for. 2. **Send the declaration for the exact model** Send the EU declaration of conformity that names the model the retailer sells and every act that applies to it in one document, with the standards and their versions, the notified body where one took part, and the date and signature. 3. **Show the evidence behind the declaration** List the harmonised standards applied and the test reports that cover them for this model. Offer the reports, or a summary of their results, according to what you agree with the retailer. The full technical documentation stays available for authorities. 4. **Explain where a notified body is and is not involved** Low voltage equipment is assessed by the manufacturer alone. Under the EMC Directive the manufacturer may choose an EU-type examination. Radio equipment needs a notified body where harmonised standards were not applied in full for certain requirements. Send the certificate only where one exists. 5. **Show the marking on the product** Send photos of the CE marking on the product or its data plate and, for radio equipment, also on the packaging, with the notified body number where the act requires it. The retailer must check the marking before it sells. ## What you need to show - **EU declaration of conformity naming the model and all applicable acts** — The manufacturer or its authorised representative (LVD Article 15; EMC Directive Article 15; RED Article 18) - **List of harmonised standards and the test reports that cover them** — The manufacturer's technical documentation (LVD Annex III point 2(d) and (f)) - **EU-type examination certificate, only where the act or the chosen route requires one** — A notified body (EMC Directive Article 14(b); RED Article 17(4)) - **Photos of the marking on the product, data plate and packaging** — Your product file (LVD Article 17; RED Article 20) ## If you do nothing - **Customs suspend the goods** — Customs suspend release for free circulation where a product bears a CE marking affixed in a false or misleading manner, or lacks required documentation (Regulation (EU) 2019/1020, Article 26(1)(a) and (c)). - **Penalties for improper use of the marking** — Member States provide for penalties for infringements of the CE marking regime, which may include criminal sanctions for serious infringements (Regulation (EC) No 765/2008, Article 30(6)). - **The retailer may not sell** — Before making electrical equipment available, a distributor verifies that it bears the CE marking and comes with the required documents, and must not sell it if it has reason to believe it does not conform (LVD Article 9(2)). ## Questions ### Is there such a thing as a CE certificate? Not as a general document. The manufacturer declares conformity itself in the EU declaration of conformity. A certificate from a notified body exists only where the act, or the route the manufacturer chose, involves one. Documents called CE certificates from testing companies are not required by any of these acts and do not replace the declaration; a test report from an accredited body is evidence authorities must take due account of (Regulation (EU) 2019/1020, Article 11(5)). ### Does the CE marking prove that the product complies? No. The Commission's Blue Guide calls the CE marking a key indicator, but not proof, of compliance. By affixing it, the manufacturer takes responsibility for conformity with every act that provides for it (Regulation (EC) No 765/2008, Article 30(3)). ### Our product has Bluetooth. Does it need a notified body? Only in some cases. Under the Radio Equipment Directive, a notified body procedure is required for the requirements in Article 3(2) and (3) where harmonised standards were not applied, were applied only in part, or do not exist (Article 17(4)). This includes the Article 3(3) requirements that Delegated Regulation (EU) 2022/30 applies to certain internet-connected radio equipment until Delegated Regulation (EU) 2026/339 repeals it on 11 December 2027. Otherwise internal production control is allowed. ### Can the retailer demand the full technical documentation? The law keeps the technical documentation for the authorities. How much the retailer sees is set by agreement. A declaration, the standards list and the relevant test reports usually answer the question. ### Who may put the CE marking on the product? Only the manufacturer or its authorised representative, and only on products for which an act provides for it (Regulation (EC) No 765/2008, Article 30(1) and (2)). An importer or retailer adds no CE marking of its own. ## Regulations involved LVD, EMC, RED ## Sources 1. [Directive 2014/35/EU on electrical equipment (Low Voltage Directive), consolidated text of 30 May 2026](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0035-20260530) — EUR-Lex, 2026-10-04 2. [Directive 2014/30/EU on electromagnetic compatibility, consolidated text of 30 May 2026](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0030-20260530) — EUR-Lex, 2026-10-04 3. [Directive 2014/53/EU on radio equipment, consolidated text of 30 May 2026](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0053-20260530) — EUR-Lex, 2026-10-04 4. [Regulation (EC) No 765/2008 on accreditation and the CE marking, consolidated text of 16 July 2021](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008R0765-20210716) — EUR-Lex, 2026-10-04 5. [Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1020-20260812) — EUR-Lex, 2026-10-04 6. [The 'Blue Guide' on the implementation of EU product rules 2022 (2022/C 247/01)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52022XC0629(04)) — European Commission, via EUR-Lex, 2026-10-04