In short
To sell products made in China on the EU market, you need to know which EU rules apply, who is responsible, and which documents prove conformity. Depending on the product, the rules include CE-marking legislation (toys, electrical goods, radio equipment, machinery, PPE, construction products), the General Product Safety Regulation (EU) 2023/988, REACH and RoHS, the food contact rules, and the packaging, WEEE and batteries rules. When the factory is in China, the EU importer must check the conformity assessment, put its own name and address on the product and keep the declaration of conformity and technical documentation for 10 years. The weak point is usually the documents: certificates issued for another company or model, expired reports, or “CE certificates” from a body that is not notified. They must be checked against the actual product before the goods leave China.
Every Chinese supplier will tell you its product is “CE”. In our work as a purchasing office in China since 2008, that statement is where the checks start, not where they end. A certificate that does not match your product can block a container at customs, stop a retail listing or leave you liable for an unsafe product. This guide explains, in plain terms, which rules to look at, what the factory must give you and how we verify documents on the ground in China.
Which EU rules apply to my product?
Most products fall under several texts at once. An electric toy with a battery, for example, is covered by the toy, EMC, RoHS, REACH, WEEE, batteries and packaging rules. Use this table as a starting point.
| Product family | Main EU rules | What you need |
|---|---|---|
| Toys | Toy Safety Directive 2009/48/EC, REACH | CE marking, declaration of conformity, EN 71 test reports, warnings |
| Electrical and electronic goods | Low Voltage Directive 2014/35/EU, EMC Directive 2014/30/EU, Radio Equipment Directive 2014/53/EU (wireless), RoHS Directive 2011/65/EU, WEEE Directive 2012/19/EU | CE marking, declaration covering every directive, test reports, RoHS evidence, WEEE registration in each country of sale |
| Machinery | Machinery Directive 2006/42/EC, replaced by Regulation (EU) 2023/1230 from 20 January 2027 | CE marking, risk assessment, instructions in the local language |
| Personal protective equipment | PPE Regulation (EU) 2016/425 | CE marking, often a notified body certificate |
| Construction products | Construction Products Regulation (EU) No 305/2011, with a revised 2024 CPR being phased in | Declaration of performance and CE marking where a harmonised standard applies |
| Other consumer products (furniture, home goods, textiles…) | General Product Safety Regulation (EU) 2023/988 (GPSR), REACH | A safe product, traceability, an economic operator in the EU, instructions in the local language |
| Food contact items | Regulation (EC) No 1935/2004, Regulation (EU) No 10/2011 for plastics | Migration tests, declaration of compliance for plastics, food contact labelling |
| Batteries, and products containing them | Batteries Regulation (EU) 2023/1542 | Battery obligations phased in over several years |
| Packaging of all products | Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) | New packaging requirements, generally applicable from 12 August 2026 |
Three points to keep in mind:
- The GPSR has applied since 13 December 2024. It covers the safety of consumer products and fills the gaps left by sector rules.
- REACH limits hazardous substances in articles (for example certain phthalates, lead, cadmium and nickel release). If an article contains a substance of very high concern from the Candidate List above 0.1% by weight, you must inform your business customers and answer a consumer’s request within 45 days.
- Some texts are changing. The new Toy Safety Regulation (EU) 2025/2509 applies from 1 August 2030, when it repeals Directive 2009/48/EC. The Machinery Regulation applies from 20 January 2027. The Batteries Regulation has applied since 18 February 2024, with requirements rolling out until 2031. For recurring orders, check which version applies when each batch is placed on the market.
Who is responsible when the factory is in China?
The manufacturer designs the product and carries out the conformity assessment. But EU authorities cannot reach a Chinese factory. So the law requires an economic operator established in the EU, both for CE-marked products (Regulation (EU) 2019/1020, Article 4) and for consumer products under the GPSR (Article 16). In most import flows, that operator is you. If you sell under your own brand, you may be treated as the manufacturer.
| Topic | Chinese manufacturer | EU importer |
|---|---|---|
| Conformity | Runs the conformity assessment, uses a notified body when required | Checks it was done and the CE marking is applied |
| Documents | Draws up the technical file and the EU declaration of conformity | Keeps the declaration and access to the technical file for 10 years |
| Marking | Model, batch or serial number, its name and contact details | Adds its own name, trade name or trade mark and postal address on the product, packaging or accompanying document |
| Instructions | Writes instructions and safety information | Makes sure they are in the language of the country of sale |
Your name, address and the translated warnings change the rating label, the packaging print and the manual. They must be in the purchase order before production starts, not fixed after. Customs can suspend the release of goods when documents are missing or doubtful, when the CE marking is misleading or when the EU operator’s details are missing (Regulation (EU) 2019/1020, Article 26).
Which documents should you ask the factory for?
For a CE-marked product, ask for:
- The EU declaration of conformity, signed by the manufacturer, naming the exact model, the applicable directives or regulations and the standards used.
- The technical file: description, drawings, component list, risk assessment, standards applied and test reports. You must be able to obtain it if an authority asks.
- Test reports for the same model, materials and components as your order.
- The notified body certificate, when the legislation requires one.
- Chemical tests for REACH and, for electrical goods, RoHS.
- Product-specific documents: declaration of compliance for plastic food contact items, battery documents, manual and labels in your languages.
Keep the declaration of conformity and the technical documentation for 10 years after the product is placed on the market. This is the period set, for example, by the Low Voltage Directive for manufacturers and importers, and by the GPSR for consumer products. Our advice: list the required documents in the purchase order and link the balance payment to receiving them, as you would to a passed inspection. Our guide to managing production orders in China explains how this fits into order follow-up.
How do you check a Chinese certificate or test report?
Getting a PDF from a supplier is easy. The real question is whether it covers your product, made by your factory, today. These are the problems we see most often when we check supplier documents:
| Problem | What to check |
|---|---|
| Issued to another company | The name on the document is not your supplier, or is a trading company with no link to the factory making your order |
| Issued for another model | Model number, ratings, materials or components differ from your product |
| Expired or outdated | Validity date passed, or the standard has since been revised |
| “CE certificate” from a body that is not notified | A private certificate with a CE logo is not a notified body certificate and has no legal value as such |
| Test report sold as a certificate | A test report shows that one sample passed specific tests on one date; it is evidence for the technical file, not an approval |
| Altered document | Inconsistent dates or fonts, a report number the laboratory cannot confirm |
Notified bodies and NANDO. A notified body is an organisation designated by an EU country to assess certain products when the law requires a third party. Many electrical goods are self-declared by the manufacturer on the basis of test reports. Many PPE categories, some machinery and toys not fully covered by harmonised standards need a notified body. The European Commission lists notified bodies in the NANDO database, with their identification number and the legislation they are notified for. Check that the number on the certificate exists in NANDO and matches the right legislation.
Test reports. Ask the issuing laboratory to confirm the report number. Large accredited laboratories such as SGS, Intertek and Bureau Veritas, all present in China, can confirm whether a report is genuine. Then compare it with your product: model, photos, materials, components and standards. If the evidence is weak, test samples taken from your own production.
What to watch for by product
Toys
Toys need CE marking, a declaration of conformity, EN 71 test reports, age warnings and the importer’s details. Toys with batteries or electronics add the EMC, RoHS, WEEE and batteries rules. The documents must match the exact items in the container. In one of our client cases, a container of toys was blocked by French customs: the trader that sold them had disappeared, and the importer could not provide certificates and test reports for several items. Our team in China traced the actual manufacturers, collected the documents matching the products, and the container was released without the goods being destroyed.
Electrical and electronic goods
Check which directives apply (low voltage, EMC, radio) and that the declaration lists all of them. RoHS restricts ten substances, including lead, mercury, cadmium and four phthalates. Each EU country asks producers of electrical goods to register with its national WEEE register. During inspection, check plugs, rating labels, the crossed-out bin symbol and manuals on mass production, not only on the approved sample. Products such as e-bikes add battery and transport documents; our e-bike import case shows how a shipment can stall when delivery terms and paperwork are unclear.
Furniture
Furniture has no CE marking. It falls under the GPSR (stability, strength, instructions) and REACH. Fire safety for upholstered furniture is not harmonised in the EU: several countries have national rules, and the UK applies its Furniture and Furnishings (Fire) (Safety) Regulations 1988. Hotel, restaurant and public-building projects usually have stricter fire requirements. Confirm them for each country and project before choosing foams and fabrics.
Food contact items
Materials must not transfer substances to food in amounts that could harm health, must be labelled for food contact and must be traceable (Regulation (EC) No 1935/2004). Plastic items must also meet Regulation (EU) No 10/2011 and come with a declaration of compliance. Bisphenol A is now restricted in food contact materials by Regulation (EU) 2024/3190, with transitional periods. Test the exact materials and colours of your order: a new pigment or coating can change the result.
How Asiaction secures compliance in China
Asiaction is a French-managed purchasing office with an operating office in Guangzhou. Since 2008 we have completed more than 3,200 projects with a network of more than 6,500 partner factories. On compliance, our work happens before the goods leave China:
- Certificate recovery and authentication. We collect certificates, test reports and declarations from the actual manufacturers, in Chinese, and check that they match the company, the model and the standards, with the issuing body or laboratory when needed.
- Checks during inspection. Our product inspections follow ISO 2859-1 (AQL) sampling. Inspectors check that specifications, markings, labels and packaging match your purchase order. Raw material inspections include the verification of certificates and technical data sheets. You receive a report with photos, videos and comments on the day of the inspection.
- Laboratory tests. We take samples from your production and arrange CE, EN, UL and other tests with accredited laboratories such as SGS, Intertek and Bureau Veritas.
- Document checks before shipping. Within order management, we validate technical and regulatory points when the order is placed, then prepare the shipping file: certificates of origin, test and compliance documents, and any specific documents your customs require.
Compliance is one step of the purchasing process. See also our guides to sourcing in China, quality control in China and importing from China.
This guide is general information, not legal advice. Rules change and depend on the exact product: confirm the requirements for your product with a compliance specialist or a notified body.
FAQ: EU product compliance for goods made in China
Is a “CE certificate” from a Chinese supplier enough to sell in the EU?
No. CE marking rests on the manufacturer’s EU declaration of conformity and technical file. A private “CE certificate” is at most supporting evidence. Only a notified body listed in NANDO for the relevant legislation can issue the certificates some products legally require.
Who is responsible for products imported from China?
The Chinese manufacturer is responsible for the conformity assessment. The EU importer must check it was done, put its own name and address on the product, keep the documents and cooperate with the authorities. A company selling under its own brand may be treated as the manufacturer.
Does my product need a notified body?
It depends on the legislation. Most electrical goods are self-declared on the basis of test reports. Many PPE categories, some machinery and toys not fully covered by harmonised standards need a notified body.
How long must I keep the compliance documents?
Usually 10 years after the product is placed on the market, both under CE-marking legislation such as the Low Voltage Directive and under the GPSR.
Does the GPSR apply to products sold to professionals?
The GPSR covers products intended for consumers or likely to be used by them, even if designed for professionals. Purely professional products are outside it, but may fall under sector rules such as the machinery or low-voltage legislation.
Can EU customs block a container for missing compliance documents?
Yes. Customs can suspend release when documents are missing or doubtful, when the CE marking is misleading or when the EU operator’s details are missing. Market surveillance authorities then decide whether the goods are released or refused. Release by customs is not proof of conformity.
Are your supplier’s certificates really valid for your order?
Send us your product, destination markets and volumes. Our team in Guangzhou will check your suppliers’ certificates and test reports and tell you what is missing before the goods leave China.
