Anyone who imports products from China into the EU is legally treated as equivalent to a manufacturer. This means: you are fully liable for the safety and compliance of your goods. Since December 2024, the new EU General Product Safety Regulation (GPSR) has significantly tightened these obligations.
This practical guide explains which requirements apply to importers from China, how the CE marking process works, what the GPSR specifically requires from you, and which mistakes you must avoid. Based on our experience from hundreds of import projects between China and Germany.
As an importer of goods from third countries into the EU, you are considered the responsible economic operator under the Product Safety Act (ProdSG) and the GPSR. This has concrete consequences:
Important: Responsibility always lies with the EU-based company, regardless of whether the manufacturer is located in China and regardless of delivery terms such as DDP or FOB.
A common problem when importing from China: many Chinese manufacturers place a mark on their products that looks deceptively similar to the CE mark, but stands for "China Export."
| Feature | Genuine CE Mark | Fake "China Export" Mark |
|---|---|---|
| Letter spacing | Clear space between C and E | C and E are placed very close together |
| Proportions | Exact proportions according to EU specifications | Often compressed or stretched |
| Meaning | Compliance with EU directives has been demonstrated | No legal meaning in the EU |
Practical tip: If your Chinese supplier claims the product is “CE-certified,” always request the complete technical documentation, the EU Declaration of Conformity, and the test reports. A sticker alone has no legal value.
The General Product Safety Regulation (Regulation (EU) 2023/988) has applied since 13 December 2024 and replaces the old Product Safety Directive. It applies to all consumer products that are not already fully regulated by product-specific EU harmonization legislation (such as CE directives).
This means: products without a CE requirement (textiles, furniture, tableware, decorative items) must also meet basic safety requirements since 2024.
The GPSR requires a systematic risk assessment for every product. In practice, this document is the one most commonly missing in imports from China.
A risk assessment is not a test report and not a certificate. It is a systematic analysis of all foreseeable hazards that a product may pose throughout its entire lifecycle:
Design and materials
Intended use
Foreseeable misuse (especially by children)
Transport, assembly, and maintenance
Age and vulnerability of users
Clear product description and definition of the target user group
Analysis of mechanical, electrical, chemical, and thermal hazards
Evaluation of likelihood of occurrence and severity of harm
Derivation of specific protective measures (technical measures, warnings, user instructions)
Assessment of residual risk
Important: The risk assessment must match the specific product. Generic templates or documents copied from the supplier are not accepted by market surveillance authorities. During inspections, the risk assessment is often the first document requested.
Changes to the product require an updated risk assessment
New findings from complaints require reassessment
Updated standards and market requirements must be taken into account
In addition to CE and GPSR, further chemical and substance-related regulations apply to imports from China:
Practical tip: Request a current REACH test report from an accredited laboratory (e.g. SGS, Bureau Veritas, TÜV) from your Chinese supplier. Many manufacturers provide outdated reports or reports issued for different product models.
Restricts the use of hazardous substances in electrical and electronic equipment:
Applies to nearly all electrical and electronic products on the EU market.
| Regulation | Applies To | Requirement |
|---|---|---|
| LFGB / Regulation (EU) 1935/2004 | Products in contact with food | Migration tests, declaration of conformity |
| EN 71 / Toy Directive | Toys | Physical, chemical, electrical testing |
| Packaging Act (VerpackG) | All packaged products | Registration with LUCID, system participation |
| Electrical Equipment Act (ElektroG) | Electrical and electronic devices | WEEE registration with stiftung ear |
| Battery Act (BattG) | Products with batteries | Registration, take-back obligation |
Advantage: Early detection of defects before the goods are shipped.
Suitable for: Ongoing production runs with established suppliers.
Providers on site: SGS, Bureau Veritas, TÜV Rheinland, Intertek have laboratories in China.
Advantage: Higher legal certainty, local testing bodies know EU standards precisely.
Risk: Delays and costs if the product fails testing (goods have already been imported).
Suitable for: First-time imports, critical product categories.
Pre-testing in China (material tests, basic conformity) combined with final confirmation in the EU (standards compliance, documentation).
This minimizes the risk of defective goods being shipped at all, while also ensuring full EU compliance.
| Test | Cost Range |
|---|---|
| CE conformity tests (depending on product complexity) | EUR 500 to 5,000 |
| REACH laboratory test | EUR 200 to 1,500 |
| RoHS laboratory test | EUR 150 to 800 |
| Food contact material test | EUR 300 to 2,000 |
| Toy safety test (EN 71) | EUR 300 to 2,500 |
Chinese manufacturers often provide certificates that have expired, were issued for a different product model, or come from non-accredited laboratories. Check every certificate for validity, correct product assignment, and laboratory accreditation.
A CE mark on the product without the corresponding conformity assessment, technical documentation, and EU Declaration of Conformity is illegal. Simply affixing the mark is not proof of compliance.
Many importers believe that products without a CE requirement are not subject to safety regulations. Since December 2024, these products must also meet risk assessment and basic safety requirements.
The GPSR does not allow delegation of responsibility to manufacturers in third countries. Even if your supplier “has all certificates” and delivers on a DDP basis, you as the EU importer remain responsible.
A passed pre-shipment inspection does not guarantee that the delivered batch is identical. Random incoming inspections in Germany are essential to detect deviations at an early stage.
Applicable EU directives and standards for the product identified
Checked whether CE marking is required
GPSR requirements reviewed (also for non-CE products)
REACH and RoHS relevance clarified
Supplier assessed for ability to produce CE-compliant products
Current test reports from an accredited laboratory available
Conformity assessment completed (self-assessment or notified body)
Risk assessment under GPSR prepared (product-specific, not generic)
Technical documentation complete
Pre-shipment quality inspection (PSI) carried out
EU Declaration of Conformity issued
CE mark correctly affixed to product and/or packaging
Name and address of the responsible EU economic operator on product/packaging
User instructions and warnings in German
Traceability ensured (batches, supplier documentation)
VerpackG registration with LUCID (for packaged products)
WEEE registration with stiftung ear (for electrical products)
Random incoming goods inspection carried out
As a German company based in Schwäbisch Gmünd with operational teams on site in China, we know both sides of the import supply chain firsthand.
You receive a seamless end-to-end process: from manufacturer selection to conformity assessment and production control, through to legally compliant import into the EU.
Contact us for a non-binding initial consultation regarding the product compliance of your China imports.
The GPSR (Regulation (EU) 2023/988) has been in force since December 2024 and regulates product safety for all consumer products in the EU. It applies not only to manufacturers, but also to importers and distributors, and requires, among other things, a risk assessment, correct labeling, and a responsible economic operator established in the EU.
That depends on the product category. Electrical appliances, toys, machinery, personal protective equipment, and many other categories require CE marking. Textiles, furniture, or decorative items generally do not. However, products without a CE requirement must also comply with GPSR requirements since 2024.
No. A CE mark on the product is only valid if it is supported by a complete conformity assessment, technical documentation, and an EU Declaration of Conformity. Many Chinese manufacturers apply a “China Export” mark that looks similar to the CE mark but has no legal meaning.
Customs authorities may refuse import. If the product is already on the market, consequences may include a sales ban, recall, fines, and personal liability of company management.
The Declaration of Conformity confirms compliance with specific EU directives (e.g. the Low Voltage Directive). The risk assessment is a broader safety analysis of all foreseeable hazards under the GPSR. Both documents are required independently.
No. The GPSR does not allow delegation of responsibility to manufacturers in third countries. As the importer, you remain fully liable, regardless of delivery terms or supplier assurances.
