CE Certificate: What It Is and What Buyers Should Ask For

Why there is no "CE certificate" under module A

By affixing the CE marking, the manufacturer declares that it takes responsibility for the conformity of the product with all the EU laws that provide for the marking. The marking is a declaration of responsibility. It is not a sign that a third party has tested or approved the product.

The route to the marking is the conformity assessment procedure set by each law. These procedures come from Decision No 768/2008/EC, which provides a menu of modules identified by letters from A to H. The simplest is module A, internal production control. Under module A, the manufacturer does everything alone: it prepares the technical documentation, assesses the design, controls production and signs the declaration. No notified body is involved.

Module A is the most common module for everyday products. The Low Voltage Directive, Directive 2014/35/EU, allows only module A, and there are no notified bodies under it. RoHS, Directive 2011/65/EU, also uses module A. Most manufacturers use module A under the EMC Directive, Directive 2014/30/EU, as well.

So for a product that follows module A, there is no such thing as a "CE certificate". No third party takes part, and the only document that declares compliance is the manufacturer's EU Declaration of Conformity (DoC). The DoC is not a test report and it is not a certificate. It is your own legal statement, signed by a person with the authority to commit the company. Our guide to the EU declaration of conformity explains its content.

What a notified body issues, and when

For higher-risk products, the law requires a notified body. This is an organisation designated by a Member State and notified to the European Commission for specific laws, modules and products. Depending on the module, it issues different documents:

Module B covers only the design phase, so it is always combined with a production module, such as C, D, E or F. These documents have a defined content, a validity and, in many cases, an expiry date. The manufacturer keeps them in the technical documentation and refers to them in the DoC, which names the notified body, its number, what it did and the certificate number. If you change the product, tell the body, because some changes need a new examination.

Even with a notified body, the manufacturer remains responsible for compliance and still signs the DoC. The certificate is evidence for one part of the procedure. It does not replace your declaration.

Examples where a notified body is needed include ATEX category 2 electrical equipment, which requires module B plus C1 or module B plus E, and pressure equipment from category II upwards. Under the Radio Equipment Directive, a notified body becomes necessary for the radio and cybersecurity requirements when harmonised standards are not fully applied. For a fuller picture, read do I need a notified body.

The four-digit number next to the CE marking

The Commission gives each notified body a four-digit identification number. Sometimes this number follows the CE marking, shown here as CE xxxx. It appears only when the notified body is involved in the production control phase, for example when it audits the manufacturer's quality system or checks production.

A body that only issued an EU-type examination certificate, under module B plus C, does not add its number. And for a module A product, there is no number at all. A CE marking followed by a four-digit number on a product that followed module A is therefore a warning sign.

Voluntary certificates and test reports

Some bodies issue voluntary "certificates of conformity" outside the legal procedures. They may be printed with a CE logo and a four-digit number. These documents can mislead buyers. A certificate of this kind does not replace the procedure required by law, and it does not transfer responsibility from the manufacturer.

A voluntary test report can still be useful as evidence in your technical file. Test reports from laboratories accredited to ISO/IEC 17025 are not required by the product laws, but they carry weight, because a national accreditation body has checked the laboratory's competence for those tests.

Two other documents are often confused with CE certificates:

• Certificates under non-EU standards, such as a UL listing. An EU authority will not accept these as proof of compliance with an EU law. You can map the work to EU requirements and close any gaps.
• CB Scheme test reports under the IEC system. They can be very useful evidence, but they do not give presumption of conformity by themselves. Check the IEC edition used against the EN edition currently cited.

What to give buyers and marketplaces instead

Buyers, distributors and online marketplaces often ask for a "CE certificate". Some marketplaces use the wrong term. For a module A product, a short written explanation can save you a long discussion. Offer:

• your signed EU Declaration of Conformity, listing all applicable laws and the harmonised standards with their editions;
• the relevant test reports, for example for electrical safety and EMC;
• where a notified body was involved, a copy of its certificate or approval.

Your technical documentation is a different matter. You keep it for ten years after the product is placed on the market, unless the specific law says otherwise, and you make it available to market surveillance authorities on request. You do not need to hand the full file to every buyer. Our guide to the technical file for CE marking covers what it contains.

Red flags when someone offers a CE certificate

Watch for these signs when a supplier shows you a certificate, or a service provider offers to sell you one:

• A "notified body certificate" for a product under a law that uses only module A, such as the Low Voltage Directive. Ask which article of the directive requires it.
• A body whose NANDO entry does not cover your law, module and product. NANDO is the Commission's public database of notified bodies, and it also shows suspended or withdrawn notifications. A certificate issued outside the notified scope will not support your DoC.
• A certificate that does not say which law and which module it relates to, or what was actually assessed.
• A DoC that mentions a notified body when none was involved, or a certificate number that does not match.
• A four-digit number next to the CE marking when no notified body took part in production control.
• A body that offers to design your product or advise on how to make it compliant, and then to assess it. A notified body must be impartial and cannot consult on the products it assesses.

Misleading documents can cause real trouble. Customs must suspend release for free circulation when the CE marking seems to be affixed in a false or misleading way, or when the required documents are missing or doubtful.

Key points

• Under module A there is no "CE certificate": the manufacturer's EU Declaration of Conformity is the compliance document.
• Notified bodies issue EU-type examination certificates, quality system approvals and unit verification certificates.
• The notified body number follows the CE marking only when the body takes part in production control.
• Voluntary certificates do not replace the legal procedure or move responsibility from the manufacturer.
• Check any notified body's scope in NANDO before relying on its certificate.

The free first module of CE Marking Fundamentals explains what the CE marking really means and the most common myths about it.