Skip to content
Third-party product inspection, explained
Product Inspection

CE marking: what an importer or distributor is expected to check

Sources checked

The European Commission's "Importers and distributors" page states that when importing from non-EU countries, importers must check that products fulfil all EU safety, health and environmental protection requirements before placing them on the market. The page says the importer has to verify three things: that the manufacturer outside the EU has taken the necessary steps to allow the product to be placed on the EU market, that the necessary documentation such as the EU Declaration of Conformity and the technical documentation is available upon request, and that contact with the manufacturer is possible at any time. Below is what that page and the related EU texts say for each role.

What the importer checks

The three items on the Commission page are the manufacturer's steps, the documentation, and manufacturer contact.

  • the manufacturer outside the EU has taken the necessary steps to allow the product to be placed on the EU market
  • the necessary documentation such as the EU Declaration of Conformity and the technical documentation is available upon request
  • contact with the manufacturer is possible at any time

The same page adds: "As they are the intermediaries between manufacturers and traders, they must have overall knowledge of the legal requirements and make sure that the products they distribute or import meet them."

The Blue Guide defines the importer as "a natural or legal person established in the Union who places a product from a third country on the EU market."

The reference provisions in Decision No 768/2008/EC address this in three articles, quoted as published in the Official Journal. Article R4(1): "Importers shall place only compliant products on the Community market." Article R4(2): "Before placing a product on the market importers shall ensure that the appropriate conformity assessment procedure has been carried out by the manufacturer." Article R4(3): "Importers shall indicate their name, registered trade name or registered trade mark and the address at which they can be contacted on the product or, where that is not possible, on its packaging or in a document accompanying the product."

For products under the General Product Safety Regulation, Regulation (EU) 2023/988, Article 11(1) requires that "Before placing a product on the market, importers shall ensure that the product complies with the general safety requirement laid down in Article 5 and that the manufacturer has complied with the requirements set out in Article 9(2), (5) and (6)." Article 11(3): "Importers shall indicate their name, their registered trade name or registered trade mark, their postal and electronic address and, where different, the postal or electronic address of the single contact point at which they can be contacted." That Regulation applies from 13 December 2024.

What the distributor checks

The Commission page says: "Distributors must handle the product carefully and they mustn't affect its compliance with EU legislation. The distributor has to know which products must bear the CE marking and the accompanying documentation. They should be able to identify products that are not in compliance."

The same page says distributors must be able to demonstrate to national authorities that they:

  • have confirmation from the manufacturer or the importer that the necessary measures have been taken
  • are able to assist national authorities in their efforts to receive the required documentation

The Blue Guide defines the distributor as "a natural or a legal person in the supply chain, other than the manufacturer or the importer, who makes a product available on the market."

Article R5(1) of the reference provisions in Decision No 768/2008/EC: "When making a product available on the market distributors shall act with due care in relation to the requirements applicable."

Under Regulation (EU) 2023/988, Article 12(1): "Before making a product available on the market, distributors shall verify that the manufacturer and, where applicable, the importer have complied with the requirements set out in Article 9(5), (6) and (7) and Article 11(3) and (4), as applicable."

Selling under your own name

The Commission page states: "If importers or distributors market the products under their own names, they take over the manufacturer's responsibilities. In this case, they must have sufficient information on the design and production of the product because they will be assuming the legal responsibility when affixing the CE marking."

The Blue Guide puts it more broadly: "If the importer or distributor or another operator places products on the market under his own name or trademark or modifies them, he then takes over the manufacturer's responsibilities."

Article R6 of the reference provisions in Decision No 768/2008/EC states that "An importer or distributor shall be considered a manufacturer for the purposes of this ... [act] and he shall be subject to the obligations of the manufacturer under Article [R2], where he places a product on the market under his name or trademark or modifies a product already placed on the market in such a way that compliance with the applicable requirements may be affected."

What the CE marking does and does not show

The Commission's CE marking page notes that "Please note that a CE marking does not indicate that a product have been approved as safe by the EU or by another authority. It does not indicate the origin of a product either." That page also states that "Not all products must have CE marking. It is compulsory only for most of the products covered by the New Approach Directives. It is forbidden to affix CE marking to other products." On the same page, affixing the CE marking is a manufacturer's declaration that the product meets all the legal requirements for CE marking and can be sold throughout the EEA, and this also applies to products made in other countries that are sold in the EEA.

The Blue Guide describes the marking as "a key indicator (but not proof) of a product's compliance with EU legislation" and notes that "CE marking does not indicate that a product was made in the European Union."

Your Europe adds a practical point: "There is no central EU body that gives you permission or a certificate allowing you to use the CE mark," and "The manufacturer is responsible for ensuring that a product meets all applicable EU requirements and for affixing the CE marking."

Documents the importer keeps

The Blue Guide says to "Keep a copy of the EU Declaration of Conformity for 10 years after the product has been placed on the market (142) or for the period specified in the relevant Union harmonisation act." It adds: "For imported products, the importer must take on this responsibility for the Declaration of Conformity (224)."

For products under Regulation (EU) 2023/988, Article 11(6) states that "Importers shall keep the copy of technical documentation referred to in Article 9(2) at the disposal of the market surveillance authorities for a period of 10 years after they have placed the product on the market and shall ensure that the documents referred to in Article 9(2), as applicable, can be made available to those authorities, upon request."

Your Europe states that "The CE marking refers to the compliance of the product at the moment it was placed on the EU market," and that "the EU Declaration of Conformity (DoC) and the technical documentation that supports it must be kept up to date retained for at least 10 years after the product is placed on the market."

Questions people ask

Do I need CE marking for my product?

Your Europe states that "CE marking is only required for products covered by harmonised EU rules that specifically mandate it. If no such EU requirements exist for your product, CE marking must not be used." It also notes that "Products that do not require CE marking are subject to general product safety rules which ensure they are safe for consumers."

Does putting my name on a product make me the manufacturer?

The Blue Guide says that if an importer or distributor or another operator places products on the market under his own name or trademark or modifies them, he then takes over the manufacturer's responsibilities.

Sources

Checked 11 October 2026. This page is an unofficial summary and is not affiliated with the European Commission or any EU body; the official text governs.

Inspection Guide