Compliance questions arrive late and in a hurry, usually from a customer who needs the file before a listing or a delivery. The difficulty is rarely technical: it is that the words used in commercial conversation — certificate, test, approval, « CE certificate » — are used as if they named one thing, when they name objects with different authors, different legal weight and different lifespans. Sorting them out takes one page and saves a referencing.
Three objects, three authors
| Document | Who issues it | What it establishes |
|---|---|---|
| A test report | A laboratory, on the samples it received | That those samples, on that date, met the clauses of the standard that were actually tested. It says nothing about the rest of the production |
| A declaration of conformity | The manufacturer, or its authorised representative, alone | That the manufacturer takes legal responsibility for the product meeting the European legislation the declaration lists. It is signed, not awarded |
| A notified body certificate | A body designated by a member state for that legislation and that scope of products | That an independent third party carried out the examination the legislation demands. It carries the body's identification and the limits of its scope |
The hierarchy surprises people the first time. The declaration, which anybody can print on their own letterhead, is the document the legislation actually requires. The test report, which looks the most technical and costs the most to obtain, has no standing on its own — it is evidence supporting the declaration. The third party's certificate exists only where the legislation says a third party must be involved, and where it says so, no declaration is valid without it. All three can sit in one file and the file can still be incomplete.
When a third party is obliged, and when it is not
For a great deal of European product legislation, the manufacturer assesses conformity itself and declares it. That is not a loophole; it is the design. The text sets the requirements, lists the assessment procedures that may be used, and says which ones are available for which category of product. For certain categories — where the risk is higher, or where the legislator decided self-assessment was not enough — the available procedures all involve a notified body, and then there is no route to a valid declaration without one. Which categories those are is set by the text applicable to your product, varies considerably between product families, and is not negotiable; read that text rather than generalising from a neighbouring industry.
Where a body is involved, it does not « give you the CE marking ». The marking is affixed by the manufacturer, under its own declaration and its own responsibility; the body's identification appears next to it when the procedure made the body responsible for part of the assessment or the production control. A European buyer who understands this reads the marking as a claim made by you, not as an approval granted to you — which is exactly why the file behind it is what gets examined.
What a report presented by a factory is worth
- Whose product it describes. A report issued to another company, on a similar model, is a report about someone else's product. Read the applicant's name and the model reference and compare them with what you are selling.
- What was tested. A standard has many clauses and a report can cover a selection of them. The scope and the list of clauses tested are the content; the conclusion line is a summary of whatever was in that scope.
- What the sample actually was. Which version, which material, which supplier for the critical component. A report on a pre-production sample can describe a product that no longer exists.
- Which standard, in which version. Standards are revised. A report against a superseded version is not worthless, but it is not the same claim, and a buyer will ask.
- Who the laboratory is. The value of a test report rests on the laboratory's competence being recognised, which is a separate mechanism from a body being notified. A laboratory can be entirely competent and not a notified body, and a notified body is not notified for everything it is capable of.
- Whether it is even the right kind of document. Where the legislation required a notified body, a thick stack of laboratory reports does not substitute for the certificate, however good the reports are.
Checking that a body is designated for your product
A notified body is not notified in general. A member state designates it for named legislation, and for a scope of products and procedures that is written down. The Commission keeps a public database of those designations: each body has an identification number, and its entry lists the legislation and the scope it may act under. Finding your body in that database, with your legislation and your product category inside its listed scope, takes a few minutes and is the single check most often skipped. A certificate issued outside a body's scope is not worth what it cost, and a buyer's quality department will find that before you do.
Validity, and what makes a file go stale
A test report does not expire by itself; what expires is its relevance. It stops describing your product the day you change a material, the supplier of a critical component, a firmware version or a construction detail — and those changes are made in the factory for good reasons, by people who have never seen the report. Certificates issued by a notified body generally do carry a period and conditions, and a change to the type obliges you to go back. The habit that keeps a file alive is a short list kept beside it: which document covers which version, and what change would invalidate which document. As for what a European buyer looks at first in all of this: the declaration of conformity, not the test reports. It is one page, it names the exact product, the legislation claimed, the standards relied on, the person who signed and the company standing behind the signature. If it is missing, generic, unsigned, or lists legislation that does not apply to the product, nothing in the rest of the file repairs it — and the buyer stops reading there, because that page is the one they will be handed if a market authority ever asks them a question.
Build the file for someone who will read it without you in the room: a declaration naming the exact model, the reports it rests on, and, where the legislation required one, the certificate of a body you have checked is designated for that product. Then keep it versioned, because the real question is not whether the file was right when it was made — it is whether it still describes what left the factory last month.
Where to read it yourself
Official pages, opened and checked on 15 October 2026. Where a rule changes, these are the addresses that change with it — this article does not.