Importing products from China into the EU: why a supplier certificate is not enough
When importing products from China, the importer must deal with CE marking, the EU Declaration of Conformity, technical documentation, GPSR, instructions for use and product labelling in accordance with EU requirements.
Importing products from China into the European Union is now a common part of business. Many companies buy electronics, toys, textiles, components, sports equipment, packaging, plastic products, wooden products or various consumer products directly from manufacturers outside the EU. However, problems often arise when an importer assumes that a certificate from a Chinese supplier is automatically sufficient for the legal sale of the product in the EU.
In practice, this is not the case. A certificate, test report or supplier declaration may be an important supporting document, but it does not necessarily mean that the product meets all requirements for being placed on the EU market. For each product, the importer must assess which legislation applies to it, whether the product requires CE marking, whether an EU Declaration of Conformity is required, and whether technical documentation, instructions for use, safety warnings, manufacturer and importer identification or other documents are necessary.
For products falling under EU harmonisation legislation, CE marking and an EU Declaration of Conformity may be required. This typically includes electrical equipment, machinery, radio equipment, toys, personal protective equipment, pressure equipment, measuring instruments and other regulated products. For these products, simply placing the CE mark on the product or packaging is not enough. The manufacturer or importer must be able to demonstrate that the product has been properly assessed, that technical documentation is available, that relevant test reports exist and that a valid Declaration of Conformity has been prepared under the applicable EU regulation or directive.
At the same time, there are many products that do not require CE marking or are not allowed to bear the CE mark at all. This does not mean that they can be sold without documentation. Consumer products are also subject to the GPSR, the General Product Safety Regulation. For such products, it is necessary to address product safety, risk assessment, instructions for use, product identification, manufacturer and importer details, product traceability and consumer information.
Additional obligations may also apply to certain products. For products made of plastics, metals, wood, textiles, rubber, packaging or chemical substances, it may be necessary to verify further requirements, such as REACH, RoHS, PPWR, material declarations, packaging documentation, battery documentation or requirements for products intended to come into contact with food.
An importer from a country outside the EU has a specific responsibility. If the importer places a product on the EU market under its own name or trademark, or imports it directly from a third country, it cannot rely solely on the supplier’s statements. The importer must have documents available that can be used during inspections, customs clearance, complaints or market surveillance checks.
The most common problems when importing products from China include invalid or incomplete Declarations of Conformity, incorrect CE marking, missing instructions in the required national language, unclear product identification, inconsistencies between the model on the product and the model in the documentation, missing importer details, outdated standards, incomplete test reports or certificates that do not relate to the specific product.
Therefore, it is advisable to deal with product documentation before the goods are imported, not only after the products are already in stock or on sale. Properly prepared documentation can significantly reduce the risk of problems during inspections, customs checks, requests from business partners, online sales or sales through marketplace platforms.
If you import products from China or another country outside the EU and are not sure whether you need CE marking, a Declaration of Conformity, technical documentation, GPSR documentation, instructions for use, a material declaration or a review of supplier documents, we can help you assess your obligations, check the available documents and prepare the documentation required for placing the product on the EU market.