CE Marking – manufacturers, importers and distributors

CE Marking – manufacturers, importers and distributors

In order to sell a lighting product (called “placing on the market” in EU terminology) in the European Union it is necessary to understand the correct process and route to placing the product on the market such that it allows free access to all countries within the EU.

As discussed in earlier articles :

CE Marking of LED Lighting Products


CE Marking – The Importance of the Technical File


The CE mark is mandatory for all lighting products and shows that the manufacturer has declared ( and can prove ) that the product bearing the CE mark is compliant to the essential requirements of the relevant EU directives and regulations and in accordance with the harmonised standards.

It is not always the manufacturer that sells the product directly to the end user in the EU. Many products are imported or resold onto the end user. Thus, there is a chain of supply through which some degree of traceability must be maintained and differing degrees of responsibility are required.

We will describe these here in more detail starting with the manufacturers.


Manufacturers play a crucial role in ensuring that products placed on the market are safe.

They are responsible for checking that their products meet EU safety, health, and environmental protection requirements. It is the manufacturer’s responsibility to carry out the conformity assessment, set up the technical file, issue the EU declaration of conformity, and affix the CE marking to a product confirming the above.

Only then can this product be traded on the EU market. Customs authority will regularly check the safety of products and always inspect the documentation including the declaration of conformity to ensure compliance with the CE marking directives.

If you are a manufacturer, you have to follow the six steps to affix a CE marking to your product:-

Manufacturers must not affix CE marking to products that don’t fall under the scope of one of the CE marking directives or if they cannot prove that the product complies with the requirements and have established and can maintain a proper technical file. All lighting products will have a CE marking directive applicable and so will need to be CE marked. Any supplier should be able to produce the confirmation that a technical file is in place and the product will comply with the essential requirements.

Importers and distributors

Importers and distributors help ensure that only those products compliant with EU legislation and bearing the CE mark are placed on the Market. As they are the intermediaries between manufacturers and traders, they must have overall knowledge of the legal requirements and make sure that the products they distribute or import meet them.


When importing from non-EU countries, importers must check that products fulfil all EU safety, health and environmental protection requirements before placing them on the market.

The importer has to verify that:

  • the manufacturer outside the EU has taken the necessary steps to allow the product to be placed on the EU market i.e. the product is compliant and can be demonstrated with a well maintained technical file;
  • the necessary documentation such as the EU Declaration of Conformity and the technical documentation is available upon request and
  • contact with the manufacturer is possible at any time


Distributors must handle the product carefully and they mustn’t affect its compliance with EU legislation. The distributor has to know which products must bear the CE marking and the accompanying documentation. They should be able to identify products that are not in compliance.

Distributors must be able to demonstrate to national authorities that they:

  • have confirmation from the manufacturer or the importer that the necessary measures have been taken;
  • are able to assist national authorities in their efforts to receive the required documentation

If importers or distributors market the products under their own names, they take over the manufacturer’s responsibilities. In this case, they must have sufficient information on the design and production of the product because they will be assuming the legal responsibility when affixing the CE marking.

EU Consumers

EU consumers may have different preferences when it comes to the colour or brand of products such as lamp or light fitting. At the same time, they expect all products on the market to be safe.

By affixing the CE marking to a product, the manufacturer assumes full responsibility for its compliance with all safety requirements. Unfortunately, due to counterfeiting or the misuse of CE marking, there is never a 100{4b479c29e7e75144eee93d961debc6ccd38b87e48532d5f844d44a1d040b5be0} guarantee that a product bearing the mark is safe.

The EU has strengthened the entire system, consisting of manufacturers, importers, distributors, notified bodies, and market surveillance authorities, through the New Legislative Framework. The new legislation aims to reduce burdens on trade while ensuring a high level of safety.

What can you do to improve the safety of products on the market?

Unfortunately, since CE marking of lighting products is a self-certified process than manufacturers that do not follow the rules and apply the CE mark without due dilligence to the correct process cannot easily be distinguished from those that do. End users and consumers can also play an important role in improving the safety of products:

Professional users and businesses should take care to understand the supply chain back to the manufacturer to be comfortable they have taken the necessary steps to ensure compliance to the standards and regulations.

Consumer should always buy products from trustworthy shops and online outlets: If an offer seems too good to be true, it may well be. Trustworthy shops take care with the products they sell and usually accept returns. On the other hand, rogue traders tend to ignore health and safety rules, and may also sell fake products.Read all warnings and instructions: Be aware of age and safety recommendations, especially in the case of toys.

Always report a safety problem:

Inform the manufacturer or the retailer from whom you bought the product.

In addition, contact the appropriate public authority such as trading standards :

This ensures that further steps to ensure the safety of the product will be taken.

Next week an article providing an overview of the performance and essential checks that can be made on Lighting Products will be posted allowing specifiers to differentiate between CE marking and a more thorough independent 3rd party check of the product compliance .