According to the EU’s Blue Guide, CE is a conformity marking that indicates a product’s compliance with European environmental, safety, and health standards and regulations.
On the other hand, the EU Declaration of Conformity is the final step in the CE marking process, serving as proof that the manufacturer has successfully completed each step.
Hence, sellers on eBay and other European online marketplaces must ensure that their products have undergone this process successfully, even if they only act as the distributors of items they include in their online stores.
However, understanding which product categories and specific products require CE marking and EU DoC can be challenging because a wide range of EU regulations mandates their use.
As a result, eBay sellers who produce sunglasses or toys must ensure that each item they place on an online marketplace in the EU has both the CE marking and the DoC.
Here’s what you need to know about the EU Declaration of Conformity and CE markings before placing a product on one of eBay’s European marketplaces.
CE Markings and the EU DoC: Key takeaways
- CE markings are mandatory for specific product categories sold in the EU, EEA, and Turkey.
- EU DoC is unnecessary for products that don’t require CE markings
- Affixing a CE marking to a product that doesn’t comply with the EU’s environmental, health, and safety regulations is punishable by fines, product recalls, and market bans.
- The exact steps manufacturers must take during the CE marking process depend on the applicable harmonizing standards, directives, regulations, and product-specific requirements.
- CE marking ensures the free movement of products on European markets.
The scope of CE Marking requirements
One of the largest obstacles sellers face on the path to the EU’s online marketplaces is grasping the scope of CE marking requirements.
There are over thirty EU-wide CE marking directives and regulations that mandate the use of this marking for specific product categories.
That’s why sellers who manufacture the products they offer on the EU’s online marketplace or distributors who significantly modify items they sell in their online stores must be familiar with all regulations, directives, and harmonized standards that apply to the specific product categories they offer to European consumers.
Before physically affixing the CE marking to a product, manufacturers or economic operators qualifying as manufacturers must:
- Ensure a product’s conformity with relevant environmental protection, product safety, and health standards.
- Compose a technical document outlining the conformity assessment procedure and listing the harmonized EU standards.
- Determine whether the notified body should conduct an independent assessment of the product.
- Create the EU Declaration of Conformity.
The process of obtaining the CE marking is free, unless an independent assessment by the notified body is required, and there’s no limit to the marking’s period of validity.
Product categories that require CE marking
It’s paramount to know which categories of products must have CE marking before entering EU marketplaces, even for online sellers who only distribute products they add to their stores. They must ensure that each item has the necessary documentation and appropriately affixed marking.
Things get exponentially more complex for international sellers on eBay or other platforms who produce the items they sell on European online marketplaces.
For instance, a US company that manufactures toys and wants to offer its products on the German marketplace must ensure that the product conforms to relevant EU laws before listing its items on a German online marketplace.
Although the regulations and directives mandating the use of CE markings often apply to products that aren’t sold on eBay and similar international marketplaces, a considerable portion of these regulations apply to items commonly distributed through online channels.
Here’s a quick overview of the product categories commonly sold on international online marketplaces that require CE markings:
- Sunglasses and safety goggles
- Smartphones and tablets
- Computers and cameras
- Power tools
- Gaming consoles
- Stuffed animals with electronic components
- Dolls
- Musical toys
- Ski, skateboarding, and cycling helmets
- Desk lamps
- Jewelry-making kits
Please note that the list above doesn’t contain all products requiring CE markings.
CE marking steps
Depending on various factors, obtaining the CE marking for a product can take anywhere between a couple of weeks and several months.
Sellers who plan to launch a new product on an EU marketplace must conduct thorough research and prepare for the challenges they may face.
We’ve broken the process into several stages to help you understand it better, but remember that the exact steps a business must take depend on the product category.
Checking for applicable EU legislation and harmonized standards
Before going through the long list of European harmonized standards, manufacturers must first determine which EU directives and regulations apply to the product they want to place on the European marketplace.
So, toy manufacturers must meet the requirements laid out in the EN-71 series of harmonized standards.
On the other hand, brands that produce sunglasses must ensure that their products comply with the EN ISO 12312 -1 standard, which specifies requirements for UV protection or optical power, among others.
Conducting the internal conformity assessments
Once the manufacturer identifies the applicable regulations and standards, they can use them as the guideline for the internal assessment process.
In most cases, manufacturers can utilize Module A to assess low-risk items by:
- Identifying foreseeable hazards
- Conducting the necessary testing
- Ensuring that the item’s design complies with applicable standards
- Implementing risk reduction measures.
Assessments by a notified body
The EU laws prevent manufacturers from self-assessing high-risk products. So, unless a product falls under the Module A category, the assessment must be conducted by a notified body.
The manufacturer must submit an application to a notified body that performs the required tests and issues the compliance certificate.
Drawing up the technical documentation
The manufacturer is responsible for drafting the product’s technical documentation, even if a notified body performs the assessment.
A product’s technical documentation should contain the following elements:
- General description of the product and a product identifier
- The name and the address of the manufacturer and authorized representative
- Design and manufacturing drawings
- Description of the production process
- List of components and materials
- The results of tests and assessments
- User instructions
- Additional accompanying documents
The exact information a manufacturer must include in the technical documentation depends on the product, which is why it’s paramount to check the requirements for a specific item before starting this step of the process.
Moreover, the manufacturer should ensure that:
- Technical documentation is completed before a product becomes available on the market.
- The market surveillance authorities have access to the technical documentation.
- Technical documentation is kept for ten years from the moment a product first becomes available on the market.
What is the EU Declaration of Conformity?
Like the Supplier’s Declaration of Conformity in the US, the EU Declaration of Conformity is a mandatory document that confirms a product has undergone the necessary testing and meets conformity requirements.
The manufacturer bears the sole responsibility for drafting this document and making it available to importers, distributors, online marketplaces, customs, and market surveillance authorities or authorized representatives.
By signing this document, the manufacturer assumes the responsibility for the product and its compliance with the relevant EU laws. Drawing up and signing this document is also the final step in the CE marking process, along with affixing the marking to the product.
Like the product’s technical documentation, the EU DoC should be kept for ten years and be available to economic operators involved in its supply chain, as well as the customs and market surveillance authorities.
The key elements of an EU DoC
This document is mandatory for all products requiring CE marking, and it should contain all the details below:
- The manufacturer’s or authorized representative’s name and contact details.
- The serial number, model, and type of the product.
- The statement that the manufacturer takes full responsibility for the product’s compliance with EU laws.
- A product’s picture, identification number, or other types of product identifiers.
- The information about the notified body that conducted the assessment (if necessary) or a brief description of the internal assessment process.
- The list of regulations, directives, and harmonized standards a product complies with.
- The manufacturer’s name and signature, along with the date DoC was issued.
It’s worth noting that in some cases, manufacturers must provide additional information when drafting the DoC.
Compliance as an entry ticket to the EU’s online marketplaces
Ensuring product compliance with EU requirements and maintaining thorough documentation are essential prerequisites for access to the EU’s digital marketplaces.
Online sellers who manufacture their products must prepare for the strict and often painstakingly long CE marking process to ensure the placement of their products on European marketplaces.
The length and complexity of the process, as well as the requirements manufacturers must meet, depend on the product. Thoroughly preparing for this process is the most crucial step a manufacturer can take on their path to compliance.
Still, CE marking isn’t the only requirement products entering the EU must meet. The general product safety regulation introduces a wide range of obligations that sellers on online marketplaces must meet before offering a product to European consumers.
Do you need assistance meeting the GPSR requirements? Book a call and find out how Webinterpret can help you get compliant.
About Webinterpret
Webinterpret supports merchants selling on eBay.
Our AI-based solutions enable more effective selling through automated listing localization, advertising, and returns and ensure all products placed on EU markets are GPSR-compliant.
By giving your international customers a full, end-to-end local shopping experience, Webinterpret improves your conversion and helps establish your business globally.
