The shape and proportions
The marking consists of the letters CE in a defined graphic form. Annex II of Regulation (EC) 765/2008 contains that drawing with a grid that establishes the proportions. When enlarged or reduced, the proportions of that graduated image must be maintained.
In practical terms, this means: you scale the marking proportionally, you do not distort it, and you do not redraw it yourself. The two letters are composed of circular segments with a fixed distance between them. Anyone who sets the letters from a standard font will almost always get it wrong.
If the specific legislation for your product does not specify a size, the height is at least 5 millimeters. Some acts do prescribe their own minimum, so check this in the act applicable to your product.
The official image is in Annex II of Regulation (EC) 765/2008, with the grid lines that establish the proportions. Use that as a reference instead of a file forwarded via a supplier. Then you can be sure the proportions are correct.
Where the marking must be placed
The marking shall be affixed visibly, legibly, and indelibly to the product or to the data plate. If this is not possible or not justified due to the nature of the product, the marking shall be placed on the packaging and in the accompanying documents.
This exception is often interpreted too broadly. It applies when the product is too small or the material is not suitable for marking, not when the marking disrupts the design. An aesthetic objection is not a ground for removing the marking from the product.
Indelible also means that a sticker that comes off after a few cleanings does not comply. Consider how the product is used and cleaned in practice.
When you affix it
The marking is affixed before the product is placed on the market. This is not just a chronological order, but also one in the technical file: first the assessment, then the documentation, then the signed declaration, and only finally the mark.
If you apply the marking earlier, you are declaring something you have not yet established. This happens more often than you might think, usually because production in Asia pre-prints the marking as standard while the file is still being compiled.
The number behind the marking
If a notified body is involved in the chosen assessment route for your product, its identification number follows immediately after the CE marking. That number is affixed by the body itself or by the manufacturer according to its instructions. If no body is involved, there is no number behind the marking.
This leads to a useful check. If you see a four-digit number behind the marking on a product for which self-declaration applies, something is wrong. The reverse is also true: if the number is missing from a product for which a body is mandatory, that is a signal.
Do you have doubts about the marking on your product?
Briefly let us know what kind of product it is. We will contact you regarding what we can do and the costs involved.
The myth of the China Export logo
The story goes that a second mark exists, called China Export, with the same letters but drawn closer together. There is no evidence that such a mark officially exists or has ever been registered. What does exist are incorrectly drawn CE markings.
That does not make the subject any less relevant, just different. The question is not whether someone is using a different logo, but whether the marking on your product meets the prescribed proportions. If not, it has not been correctly affixed.
More importantly: the shape says nothing about the substantiation. A perfectly drawn marking on a product without a technical file is a greater violation than a slightly too narrow letter on a product that does comply.
What goes wrong in practice
In terms of design, we see four recurring problems. The marking is too small. It is distorted by non-proportional scaling. It is on the packaging when it could have been on the product. Or there are other marks around it that impair its legibility.
- Too small. Under 5 millimeters, while the specific legislation does not mention a different size.
- Stretched or compressed. Occurs when a designer fits the image into a box without locking the aspect ratio.
- Only on the box. While the product or the data plate had enough space.
- Crowded by other marks. Other marks may be added, as long as they do not impair the visibility, legibility, and meaning of the CE marking.
What you check
Take a sample from your stock and measure the marking. See if the proportions match the drawing in the annex. Check if it is on the product itself and whether a number is correctly present or absent behind it. Do this per supplier, as errors are consistent per factory.
- Measure the height. Under 5 millimeters without a deviating legal size is not in order.
- Place the marking next to the drawing from Annex II and see if the proportion is correct.
- Check if it is on the product or the data plate. If it is only on the box, check if there is a good reason for that.
- Check if there is a notified body number behind it and if that matches your assessment route.
- Test whether the marking remains legible after normal use and cleaning.
Is the marking on your product correct?
We check the marking, packaging, and accompanying documents against the requirements of the legislation applicable to your product. Fixed price in advance.
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