Import aus China vs. CE-Zeichen

Here you can find interesting cases of CE marking, other marking, certification, and technical quality issues of machines from China and other countries.

The CE vs China Export mark

The obligation to comply with the directives and the CE marking of machinery has become a major obstacle for imports from China. The production of safe machines and the obligation to develop construction documentation and hazard analysis has become a significant manufacturing cost for many smaller plants. Also, not having an EU representative there is no way to provide a machine from China to EU. Resourceful managers from the east quickly found out a way to create their own marking - CHINA EXPORT confusingly similar to the EU CE mark. The only difference is that CHINA EXPORT has the letters CE placed in a smaller distance and often, the middle beam of the letter E is equalized with the extreme ones. To be clear, the China Export mark does not exist as a legal Chinese marking. It is just an attempt to mislead buyers.

The correct pattern of the CE mark is characterized by the fact that the internal circle of the letter C is tangent to the outer circle of the letter E, in addition, the central beam of the letter E is clearly shorter than the extreme as shown in the picture. The sign can be downloaded from the website:

znak ce mm

Examples of false CE marks below. The first from the left is the most commonly used China Export mark.

znak ce fals

Importers, companies buying from China should be aware of the difference between the certificate of conformity and the EC declaration of conformity. The certificate, in short, is an intermediate document issued by an external body (it should be a notified body) upon receipt of which the manufacturer should issue his own EC declaration of conformity. EC Declaration od Conformity can be issued by manufacturer of his authorized representative (inside EU) and can't be issued by any third party. Chinese manufacturers often submit different certificates to the buyer. Sometimes units that are not notified and spend them in bulk without any tests and even certificates of non-existing units. The buyer should be given a Declaration of Conformity (issued and signed by the manufacturer) and not a certificate.

"Customs officers retain goods without a CE mark" 
Polish article:
English translation:

How to check the credibility of the Declaration of Conformity?

The EC Declaration of Conformity should be attached by the manufacturer to each product subject to CE marking. In the case of small electrical products, it is permissible to make the declaration available on the manufacturer's website.

An importer of goods from outside the EU who do not have a proper marking and declaration of compliance risk being detained by the Customs Office. The correct declaration of conformity for machines should contain:

  1. The name, type (sometimes model) of the machine.
  2. The name and address of the manufacturer or his authorized representative established within the European Community. WARNING! Chinese producers often do not have a representative in the EC. Practically it means that there is no person responsible for the product.
  3. The aforementioned directives with which the machine complies.
  4. The harmonized standards mentioned in the design of the machine.
  5. In the case of machinery listed in Annex IV of the Machinery Directive, the number of the notified body involved in the conformity assessment. WARNING ! It is worth checking whether the unit recalled exists and whether it is definitely a notified body. The identification number of the notified body should be affixed to the CE mark.

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