The CE mark appears on nearly every electronic device sold in Europe, but very few businesses can answer exactly on what legal basis the mark is applied. And that is the point where the goods are held back.
This article explains what CE marking actually is, what directives commonly apply to electronics, why WEEE is not included in the CE marking directives, and five common mistakes.
1. The CE mark is not a certification
CE marking is the result of the manufacturer’s (or authorized representative’s) self-assessment and declaration that the product meets all applicable directives. This is not a third-party certification for most common electronic products.
Three important consequences:
- The CE mark is only correct when the documents are correct: Without corresponding documents, the CE mark is invalid.
- The CE mark covers many directives at the same time: The lack of an applicable directive means that the CE marking is invalid for the entire product.
- Responsibility belongs to the person who affixes the seal: usually the manufacturer, or the importer when the product comes from outside the EU.
2. Directives often apply to electronic goods
| Directives/regulations | Content | When to apply |
|---|---|---|
| Electromagnetic compatibility (EMC) | The device does not cause excessive interference and is tolerant to interference | Nearly every device has electronic circuits |
| Low Voltage Safety (LVD) | Safe for equipment to operate within a specified voltage range | Equipment in the a.c. voltage range of approximately 50 V to 1,000 V or the corresponding d.c. range |
| Radio equipment (RED) | Requirements for equipment with radio transmitting or receiving functions | The device has Wi-Fi, Bluetooth, and mobile signal |
| RoHS | Restrict substances in electrical and electronic equipment | Equipment covered by the Directive |
| Eco design/sustainable products | Requirements by product group | When the product belongs to the adjusted group |
| General product safety | Safety requirements for consumer products | Widely applicable, including products under the voltage range of LVD |
Point to note: many electronic products have small capacity or use low DC power not covered by LVD. Then it is still necessary to meet safety requirements, but the basis of assessment lies in general product safety regulations, not LVD.
3. Why is WEEE different?
| Criteria | The directive belongs to the CE marking group | WEEE |
|---|---|---|
| CE marking facility | Yes | No |
| Nature of obligation | Safety, electromagnetic compatibility, limited substances | Registration, volume reporting, collection and recycling responsibilities |
| Management agency | Market surveillance agency | Environmental agency of each member state |
| Labeling requirements | CE marking and identification information | Individual collection symbols and manufacturer identification information |
| Place of performance | According to the manufacturer’s technical records | According to registration in each country |
In other words: WEEE is a parallel obligation but not a “leg” of the CE marking. Businesses must still meet both, but do not use WEEE records to prove CE marking and vice versa.
4. Five common mistakes
| Mistake | Reality | Consequences |
|---|---|---|
| Apply CE mark when only RoHS test report is available | Lack of EMC, electrical safety and other directives | CE marking is not valid on the entire product |
| Apply LVD to all electronic products | LVD only applies within a specified voltage range | Making wrong documents costs unnecessary money |
| Eliminate EMC for devices with digital circuits | Digital circuits almost always involve electromagnetic compatibility requirements | Missing an instruction, the goods are detained |
| Consider WEEE as part of the CE mark | WEEE is a separate obligation, not part of the seal application | Not registered in the country of sale |
| Do not update records when design changes | Changing components, sources, and antennas can all affect results | CE marking based on records is no longer correct |
5. How to determine enough “legs” before stamping
- Determine the nature of the product: Is there an electronic circuit, is there a radio function, what is the operating voltage?
- List applicable directives According to each of those characteristics, record it in the records according to the product code.
- Prepare separate documents for each directive: Test reports, evaluations, design documents.
- Check obligations beyond the CE mark: WEEE, registered by country, requires private label.
- Sign the unified declaration of conformity clearly state the applicable directives.
6. Frequently asked questions
Is third-party certification required for CE marking?
For most common electronic products, no. Manufacturers make their own assessments and take responsibility. Some product groups have their own requirements for designated organization participation.
Does a product using a 5V battery have to be made LVD?
Normally not within LVD range if operating outside the applicable voltage range. However, it still must meet general product safety requirements, EMC and RoHS.
Is WEEE needed to sell products on e-commerce platforms?
Yes. E-commerce platforms in the EU often require proof of WEEE registration and responsible person in the EU, in addition to CE records.
If I only sell goods to businesses, do I have to have CE stickers?
It still applies if the product falls within the scope of the directives, whether sold to businesses or consumers. CE marking is required to be attached to the product, not to the sales channel.
How long do CE records stay?
According to the time limit specified by each directive; with RoHS, it is ten years from the time the product is brought to market. The longest period of the applicable directives should be applied.
7. Conclusion
CE marking for electronic goods is the result of several directives at once: electromagnetic compatibility, electrical safety (if within the applicable voltage range), radio equipment (if applicable), RoHS and eco-design requirements where applicable. WEEE is a parallel obligation but is not included in the group of CE marking directives.
Three things to do: create a list of directives applicable to each product code; Prepare separate documents for each directive in the same dossier set; and check the obligations beyond the CE mark before delivering the first batch.
References
- Directive 2014/30/EU (electromagnetic compatibility) and Directive 2014/35/EU (low voltage safety).
- Directive 2014/53/EU on radio equipment (RED).
- Directive 2011/65/EU and its amendments (RoHS).
- Directive 2012/19/EU (WEEE) on waste electrical and electronic equipment.
Related articles
- Declaration of conformity (DoC) and CE marking for RoHS: who signs, for which products, what if it’s wrong?
- RoHS and WEEE: one side restricts the substance, the other side is responsible for recall
- 7 errors caused electronic shipments to be detained at EU border gates because of RoHS
- RoHS and ESPR/digital product passport: how will the way of proving compliance change?
Discuss further
Disclaimer
This article is an interpretive content compiled by us; not legal advice. Enterprises need to compare relevant documents/standards verbatim before applying them to specific products.
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