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CE marking is not an ISO certificate: how to check CE documents

CE marking is the manufacturer's own declaration that a product meets the EU legislation that applies to it, after the procedure that legislation sets. No certificate creates it.

Published by CAS — Conformity Assessment Services · 31 October 2026 · 5 min read
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CE marking is not an ISO certificate: how to check CE documents

Key takeaways

  1. 1a number identifying the product, and details that allow it to be traced;
  2. 2the name and address of the manufacturer or authorised representative issuing it;
  3. 3a statement that it is issued under the sole responsibility of the manufacturer;
  4. 4the EU legislation complied with, and the standards or specifications referenced, with their version or date;

CE marking is the manufacturer's own declaration that a product meets the EU legislation that applies to it, after the procedure that legislation sets. No certificate creates it. Where the legislation requires a notified body, only a notified body, acting within what it was notified for, can carry out that step. An ISO 9001 certificate is evidence about a management system and stands in for neither.

Exporters are still offered documents that claim otherwise. This is how to check them.

Who stands behind the CE marking

Under Article 30 of Regulation (EC) No 765/2008, only the manufacturer or its authorised representative affixes the CE marking, only on products for which EU harmonisation legislation provides for it. By affixing it, the manufacturer takes responsibility for the product's conformity.

The document behind the marking is the EU declaration of conformity, drawn up and signed by the manufacturer or its authorised representative established in the Union. The Commission's Blue Guide calls the CE marking "a key indicator (but not proof)" of compliance, and states that only products regarded as presenting a high risk to the public interest require a third party, a notified body.

Four documents that are not what they claim

1. A "CE certificate" from a body that is not a notified body. The Commission's NANDO pages warn about unregulated certificates, often called voluntary certificates, issued for harmonised products by bodies not acting as notified bodies. The Commission calls the practice misleading, since only notified bodies may issue certificates of compliance for these products, and "only in the area for which they are notified". Such certificates have no value in checks by market surveillance authorities or customs, unless specific legislation provides for voluntary certification. The same page states that certificates may not bear a CE marking.

2. A notified body's certificate outside its notification. The Commission's own example: a body notified for machinery should not issue certificates, voluntary or other, for non-machinery products such as masks. The Blue Guide adds that a notified body may use its number only for work under the module it was notified for, and not for other EU legislation.

3. A test report presented as the notified body step. A body issuing a test report acts as a conformity assessment body; only as a notified body can it issue an EU-type examination certificate, bearing its name and identification number. A notified body may not put its number on a test report for tests the legislation does not specify.

4. An ISO 9001 certificate offered as proof of CE conformity. Under ISO/IEC 17021-1 §8.2.2, a management system certificate identifies the certified organization, the management system standard and the scope of certification. It names no EU act, module or notified body number.

How to check, in three steps

Start with the EU declaration of conformity. The model in Decision No 768/2008/EC, as the Blue Guide sets it out, includes:

  • a number identifying the product, and details that allow it to be traced;
  • the name and address of the manufacturer or authorised representative issuing it;
  • a statement that it is issued under the sole responsibility of the manufacturer;
  • the EU legislation complied with, and the standards or specifications referenced, with their version or date;
  • where a notified body was involved, its name, identification number and certificate reference;
  • the date of issue, and the signature and title of the person authorised to sign.

A "declaration" issued by a certification body in its own name is not this document.

Then read the act for the module. Each act sets its own procedures. Article 19 of Regulation (EU) 2016/425 on personal protective equipment is a clear case:

  • Category I: internal production control (Module A), with no notified body.
  • Category II: EU type-examination (Module B), followed by Module C.
  • Category III: Module B, followed by either Module C2 or Module D. Single Category III units made to fit one user may follow the Category II route.

For Category III, Article 17(3) requires the CE marking to be followed by the number of the notified body involved in Module C2 or D. Under Annex V, the Module B certificate names the notified body and its number, the type covered and the dates of issue and expiry, with a validity of no more than five years.

A CE marking with no number is not a defect in itself. The number follows the marking only where a notified body is involved in the production phase, so a product under Module A, or under Module B followed by Module C, carries none.

Finally, check the number in NANDO. The Commission's NANDO database lists each notified body with its identification number, the acts it is notified for and, under each act, the procedures and products. Certificates are always issued by and in the name of the notified body, even where its staff work outside the EU, so a certificate in the name of a local partner does not qualify.

What the wrong document costs

The manufacturer's responsibility does not move to whoever sold the document. Member States must act against improper use of the CE marking, with penalties that may include criminal sanctions for serious infringements.

CAS's position

CAS is not a notified body, does not issue CE certificates or declarations of conformity, and does not carry out conformity assessment under EU harmonisation legislation.

What this means for you

If you are an exporter: before paying for a "CE certificate", identify the act and its module. If the module needs a notified body, the body must appear in NANDO for that act, procedure and product. If none is needed, no certificate takes the place of the manufacturer's declaration.

If you are an EU buyer or importer: ask for the declaration of conformity first, then for the certificate it references, then check the number in NANDO.

If you hold an accredited ISO 9001 certificate: present it for what it is, evidence about your management system, checked by its number and scope.

This is generic information about the requirement, not advice on any particular management system.

CAS — An EGAC accredited MS certification body No. 012418. Accredited scope: ISO 9001, ISO 14001, ISO 45001, ISO 22000, ISO 50001 and ISO 22301. Certificates accredited for ISO 9001, 14001, 45001, 22000 and 50001 fall within EGAC's IAF MLA scope; ISO 22301 is accredited by EGAC and sits outside that scope.

Verify any certificate: cas.com.eg/certsearch

Apply for certification →Verify a certificate

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