Affixing CE Marking On Products And How To Avoid Doing It Wrongly?

CE marking is the official conformity marking placed on products after the European harmonisation took place. Consequently, all other mandatory conformity markings, that might have existed in the EU Member States’ national legislation and having the same meaning as CE marking, need to be removed from products’ surfaces and replaced with the CE marking.

Legal markings, such as a manufacturer’s protected trademark or a Notified Body’s marking, are allowed to be affixed on products to the extent that such markings cannot be confused with the CE marking. Moreover, they must not diminish the legibility and visibility of the official CE marking.
By affixing the CE marking on items, manufacturers indicate that their products comply with the specific European directive(s). CE marking is mandatory for most types of products sold in Europe and, therefore, must be displayed on their surfaces or packaging. To do this correctly, manufacturers need to follow specific guidelines for affixing CE marking on products.

First of all, when affixing the CE Conformity Marking on products, you must make sure it consists of the initials ‘CE’ as shown in the figure below. The proportions presented in the figure must be respected no matter if the size of the CE marking is reduced or enlarged. Moreover, unless otherwise stated in the applicable European directive (s), the minimum height that the CE Marking should have is 5 mm. In case it’s not possible to affix the CE marking to the product in a visible, legible and permanent way, it has to be displayed on the packaging and any complementary documentation.

Figure 1. CE Marking

Second of all, to affix the CE marking on products, manufacturers or any other concerned party must make sure that all necessary conformity assessment procedures have been completed with success. Usually, this is done at the end of the production phase. However, if for some reason the CE marking forms an inseparable part of the product, then manufacturers may affix it at any other stage of the production phase. This is only allowed if the manufacturer or the Notified Body can verify the product’s conformity during the production control phase.

The CE marking can be moved to the packaging or complementary documentation in all other cases, except in the presence of only purely aesthetic grounds. To justify the different location of the CE marking, manufacturers need to be able to state one of the following reasons:

• the affixing to the item is impossible, and such can be the case when the product has an explosive nature
• there are technical conditions that don’t allow it;
• the minimum dimensions of the marking cannot be respected;
• the visibly, legibly and indelibly of CE marking cannot be ensured.

Sometimes, although the clear guidelines, it happens that the CE marking is affixed wrongly or abuse has been detected. In such cases, the EU’s Member States are allowed to deal with the situation in one of the following ways:

• ask the manufacturer to reinsure the product’s compliance;
• restrict or prohibit the product in question of being placed on the Single Market;
• ensure that the particular product is withdrawn from the market.

By law, it’s prohibited to affix marks that are likely to mislead third parties with regard to the meaning and graphics of CE marking. If the CE Marking has been displayed on a non-compliant industrial product, the manufacturer has an obligation to end the infringement under the conditions imposed by the competent national authorities.