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Suppliers and imports Importer 6 min read

We doubt that the supplier's certificate is genuine

Many supplier 'CE certificates' are not documents EU law asks for. For low voltage equipment the manufacturer declares conformity itself, and only a notified body can issue an EU-type examination certificate where an act requires one. Check the issuer and its number in the Commission's NANDO list, confirm the certificate with the body, match the model and standard, and treat an unverified certificate as no evidence.

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Reviewed 4 October 2026 by the Conphora compliance team · Not legal advice

Why this happens

EU product law knows only a few documents that prove conformity, and a 'CE certificate' is usually not one of them. For low voltage equipment, the manufacturer follows module A, internal production control: it draws up the technical documentation, which includes test reports, affixes the CE marking and draws up an EU declaration of conformity, declaring on its sole responsibility that the equipment meets the requirements (Directive 2014/35/EU, Annex III). By drawing up the declaration, the manufacturer assumes responsibility for compliance (Article 15(4)). No notified body takes part.[1]

Where an act requires third-party assessment, the model in Decision No 768/2008/EC is module B, type examination (the decision calls it EC-type examination). A notified body examines the design and, where the type meets the requirements, issues a certificate that contains the name and address of the manufacturer, the conclusions of the examination, any conditions for its validity and the data needed to identify the approved type (Annex II, Module B, point 6). The body informs the other notified bodies of certificates it refuses, withdraws or suspends (point 8). The Commission assigns each notified body one identification number and publishes the list of bodies with their numbers and notified activities (Annex I, Article R24).[2][3]

The Commission's Blue Guide explains how to use that list. Notified bodies are conformity assessment bodies designated and notified by their national authority; to be eligible, a body must be a legal entity established in a Member State, although it may work in third countries. The NANDO website can be searched by act, country, number or keyword, and withdrawn or expired notifications stay visible in a separate part of the site. Voluntary certification cannot be put on the same footing as market surveillance; authorities must take due account only of reports and certificates from accredited bodies (section 7.4.1; Regulation (EU) 2019/1020, Article 11(5)).[4][5]

For the importer, the question is not whether a document looks official but whether the product conforms. Before placing low voltage equipment on the market, the importer must ensure that the manufacturer has carried out the appropriate conformity assessment, drawn up the technical documentation and affixed the CE marking; an importer with reason to believe the equipment does not conform may not place it until it does (LVD Article 8(2)). For consumer products outside the harmonised acts, the GPSR places the same check on the manufacturer's file (Regulation (EU) 2023/988, Article 11(1)). Customs suspend the release where there is reasonable doubt about the authenticity of the documentation or the CE marking was affixed in a false or misleading manner (Regulation (EU) 2019/1020, Article 26(1)).[1][4][6]

How to solve it

  1. Read what the document claims to be

    Sort the paper first. A declaration of conformity is the manufacturer's own statement. A test report comes from a laboratory and covers named tests on a named sample. An EU-type examination certificate is issued by a notified body where an act requires third-party assessment. Anything else, such as a 'certificate of compliance' from a testing company, is a voluntary document: it does not replace the declaration or the technical documentation. Authorities take due account of reports and certificates from a body accredited for that work, but voluntary certification does not exempt a product from market surveillance.

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  2. Check whether a notified body was needed at all

    Low voltage equipment is assessed under module A, internal production control: the manufacturer declares conformity on its sole responsibility, without a notified body. For such a product, the supplier's 'CE certificate' cannot replace the technical documentation and the declaration. Where an act does require a notified body, its identification number follows the CE marking when it is involved in the production control phase.

  3. Look the issuer up in NANDO

    The Commission publishes the list of notified bodies with their identification numbers and the acts and activities they are notified for. Search by number, act or country. A body must be established in a Member State to be notified, and withdrawn or expired notifications are moved to a separate part of the site. A body that is not listed for that act cannot issue a notified-body certificate under it.

  4. Confirm the certificate with the issuer

    Write to the body named on the certificate and ask it to confirm the certificate number, the holder, the model and that the certificate is still valid. Notified bodies keep copies of the certificates they issue and inform each other of certificates they refuse, withdraw or suspend. The law gives an importer no right to an answer; if the body does not reply, ask the manufacturer to have it confirm in writing.

  5. Match the document to your product

    An EU-type examination certificate names the manufacturer, the conditions for its validity and the data that identify the approved type. Compare those with your product, the label, the manufacturer's name and the standard editions in your file. A genuine certificate for another type is no evidence for yours.

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  6. Treat an unverified certificate as no evidence

    If the certificate cannot be confirmed, you are back to the question of whether the product conforms. An importer with reason to believe a product does not conform may not place it on the market until it does, and where it presents a risk must inform the manufacturer and the market surveillance authorities.

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What you need to show

DocumentWhere it comes fromLegal ground
The manufacturer's EU declaration of conformityThe manufacturerLVD Articles 8(2), 8(8) and 15
The type-examination certificate with its annexes (EC-type in Decision No 768/2008/EC, EU-type in the 2014 directives), where the act requires oneThe manufacturer, issued by a notified bodyDecision No 768/2008/EC, Annex II, Module B, points 6 and 9
The NANDO entry and the issuer's written confirmationThe Commission's notified bodies list and the body itselfDecision No 768/2008/EC, Annex I, Article R24(2)
Your comparison of certificate, product and technical fileYour quality filesLVD Article 8(2); GPSR Article 11(1)

If you do nothing

Customs stop the goods on the document

Release for free circulation is suspended where there is reasonable doubt about the authenticity, accuracy or completeness of the required documentation, or where a CE marking has been affixed in a false or misleading manner (Regulation (EU) 2019/1020, Article 26(1)(a) and (c)).[4]

The product is treated as non-compliant

Importers may place only compliant electrical equipment on the market (LVD Article 8(1)). Where a non-compliance persists, the authority can prohibit or restrict the product or order its withdrawal or recall (Regulation (EU) 2019/1020, Article 14(4)(h)).[1]

Your own name is on the line

The importer's name and address are on the product (LVD Article 8(3)), so the authority contacts you first, whatever the supplier's certificate says.[1]

Questions about this problem

Does every CE-marked product need a certificate?

No. Under the Low Voltage Directive the manufacturer follows module A, internal production control, and declares conformity on its sole responsibility (Annex III, point 1). A notified-body certificate exists only where the applicable act requires third-party assessment.

Can a laboratory outside the EU be a notified body?

To be notified, a body must be established in a Member State. Notified bodies may carry out their activities in third countries, so a test location outside the EU is possible, but the issuing body must be the notified legal entity listed in NANDO (Blue Guide, sections 5.2.1 and 5.2.2).

What does the four-digit number after the CE marking mean?

It is the identification number the Commission assigns to a notified body, one number per body even when it is notified under several acts (Decision No 768/2008/EC, Annex I, Article R24(1)). It follows the CE marking where that body is involved in the production control phase (Article R12(3)).

The certificate was real but has been withdrawn. What now?

Ask the manufacturer for the current certificate or the outcome of a new assessment. Until you have it, you have reason to doubt conformity, and the importer may not place the product on the market (the importer article of the act concerned, modelled on Decision No 768/2008/EC, Annex I, Article R4(2)).

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Related problems

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Regulations involved

GPSRLVD

Sources

  1. Directive 2014/35/EU on electrical equipment (Low Voltage Directive), consolidated text of 30 May 2026 EUR-Lex · accessed 4 October 2026
  2. Decision No 768/2008/EC on a common framework for the marketing of products EUR-Lex · accessed 4 October 2026
  3. NANDO — notified bodies list (Single Market Compliance Space) European Commission · accessed 4 October 2026
  4. Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026) EUR-Lex · accessed 4 October 2026
  5. The 'Blue Guide' on the implementation of EU product rules 2022 (2022/C 247/01) European Commission, via EUR-Lex · accessed 4 October 2026
  6. Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026) EUR-Lex · accessed 4 October 2026

About this page

Reviewer
Conphora compliance team
Reviewed
4 October 2026

General information, not legal advice. Check the legal text or ask an adviser about your own product.

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Cite this page 
Conphora (2026). We doubt that the supplier's certificate is genuine. Retrieved 13 October 2026 from https://www.conphora.com/solutions/problem/supplier-fake-certificate/
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