Aside

Do your products need CE marking?

Unfortunately, the process of determining whether the CE marking applies to a product is rather complex. The European legislator does not provide product lists or nomenclatures which indicate the appropriate CE marking directives.

The CE marking applies to products placed in the market or put into service in the European Economic Area, and only for certain product groups or product aspects. Thus in order to answer the question whether a product needs to be CE certified, one has to determine first in which countries the products are going to be placed in the market or used. Secondly, for each single directive it must be determined whether the products, or some of its aspects, falls within its scope.
 
Step 1.The CE Marking Is Required Only in the Countries of the European Economic Area (EEA):

The European Economic Area (EEA) is formed by the twenty-seven Member States of the European Union (EU)…:

     
  1. Austria (became member in 1995)
  2. Belgium (Founder Member in 1957)
  3. Bulgaria (2007)
  4. Czech Republic (2004)
  5. Cyprus (2004)
  6. Denmark (1973)
  7. Estonia (2004)
  8. Finland (1995)
  9. France (FM 1957)
  10. Germany (FM 1957)
  11. Greece (1981)
  12. Hungary (2004)
  13. Ireland (1973)
  14. Italy, (FM 1957)
  15. Latvia (2004)
  16. Lithuania (2004)
  17. Luxembourg (FM 1957)
  18. Malta (2004)
  19. The Netherlands (FM 1957)
  20. Poland (2004)
  21. Portugal (1986)
  22. Romania (2007)
  23. Slovakia (2004)
  24. Slovenia (2004)
  25. Spain (1986)
  26. Sweden (1995)
  27. United Kingdom (Great Britain) (1973)

…as well as three members of the European Free Trade Association (EFTA):

    * Iceland
    * Norway
    * Liechtenstein 

Although Switzerland is member of the EFTA, it does not take part in the EEA.

PLEASE NOTE: Turkey is neither member of the EU, nor is considered a part of the EEA. However, Turkey has fully implemented many of the European CE marking directives. This means that for many products they also require CE Marking.

If the product is to be placed or put into service in the aforementioned markets, the CE mark may apply if the product is covered by one or more of the European CE marking directives.

2.The CE Marking Is Required Only for the Following Types of Products:

  • Toys
  • Machinery
  • Electrical equipment
  • Electronic equipment
  • Personal protective equipment
  • Pressure equipment
  • Medical devices
  • Active implantable medical devices
  • In vitro diagnostica
  • Radio and Telecommunications terminal equipment
  • Simple pressure vessels
  • Gas appliances
  • Lifts
  • Recreational craft
  • Equipment and protective systems for use in explosive atmospheres
  • Non-automatic weighing instruments
  • Cableways
  • Construction products
  • Explosives for civil use
  • New hot water boilers
  • Measuring Equipment

The CE marking is NOT required for the following products:

  • Chemicals
  • Pharmaceuticals
  • Cosmetics
  • Foodstuffs

Products that are not covered by the European CE marking directives may fall within the scope of other European or national legislation. If there is no specific legislation, the General Product Safety Directive (2001/95/EC) may apply. This European Directives requires that products are safe, but is does not require any marking.

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About Han Zuyderwijk

Han is an author, speaker and consultant specialized in CE certification and European technical regulations. Founder of CEMarking.Net. See Google+ Profile

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48 Responses to Do your products need CE marking?

  1. mark January 26, 2012 at 5:07 PM #

    Han

    We manufacture composting toilets. Our versions with electrical components are CE certified under the LV and EMC directives. We also have a non-electric version with no electrical components. I assume that this product is not required to be CE certified since it is identical to the electrical model and neither the LV or EMC dirctives apply.

    Looking for confirmation

    thanks,
    Mark

  2. Dennis Paller October 31, 2011 at 4:31 PM #

    Hi Han, We are going to be producing some MP3 players in china that are battery operated. These are for temporary use and the battery cannot be changed nor is it rechargeable. Is this a product that requires CE marking?

    • Avatar of Han Zuyderwijk
      Han Zuyderwijk November 1, 2011 at 9:46 AM #

      Hi Dennis,

      Thank you for your question. Please have a look at the EMC Directive. This directive could apply to your players, because they contain electronics (which are likely to cause EMI or be susceptible for EMI).

  3. Avatar of ASIER CONDE
    ASIER CONDE October 27, 2011 at 8:29 AM #

    Dear Han,
    We are manufacturers of wind turbine blades made of reinforced fiberglass and epoxy resin. I think we don’t require the CE Marking, but I would like to confirm this information with you.
    I am not really sure in which group would be a wind turbine blade. Might be construction products, machinery or none of them?

    Thank you very much for your help
    Kind regards
    Asier Conde

    • Avatar of Han Zuyderwijk
      Han Zuyderwijk October 31, 2011 at 8:13 AM #

      Yes, perhaps the Construction Products Directive applies. I would have to study your product documentation to be able to give you definite a answer. Contact me if you need my help.
      You may also want to search for product specific standards. The wind turbine will require CE, and perhaps there is a harmonized standard that covers the blades.

      • Damian McCusker January 6, 2012 at 3:48 PM #

        Hi Han
        On this issue , we manufacture / distribute adhesives and sealants, some for construction, sewer pipes etc.
        Do we need CE mark?? please help??
        thank-you in advance

        • Avatar of Han Zuyderwijk
          Han Zuyderwijk January 7, 2012 at 9:47 AM #

          Hi Damian,

          The Construction Products Directive 89/106/EEC could apply to adhesives and sealants. I recommend you to have a look at this directive.

  4. Alastair Bark October 24, 2011 at 11:47 PM #

    Dear Han,
    I work for a company which manufacture custom built furniture/consoles from aluminium extrusion in the UK. We recently manufactured 3 consoles with an actuated (raise/lower) worksurface. Our client is now insisting that these console require CE marking. I cannot see which type of product they may fall into. The electronic acuators are CE marked, should the complete asemble be CE marked?
    Alastair Bark

    • Avatar of Han Zuyderwijk
      Han Zuyderwijk October 31, 2011 at 8:15 AM #

      Can you email me a picture or drawings of the console?

      • Alastair Bark October 31, 2011 at 10:34 AM #

        Han, could you send an email to my address, then I can reply with the drawing attached.
        Alastair

  5. Avatar of Mark Tarpy
    Mark Tarpy October 7, 2011 at 4:33 AM #

    We are a publisher of books and some of our products target audience is children under the age of 14. Recently an importer in Europe expressed concern that some of our book products could be classified as toys because they contain various activities such as colouring pages or cut outs. How would we go about determining which of our books may qualify as toys and require CE marking?

    • Avatar of Han Zuyderwijk
      Han Zuyderwijk October 7, 2011 at 3:17 PM #

      Hi Mark,

      Thank you for your question. You’d have to determine whether the books are in the scope of the Toys Directive (2009/48/EC). Article 2 defines the scope:
      “Article 2. Scope
      1. This Directive shall apply to products designed or intended, whether or not exclusively, for use in play by children under 14 years of age (hereinafter referred to as toys).
      The products listed in Annex I shall not be considered as toys within the meaning of this Directive.”

      Annex I to the Toys Directive gives a list of products that are excluded from the directive. Children’s books are not mentioned there specifically, which means they could be covered when we can consider your books to be designed or intended for use in play. The European Commission has published a guidance documents on this very topic. The criteria they recommend are:
      “The play value of a book could be determined by the following key factors1:
      (1) Number of Pages
      (2) Materials
      (3) Sensory Elements
      (4) Level of Detail
      (5) Colour/Contrast”

      You can find this guidance document (with some great examples) here:
      http://ec.europa.eu/enterprise/sectors/toys/files/009_guidance_document_9_on_classification_of_books_red_en.pdf

      I hope this helps.

      Han

  6. Mojtaba Sadeghi September 20, 2011 at 10:43 AM #

    Dear Han,

    We are a manufacturer of upvc profile as well as upvc door & widow. As our products fall in the construction products, so do we need to get CE certificate for our products? If so, from where we can start.
    Is it possible we determine to self- affix the CE mark?
    Thanks for your help.
    Regards,
    Sadeghi

    • Avatar of Han Zuyderwijk
      Han Zuyderwijk September 21, 2011 at 5:50 PM #

      Yes, these products fall within the scope of the Construction Products Directive (89/106/EEC). There are European harmonized standards for doors and windows. Use these. All requirements and certification procedures are listed in these standards.

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