CE, FCC, RoHS: what a supplier's certificate is actually worth

CE is mostly a declaration, not a certification

For the majority of product categories, CE marking is self-declared. The manufacturer compiles a technical file, assesses the product against the applicable directives, and signs a Declaration of Conformity. No external body needs to be involved, and there is no such thing as a "CE certificate" issued by an authority for these products.

Only specific higher-risk categories — certain machinery, medical devices above Class I, some pressure and lifting equipment, personal protective equipment in higher categories — require a Notified Body, which does issue a certificate carrying a four-digit number you can look up.

So the document a factory sends is usually one of two things: a genuine Declaration of Conformity, which is a statement of their own responsibility, or a voluntary test report from a commercial laboratory, which shows a sample passed particular tests on a particular day. Both are useful. Neither is an official approval.

There is no registered "China Export" mark, despite how often the story is repeated. Narrow letter spacing on a CE logo means somebody used the wrong artwork, not that a secret alternative mark exists — and correct spacing proves nothing about compliance either.

The obligation follows the importer

When you bring goods into the EU from outside it, you take on the importer's duties, and for many purposes the obligations of a manufacturer. You must be able to produce the technical file, and the Declaration of Conformity must name a responsible economic operator established in the EU.

This is the part that surprises people: a certificate from your Chinese supplier does not transfer liability to them. If a market surveillance authority questions the product, they come to you, and "the factory said it was compliant" is not a defence.

The practical consequence is that you need the underlying documents in your own possession — the test reports, the technical file, the signed declaration — not a reassurance in an email thread.

Reading a test report properly

Check the sample description against your product. Reports are routinely issued for a similar model, an earlier revision, or the version without the feature you are adding, and the difference is often visible only in the specification table.

Check the standard and its version. Harmonised standards are revised, and a report against a superseded version demonstrates conformity to a rule that no longer applies.

Check the applicant name. A report frequently belongs to a component supplier — the LED driver, the wireless module, the battery cell — rather than to the finished product or the factory selling it to you. A compliant module inside a non-compliant assembly is common.

Check the date and the laboratory. Accredited labs are traceable; a report from an entity you cannot find is not worth the paper.

Test reports are verifiable. Most laboratories will confirm a report number on request, and a supplier who objects to that check has answered a different question.

FCC, RoHS and REACH in one paragraph each

FCC applies to electronics sold in the US. Anything with an intentional radio transmitter needs an FCC ID, which is searchable in the FCC's public database — check that the grantee is the party you expect and that the equipment class matches. Unintentional radiators fall under a self-declared route similar to CE.

RoHS restricts specific hazardous substances in electrical and electronic equipment. It is declared rather than certified, and is supported by material declarations and test data from the component chain. A single-page "RoHS certificate" with no substance table behind it is decoration.

REACH is broader and applies to chemical substances in almost any article, with the restricted list under Annex XVII and the candidate list of substances of very high concern both updated regularly. Because the lists move, a REACH statement carries a date, and an old one may no longer be true through no fault of the supplier.