By Norbert Laszanowski · Updated · First published
Importing a product from Asia and selling it in the EU makes you — not the factory — legally responsible for CE compliance. Here's the full importer's guide: which directive applies, what documents you need, and how to write supplier contracts that protect you.
How FabriMatch verifies suppliers →CE marking is only required for products covered by specific EU harmonisation legislation. Many B2B manufactured components do not require CE marking — only the finished assembly does.
| Directive/Regulation | Applies when… | Typical parts |
|---|---|---|
| Machinery Directive 2006/42/EC (Regulation (EU) 2023/1230 from 20 Jan 2027) | Product is a machine, safety component, or interchangeable equipment | Motors, gearboxes, safety guards, presses |
| Low Voltage Directive 2014/35/EU | Electrical equipment 50–1000 V AC or 75–1500 V DC | Power supplies, motors, transformers |
| Pressure Equipment 2014/68/EU | Pressure vessels, steam generators, fittings > category 1 | Hydraulic cylinders, valve bodies, pressure tanks |
| RoHS 2011/65/EU (recast) | Electrical/electronic equipment placed on EU market | PCBs, sensors, controllers |
| General Product Safety (GPSR) 2023/988 | Consumer products (direct-to-consumer or household use) | Consumer electronics, tools, toys |
| Pure B2B component (no directive) | Sold as input to an OEM, not placed on consumer market | Precision CNC brackets, custom extrusions |
Your purchase order or supply agreement with the Asian manufacturer should include these clauses to protect your CE liability position:
Who is responsible for CE marking on imported goods?
The manufacturer carries out the conformity assessment, draws up and signs the EU Declaration of Conformity and affixes the CE mark. As the EU importer you must check that this was done, put your name and address on the product, keep a copy of the Declaration for 10 years and cooperate with market surveillance authorities. If you sell the product under your own name or brand, you take on all of the manufacturer's obligations.
What is an Authorised Representative and do I need one?
An Authorised Representative (AR) is an EU-established entity a non-EU manufacturer appoints in writing to carry out some of its obligations, such as keeping the Declaration of Conformity and technical file available to authorities. For products covered by Article 4 of Regulation (EU) 2019/1020 there must be an EU-based economic operator — often the importer itself — so an AR is optional when you import and fulfil that role.
Can a Chinese manufacturer CE-mark parts before shipment?
Yes — affixing the CE mark is the manufacturer's job, after it has completed the conformity assessment and signed the Declaration of Conformity. What it cannot do is place the product on the EU market alone: for most CE-marked products an EU-based economic operator (the importer, an authorised representative or a fulfilment service provider) must be identified on the product.
Which EU directives apply to CNC machined metal parts?
It depends on the end use. The Machinery Directive (2006/42/EC) — replaced by the Machinery Regulation (EU) 2023/1230 from 20 January 2027 — applies if the part is a machine, partly completed machinery or a safety component. Pressure Equipment Directive (2014/68/EU) applies to pressure-bearing parts. General product safety rules apply to consumer goods. Many B2B CNC parts sold as components (not finished machines) don't require CE marking at all — check with your legal counsel.