Who is responsible for the CE mark
The manufacturer carries out the conformity assessment, draws up the technical file and signs the EU declaration of conformity. The importer who places the product on the EU market has separate duties: to check that this has been done, that the product carries the CE mark and the required information, and that the documents can be handed to a market surveillance authority on request. If something is missing, the importer must not place the product on the market.
In practice, a buyer who imports directly from a factory becomes that importer. A buyer who purchases from an EU importer can rely on the importer for these checks, but should still keep copies of the key documents.
Which rules apply to which products
| Product | Main rules |
|---|---|
| Cordless drills, impact drivers, grinders, saws, rotary hammers | Machinery Directive 2006/42/EC, EMC 2014/30/EU, RoHS 2011/65/EU; chargers also LVD 2014/35/EU |
| Corded power tools | Machinery Directive, EMC, RoHS; the electrical safety requirements of the LVD are covered through the machinery rules |
| Cordless and electric mowers, grass and hedge trimmers | Machinery Directive, EMC, RoHS, outdoor noise Directive 2000/14/EC |
| Electric tillers and cultivators | Machinery Directive, EMC, RoHS |
| Drainage, booster and pond pumps | Machinery Directive or LVD depending on the product, EMC, RoHS |
| Bench drill presses, table saws | Machinery Directive, EMC, RoHS |
On top of CE marking, battery products fall under the Batteries Regulation (EU) 2023/1542, and every electrical product under the WEEE Directive. Both require producer registration in each country of sale.
The Machinery Regulation from 20 January 2027
The Machinery Directive 2006/42/EC is replaced by the Machinery Regulation (EU) 2023/1230, which applies from 20 January 2027. For buyers, three points matter:
- products placed on the market from that date need a declaration of conformity that refers to the new Regulation;
- instructions may be supplied in digital form, with a paper version free of charge on request at the time of purchase; for products that consumers may use, the essential safety information must still come on paper in the box;
- the importer’s name and address must appear on the machine or, where that is not possible, on the packaging or accompanying document.
If you are planning programmes for spring 2027, ask now whether the manufacturer will issue the declaration under the new Regulation, and from which production date.
Products already placed on the market under the Directive before that date can continue to be sold. The date that matters is when each unit is placed on the market, not when the model was designed, so a container arriving in February 2027 is assessed under the new rules.
The documents to request
- EU declaration of conformity naming the manufacturer, the model and type references, every directive or regulation applied and the harmonised standards used, signed and dated.
- Test reports behind the declaration, for example to EN 62841 for hand-held power tools, EN 55014 for EMC and the outdoor noise measurement for mowers and trimmers.
- The user manual in the languages of the countries of sale, with the safety instructions and the declared vibration and noise values.
- Rating plate artwork with model, voltage, power, production year and the CE mark.
- Battery and charger data, including cell type, capacity and the transport test summary for lithium batteries.
Check that the model numbers in the documents match the product, the rating plate and the carton. A report issued for a different housing, motor or battery is not evidence for your product. We request and check these documents for every model we import; more detail is on our quality page.
Outdoor noise: the guaranteed sound power level
Mowers, grass trimmers, hedge trimmers and some other outdoor equipment must carry a label showing the guaranteed sound power level in dB(A), as set by Directive 2000/14/EC. The declaration must mention this Directive and the conformity assessment procedure used. A missing noise label on a cordless lawn mower is one of the most common findings when imported garden tools are checked.
Vibration and noise values in the manual
For hand-held tools such as grinders, rotary hammers and hedge trimmers, the manual must declare vibration emission and noise values. Buyers sometimes treat these as marketing figures. They are not: they must come from measurement under the relevant standard, and a value missing from the manual is a gap in the documentation.
Keep in mind that a declaration covers what was tested. If the factory changes the motor supplier, the battery cells or the guard design between orders, ask whether the reports still apply. A short question at re-order saves a problem at the next inspection.
Private label does not change the obligations
If you put your brand on a tool, you may become the manufacturer in legal terms. Under EU product law, a company that places a product on the market under its own name or trademark takes on the manufacturer’s obligations. That means the declaration should be in your name, or the arrangement with the actual manufacturer must be clear and documented. Talk to us about this before artwork is approved; our private label page explains how we handle the paperwork.
GPSR and online listings
CE rules sit alongside the GPSR (Regulation (EU) 2023/988). Each product needs the manufacturer’s and the EU economic operator’s name, postal and e-mail address, a type or batch reference and the safety information in the local language. Online listings must show the same data and a product image. Marketplaces increasingly check this before a listing goes live.
Red flags when you review a supplier’s file
- a “CE certificate” issued by an unknown company, presented instead of a declaration of conformity;
- a declaration that lists only the EMC Directive for a power tool;
- test reports several years old for a model that has since been changed;
- a mower without a noise label or a manual without vibration values;
- model numbers that do not match the carton or the rating plate.
None of these automatically means the product is unsafe, but each one means you cannot yet show that it complies. Ask for corrected documents before you order. If you prefer to buy with the checks done, look at our drills and drivers and send us a list of models you need.
