Product certifications are one of those topics that people assume "someone else is handling." Importers assume their Chinese supplier has it sorted. Suppliers assume the buyer knows what's required. Somewhere in the middle, a container arrives at Rotterdam or Los Angeles and gets stopped because the product doesn't carry the right marks.
Getting certifications wrong doesn't just delay a shipment. Selling a non-compliant product can mean recalls, fines, and in serious cases, criminal liability. Let's break down the main frameworks.
CE Marking — European Economic Area
The CE mark (Conformité Européenne) is required for most product categories sold in the EU, Iceland, Liechtenstein, and Norway. It signals that the product meets EU health, safety, and environmental standards.
Who's responsible? The manufacturer or the "importer" (defined in EU law as the first person who places the product on the EU market). If you're buying from China and importing into Germany, you — not your Chinese supplier — are legally the importer and bear responsibility for CE compliance.
Products that require CE: electrical equipment (Low Voltage Directive), machinery, personal protective equipment, toys, medical devices, radio equipment (RED Directive), pressure vessels, and more. The list is long and directive-specific.
How is CE obtained? It depends on the product risk level:
- Low risk (e.g., simple household appliances): self-declaration of conformity after testing against relevant harmonized standards. Your supplier can do this, but you need to verify it's been done properly with actual test reports.
- Medium-to-high risk (e.g., medical devices, PPE, machinery with significant hazards): requires a Notified Body — an independent third-party certification organization authorized by an EU member state. They review your technical documentation and issue a certificate.
CE marking itself is free — you apply it yourself. The cost is in the testing and Notified Body assessment, which runs from a few hundred euros for simple products to tens of thousands for complex machinery or medical devices.
Watch for: fake CE marks. Some Chinese manufacturers apply a "China Export" CE-like logo that has the same letters but different proportions. It has no legal meaning in Europe whatsoever. Check the ratio between the two letters of a genuine CE mark — the C is not a complete circle, and the proportions are specified.
FCC Authorization — United States
The Federal Communications Commission (FCC) controls electronic devices that emit radio frequency (RF) energy in the US market. This covers almost any electronic product: computers, phones, Bluetooth devices, Wi-Fi equipment, LED drivers, switching power supplies, and much more.
Three authorization tracks:
- FCC Certification (third-party): Required for intentional radiators — devices that deliberately emit RF (Wi-Fi routers, Bluetooth speakers, remote controls). Requires testing at an FCC-accredited lab and application through a Telecommunications Certification Body (TCB).
- Supplier's Declaration of Conformity (SDoC): For unintentional radiators — devices that emit RF as a byproduct (computers, monitors, most consumer electronics). Self-declared after lab testing; the manufacturer keeps records.
- Verification: For the lowest-risk unintentional radiators. Internal verification, no external lab required.
Products that need FCC authorization and don't have it will be refused entry at US ports or seized by customs. The FCC also has enforcement authority after products are in the market — they can issue recalls and fines.
Practical note: If your Chinese supplier says they have FCC certification, ask for the FCC ID. You can verify it at apps.fcc.gov/oetcf/eas/reports/GenericSearch.cfm. Every certified device has a unique ID that must appear on the product label.
RoHS — Restriction of Hazardous Substances
RoHS isn't a mark you'll see stamped on a product — it's a compliance requirement. The EU's RoHS Directive (and similar regulations in the UK, China, and elsewhere) restricts the use of certain hazardous substances in electrical and electronic equipment (EEE):
- Lead (Pb): max 0.1% by weight in homogeneous materials
- Mercury (Hg): max 0.1%
- Cadmium (Cd): max 0.01%
- Hexavalent chromium: max 0.1%
- Polybrominated biphenyls (PBB): max 0.1%
- Polybrominated diphenyl ethers (PBDE): max 0.1%
- Plus four phthalates added in RoHS 3 (2019)
RoHS compliance is a prerequisite for CE marking on EEE — you can't have one without the other. Your supplier should provide a RoHS Declaration of Conformity backed by test reports from an accredited lab. Don't accept declarations without test data.
UKCA — United Kingdom Post-Brexit
After Brexit, the UK created its own product safety mark: UKCA (UK Conformity Assessed). For most product categories, it replaces CE marking for the Great Britain market (England, Scotland, Wales). Northern Ireland has a more complex situation — it accepts both CE and UKCA under the Windsor Framework.
The UKCA mark has been phased in gradually. As of 2025, it's required for most product categories that previously required CE. The technical requirements are largely identical to EU legislation (the UK adopted EU standards into UK law at the point of Brexit), but the conformity assessment process must now involve UK-approved bodies, not EU Notified Bodies.
If you're shipping to both the EU and UK: you need both CE and UKCA, which means two separate conformity assessment processes (or working with bodies that are authorized in both jurisdictions). Budget for this accordingly.
Who Should Handle Certification?
The honest answer: it depends on the product and the volume.
For low-risk, self-declared products (basic household goods, simple electronics under SDoC), a diligent importer can manage the process with help from their supplier and an accredited test lab.
For higher-risk categories — anything involving RF emissions, medical use, children's products, machinery, or food contact — work with a professional certification consultant or the Notified Body / TCB directly. The cost of getting it wrong (recalls, seizures, liability claims) far exceeds the cost of proper upfront testing.
Before you place a factory order, confirm certification requirements for your target markets. This affects product design, materials, labeling, and timelines. Certifications aren't something you bolt on at the end — they're part of the product development process.
When you're ready to plan the freight side, the ChinaLogisticHub freight team can advise on import documentation requirements at destination and flag any certification-related customs requirements we commonly see for your product category.