Is there such a thing as a CE compliance certificate? What to ask for instead

If you have asked a supplier, retailer or marketplace for a "CE compliance certificate", you may have got an unexpected reply. Some suppliers do not hold one at all, and some that do are holding something different from what the request assumed. The phrase is common in search and in buyer questionnaires, and it has become shorthand for "prove this product is CE marked". The legal answer is more specific. For most products placed on the EU market, the document with legal weight is the EU Declaration of Conformity, written and signed by the manufacturer. A certificate from a notified body is needed only on some conformity routes, and it is not the same thing as the declaration.

What people usually mean by a CE certificate

"CE certificate" is not a defined term in the directives and regulations that set up the CE marking. It gets used loosely for three different documents:

• the EU Declaration of Conformity, which the manufacturer draws up and signs;
• a certificate issued by a notified body under one of the conformity assessment modules; and
• a test report from a laboratory showing that the product was measured against named standards.

Only the first is required for the majority of products. The second appears on some routes. The third is evidence that supports a declaration, not a conformity document in its own right. When a buyer asks for a "CE certificate", the useful reply is to ask which of these they actually need.

The Declaration of Conformity is the document that matters

The EU Declaration of Conformity (DoC) is the manufacturer's formal statement that the product meets the applicable requirements, made under the manufacturer's sole responsibility. Its model structure comes from Annex III of Decision No 768/2008/EC, and our guide to the EU Declaration of Conformity goes through each element in order. For this question, three points matter most:

• It is drawn up by the manufacturer, or by an authorised representative established in the EU. It is not written by a test laboratory or a notified body.
• It identifies the product and lists the directives and regulations that apply. It also cites the harmonised standards used, with dates. A generic reference to a standard family is not enough.
• It is dated and signed. One guide we checked notes that a declaration signed in advance and applied to a later product, or issued with no date, fails the formal requirements.

If you can produce a complete DoC, most "CE certificate" requests are answered, because that is what the request is really asking for. A DoC is also among the first documents a market surveillance authority will ask to see.

Where a notified body certificate fits

Notified bodies are involved only on some routes. Under the notified body modules, a body examines the design, a sample, or the production system, and issues a certificate for what it examined. The best-known example is the EU-type examination under Module B. A Module B certificate does not let the manufacturer ship on its own. As the WELMEC guidance on Module B explains, it is always followed by other modules that demonstrate the production conforms to the approved type. Under Module C, for example, the manufacturer keeps the DoC and affixes the CE marking.

So the notified body certificate and the declaration do different jobs. The certificate records a third party's examination. The declaration is the manufacturer's legal claim that the product, as placed on the market, conforms. A commercial guide to the EU type-examination process makes the same handoff: after a conforming result, the manufacturer affixes the CE marking and issues the declaration.

Which route applies depends on the directive and on the product's risk category. Our CE certification process explained compares self-declaration with the notified body routes. What a notified body is covers how these bodies are appointed and how to find them. Notified bodies are listed in the NANDO database. Where a notified body was involved, the DoC should identify it, including its NANDO number and certificate reference.

Check which route applies before you ask for anything

Before you request or supply a certificate, establish which route your product is on. Three questions settle most cases:

• Which directives and regulations apply to the product? Electronics often fall under several at once, which is why one declaration usually lists more than one act.
• Does the directive allow self-declaration for this product? Many low-risk categories do, and for those no notified body certificate is needed.
• If a notified body is required, which module applies, and is the certificate still in date and still covering this exact design? A certificate is tied to what was examined, so a design change can mean the approval has to be reassessed.

Certificates from notified bodies are time-limited in many cases, and the period varies by directive and by the certificate itself. Read the expiry and scope written on the document rather than assuming it runs indefinitely.

What to send when someone asks for a CE certificate

The table below sets out what each document is, who issues it and what it proves. It is the quickest way to answer a buyer who has asked for something vague.

When a buyer asks, send the DoC, the list of standards it cites, the test reports for those standards, and a short note on which conformity route you used. Send a notified body certificate only if your route required one and the certificate actually covers the product you are shipping.

Mistakes that come up repeatedly

The same errors appear again and again when suppliers answer these requests:

• Treating a test report as a conformity certificate. A passing report supports the declaration, but it does not replace it.
• Keeping an expired notified body certificate on file and assuming it still covers the product.
• Signing a declaration before the product is final. The declaration has to reflect the product as it is placed on the market.
• Citing standards without dates, or citing only the generic reference. Dated references are what make the declaration specific.
• Writing "CE certificate" into a supplier contract without defining it. Name the documents you want, such as the DoC, the test reports and the technical file.

The technical file sits underneath all of it

Every CE-marked product needs a technical file that backs up the declaration, whichever route was used. It holds the design documentation, the risk assessment, the test evidence and the list of standards applied. Our technical file explainer covers what goes in it. The file is what an authority will ask for after it has seen the declaration, and it is what makes a certificate request answerable in full.

Where to start

If you have been asked for a CE compliance certificate and you are not sure what is meant, reply and ask which document the buyer needs. If the answer is a declaration, our free declaration of conformity generator produces one from the fields it requires, and our declaration of conformity template shows the layout. If the answer is a notified body certificate, first confirm that your product's route requires one.

Our requirements checker shows the route for your product and a source link for each rule. For a decision with legal weight, though, the primary legislation and the notified body are the final word, not us.