Compliance
A mark on a product is a statement by someone, about a defined set of rules, for a defined market. Most compliance failures are not counterfeit marks. They are real marks attached to the wrong document, for the wrong market.
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A conformity mark says that the product meets the legal requirements of a market, that an assessment was carried out, and that a named party takes responsibility for the claim. It does not say the product is good, safe in every circumstance, or certified by a government.
That last point matters at a trade fair. Sellers talk about certificates as if a laboratory issued them. In most regimes the manufacturer issues the declaration and the laboratory produces evidence. The certificate is the manufacturer's statement; the test report is the evidence behind it. Both are needed, and they are not the same document.
The markets diverge in what they require and how they police it. The EU regulates by product directive and requires a declaration of conformity. The United States regulates by agency rule and, for many products, requires testing by an accredited laboratory. Neither accepts the other's paperwork automatically.
CE marking applies to products covered by specific EU directives and regulations: electrical safety, electromagnetic compatibility, machinery, toys, medical devices, construction products, pressure equipment, radio equipment and others. A product outside those scopes does not carry CE, and a product sold with a CE mark it cannot justify is worse off than one sold without it.
The route depends on the directive. Most consumer electrical goods follow a self-declaration route: the manufacturer builds a technical file, carries out or commissions the required testing, assesses the risks and signs a declaration of conformity. Some categories, and some products within otherwise self-declared categories, require a notified body.
The technical file is the part buyers overlook. It is not sent to customs and it is not on the carton. It sits with the manufacturer and, under most directives, with an authorised representative in the EU, and it has to be producible on request for around ten years after the last unit is placed on the market. A supplier who cannot describe where that file is has a mark without a foundation.
RoHS sits inside this structure for electrical goods: ten restricted substances, with limits on lead, mercury, cadmium, hexavalent chromium, two flame retardants and four phthalates. A CE declaration for an electrical product that does not address RoHS is incomplete, which is a common gap in supplier paperwork.
The United Kingdom created UKCA marking for goods placed on the market in Great Britain, meaning England, Scotland and Wales. Northern Ireland follows different rules and continues to use CE marking in most cases, because it applies EU goods rules.
The UK has repeatedly extended the period during which CE marking continues to be recognised for many product groups, which means the practical position depends on the product and on the date. For some categories CE is accepted indefinitely; for others UKCA became mandatory. Medical devices, construction products and a few others have their own timetables.
Check the current position for your product, not the general rule. The recognition dates have moved more than once, and a supplier who tells you UKCA is required may be working from an outdated briefing, while one who says CE is always fine may be working from an optimistic one.
Where UKCA applies, the structure mirrors CE: designated standards, a technical file, a declaration of conformity and a UK-recognised body where the category demands one. A CE test report can support a UKCA declaration where the standards are identical, but the declaration itself has to be issued against UK rules by a UK-responsible party.
The Federal Communications Commission regulates radio frequency devices, which in practice means anything that emits or is affected by radio frequency energy. That is broader than most importers expect: a Bluetooth speaker, a WiFi module, a wireless charger, a laptop, a device with a switching power supply.
Three routes exist. Verification is a manufacturer's own test record for certain unintentional radiators. A supplier's declaration of conformity is used for most unintentional radiators and requires testing at an accredited laboratory and a compliance statement. Certification, with a filing and an FCC ID, applies to intentional radiators, meaning devices that transmit.
The practical point for a buyer is that the route determines what document should exist. A product claiming to be FCC compliant with no test report and no FCC ID, where an ID is required, has neither. Ask which route the product takes and for the document that route produces.
The FCC mark itself is not a certification stamp applied by the agency. There is no FCC certificate for most devices. There is a declaration and a test file, and for transmitters a grantee code and an ID that can be looked up in the Commission's public database, which is the fastest verification step available to a buyer.
The Consumer Product Safety Improvement Act applies to products designed or intended primarily for children twelve years old or younger. It requires compliance with a set of standards, testing by a third party laboratory accredited by the Consumer Product Safety Commission, a children's product certificate, and a permanent tracking label on the product and its packaging.
The tracking label is where shipments fail. It must carry the manufacturer or importer, the location and date of production, and a cohort identifier, in a form that survives the life of the product. A carton printed with a lot code is not enough if the product itself carries nothing. A sticker added at the last minute is not permanent marking in the sense the rule means.
Scope is broader than toys. Children's clothing, furniture, feeding items, jewellery, school supplies and anything marketed to children can fall inside it, and marketing language is part of the test. A general use lamp sold as a nursery lamp invites the question.
Testing is not one-off in the way suppliers often assume. Material changes, a new factory, a new component supplier or a design change can require a new test. The certificate on file should describe the product as it is actually being made, and the buyer has no way of knowing whether it does unless the file records the version tested.
In every one of these regimes the declaration is signed by a party in the supply chain, and the importer carries consequences at the border. Customs authorities increasingly ask for compliance evidence at import, and a product held for missing conformity documents is a container accruing storage.
The importer of record is usually the responsible economic operator in the destination market, which brings obligations that have nothing to do with freight: keeping the declaration, holding the technical documentation, responding to a market surveillance enquiry, and in the EU appointing an authorised representative where the manufacturer is outside the union.
For a buyer placing a first order from a fair, that is a real cost to plan for. It is also a form of security. A supplier who can produce a complete technical file, a current test report and a signed declaration is a supplier who has been through this before, which correlates with fewer surprises on the water.
Ask for the same five items from every candidate supplier. The set is small enough that refusal is informative.
| Document | What it proves | What it does not |
|---|---|---|
| Declaration of conformity | A named party claims compliance against named rules | That testing was done, or done on this version |
| Test report | Specific samples met specific standards on a date | That later production matches those samples |
| Technical file index | The manufacturer maintains the documentation | That the contents are complete; it is an index |
| Accreditation scope | The laboratory was accredited for the test performed | That the laboratory tested your product |
| Tracking label artwork | Where the production identifiers will appear | That they will be applied to every unit |
A document checklist, not legal advice. Which rules apply depends on the product, the market and the current text of each regime.
Read the test report, not only the cover. Check that the model number matches what you are buying, that the standards cited are the ones the directive or rule names, and that the report is not a report on a component rather than on the finished product. Component reports are common and they are not finished-goods evidence.
Q Can I use the supplier's CE certificate as proof of compliance?
There is usually no certificate to use. For most CE categories the manufacturer issues a declaration of conformity supported by a technical file and test reports. A document titled CE certificate from a commercial laboratory is a test report or a voluntary attestation, not the legal instrument. Ask for the declaration and the technical file reference.
Q Is UKCA required instead of CE?
For many product groups CE continues to be recognised in Great Britain under extensions the UK government has made, while other categories have moved to UKCA. The position depends on the product and has changed more than once. Check the current rule for your specific product before printing packaging.
Q Does FCC apply to a product with no radio?
It can. Unintentional radiators, meaning devices that generate radio frequency energy internally without transmitting, are covered, and that includes many products with switching power supplies or digital circuits. Whether a declaration or certification is needed depends on the device class.
Q Who signs the children's product certificate?
The manufacturer or the importer, and in practice the importer is the party the CPSC will look to when the product is in the US market. The certificate has to rest on testing by a CPSC-accepted laboratory, and it has to identify the product as it was actually tested.
Q Can compliance documents be arranged after the goods ship?
Sometimes, but the exposure is a held container. Several destinations can require conformity evidence at the point of import, and a product without it sits in a terminal while storage and demurrage run. Collect the documents before booking, which also gives time to replace a supplier who cannot produce them.
Q Is a test report valid forever?
No. Reports describe samples tested on a date against standards as they stood. Standards are revised, designs change, factories change, and some markets expect periodic re-testing. A report more than a few years old on a product that has been through a redesign is a document about a different product.
Related pages
Send the product category and the destination market. We will list the documents a customs officer is likely to ask for, so they are in the file before the container is gated in.
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