Do all products exported to Europe need CE marking?
No. CE marking is required only for products covered by specific EU product laws (often called “harmonised legislation”). Examples:
- Toys — Toy Safety Directive 2009/48/EC (a new Toy Safety Regulation (EU) 2025/2509 applies mainly from 1 August 2030)
- Electrical equipment within certain voltage limits — Low Voltage Directive 2014/35/EU
- Electronics — Electromagnetic Compatibility Directive 2014/30/EU, and RoHS 2011/65/EU on hazardous substances
- Products with radio, Wi-Fi or Bluetooth — Radio Equipment Directive 2014/53/EU, with cybersecurity requirements mandatory since 1 August 2025
- Machinery — Machinery Directive 2006/42/EC, replaced by the Machinery Regulation (EU) 2023/1230 from 20 January 2027
- Personal protective equipment — Regulation (EU) 2016/425
- Construction products — CE marking under the Construction Products Regulation, where a harmonised standard exists
Products such as most furniture, textiles, bags, kitchen utensils without electrics, decorations or stationery do not carry CE marking. They are still not “free”: they fall under the General Product Safety Regulation (GPSR) and, depending on the product, chemical, food-contact or textile labelling rules. Adding a CE mark to a product that does not need it is not allowed.
For CE products the manufacturer carries out the conformity assessment, prepares the technical file and signs the EU declaration of conformity. For some products and risk classes a notified body must be involved. A test report from a laboratory is evidence, not a certificate that replaces the declaration.
Requirements by product type
| Product type | CE marking | Main rules to check | Typical documents |
|---|---|---|---|
| Toys | Yes | Toy Safety Directive, EN 71 standards, chemicals; GPSR obligations for operators | Test reports, technical file, declaration of conformity, warnings in the local language |
| Electrical and electronic products | Yes | LVD, EMC, RoHS, RED if wireless; WEEE and battery rules; common charger for some devices | Test reports, technical file, declaration of conformity, WEEE/battery registration |
| Machinery and power tools | Yes | Machinery Directive, from 20.01.2027 Machinery Regulation; often also LVD and EMC | Risk assessment, technical file, manual in the local language, declaration |
| Furniture and wooden products | No | GPSR; REACH formaldehyde limits from 6 August 2026; EUDR for wood-based products | Test reports for emissions and stability, product information, supply-chain data |
| Textiles and clothing | No | GPSR; Textile Labelling Regulation (fibre composition); REACH (for example azo dyes, PFHxA) | Fibre labels, test reports for restricted substances |
| Kitchenware and food-contact items | No | Food-contact materials framework; specific rules for plastics; BPA ban | Declaration of compliance for food contact, migration test reports |
| Cosmetics | No | Cosmetics Regulation (EC) 1223/2009: EU responsible person, safety report, CPNP notification | Product information file, safety assessment |
| General consumer goods (gifts, home, sport, bags, stationery) | Usually no | GPSR; REACH; product-specific standards where they exist | Risk assessment, test reports where relevant, labels |
The table is a starting point. Products with batteries, lights, motors or wireless functions often fall into several rules at once. Check every product range before the first offer.
GPSR: the rule that applies to almost every consumer product
The General Product Safety Regulation (EU) 2023/988 has applied since 13 December 2024. Two points matter most for factories outside the EU:
- A product can only be placed on the EU market if an economic operator established in the EU is responsible for it: the EU manufacturer, the importer, an authorised representative or, if none of these exists, a fulfilment service provider (Article 16).
- The product must show a type, batch or serial number, the manufacturer’s name and postal and electronic address, and the EU responsible person’s details, on the product, its packaging or an accompanying document. Warnings must be in the language of the country of sale.
Online listings must show the same information. Read our GPSR guide for Chinese manufacturers.
Labels and language
Check for each product:
- Product identification: model, batch or serial number
- Manufacturer name, trade mark, postal address and e-mail or website
- EU responsible person or importer name and address
- CE mark where required, with the correct size and placement
- Warnings, age grading, instructions and safety information in the local language
- Product-specific marks: textile fibre composition, WEEE crossed-out bin, battery marks, food-contact symbol
Packaging requirements: PPWR and EPR
The EU Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) has applied since 12 August 2026. It requires conformity assessment and technical documentation for packaging, an EU declaration of conformity, traceability information on packaging (manufacturer, importer, batch or serial number) and limits on heavy metals, as well as limits on PFAS in food-contact packaging. Recycled-content and recyclability-label requirements apply in stages from 2028.
Separately, each EU country runs extended producer responsibility (EPR) systems: whoever first places packaged goods, electrical equipment or batteries on a national market usually has to register there and pay for collection and recycling. In Germany, for example, packaging registration in the LUCID register must be done by the obligated company itself. Under the WEEE Directive, a producer selling electrical equipment into a country where it is not established must appoint an authorised representative there. See EPR and packaging.
Chemicals: REACH
REACH applies to substances in almost all products. Two parts matter most for finished goods:
- Restrictions (Annex XVII) — limits for specific substances in specific products, for example formaldehyde emissions from furniture and wood-based products from 6 August 2026, PFHxA in consumer clothing from 10 October 2026, and microplastics.
- Substances of very high concern (SVHC) — if an article contains a substance on the Candidate List above 0.1% by weight, the supplier must inform professional buyers and, on request, consumers. The Candidate List is updated regularly.
Other points before export
- Customs classification — the customs code determines the duty rate and sometimes extra rules. The European Commission’s Access2Markets portal shows duties and requirements per product code.
- EORI number — the company that lodges customs declarations needs one; a non-EU company obtains it in the EU country of its first customs operation.
- Anti-dumping duties — some products from China carry additional duties. Check the code before you quote a delivered price.
- Intellectual property — do not copy European brands, designs or trademarks; customs can seize such goods.
Checklist: documents to prepare per product range
- List of applicable EU rules (CE directives or regulations, GPSR, REACH, product-specific rules)
- Test reports from a recognised laboratory against the relevant standards
- Technical file and EU declaration of conformity, where CE applies
- Risk assessment for GPSR
- Name and address of the EU responsible person
- Label artwork with all required information, warnings in local languages
- Instructions and safety information in local languages
- Packaging information for PPWR and EPR registrations in the countries of sale
- REACH statement on restricted substances and SVHC
- Customs code for each product
Common mistakes with EU documents
- A “CE certificate” bought online that is not linked to real tests or to the product actually shipped. Buyers and authorities check the declaration, the technical file and the test reports, not a nice-looking certificate.
- Old test reports against standards that have since been replaced, or reports for a different model.
- Changed materials after testing: a new supplier of plastic, paint or batteries can change the result.
- Labels in English only for consumer products sold in Germany, Poland or France.
- No EU address on the product or packaging, so the product cannot legally be placed on the market.
- Forgetting packaging: the product is compliant, but nobody registered the packaging for EPR in the country of sale.
How we can help
Before your first offer we check which EU rules apply to each product range, review your existing documents and labels and tell you what is missing. Our company in Poland can act as the GPSR responsible person, and registrations for EPR are arranged through trusted partners. The final conformity assessment remains the manufacturer’s responsibility, and where required a notified body’s. See EU compliance and CE marking.
