Banking & Practical

CE Marking and the Importer’s Duties in the EU

Updated: 6 October 2026 Holdwise editorial team CE marking Importer Compliance

With the CE mark, the manufacturer states that a product meets EU rules. Under EU law, the importer must check this claim first. If you bring goods in from outside the EU, you have three duties: you verify, you identify and you document. If you plan ahead, you meet these duties at a low cost. If problems come up later, you pay much more. At Holdwise, we keep this answer up to date and change it when the rules change.

The importer’s three duties

Verify: before placing goods on the market, confirm that the manufacturer completed the conformity procedure. The declaration of conformity must be on hand and the technical file must be ready. The CE mark and the required information must also be on the product. Identify: put the importer's name and address on the product or packaging. This is the first thing surveillance authorities check. Document and act: keep the declaration for the retention period, which is typically ten years. Cooperate with the authorities, and recall products that turn out to be risky, whatever your profit margin.

For CE marking and the authorised representative, see which EU representative your product needs.

The roles around the importer

Manufacturers outside the EU can also appoint an EU authorised representative for market surveillance. Some laws, such as the rules for medical devices, require one. For most other products, the EU importer can be the responsible contact for the authorities. A Dutch BV can take on this role and the distribution, with one address on the box and one compliance file. See the hardware importer's guide and, for medical devices, the medtech guide.

Is your company established outside the EU? Then a Dutch fiscal representative files the VAT returns and applies for the Article 23 licence for you. See fiscal representation in the Netherlands for non-EU companies for how it works and how the costs are built up.

Which return is due when, and what happens if you miss a date? See running a Dutch BV: taxes, filings and deadlines.

How to organise compliance

The working method: a per-product compliance folder (declaration, test reports, label proofs, instructions per language), supplier contracts that require documentation, and one yearly review. This works alongside the other customs requirements: EORI, article 23, and the warehouse where relevant (the EORI guide, the article 23 scheme), and more broadly: labels, liability and recalls.

For the importer duties behind the CE mark, see machinery and electronics in Europe. That page also covers Regulation (EU) 2023/1230 on machinery, which applies from 20 January 2027, and the Cyber Resilience Act.

Free advice

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Part of Doing Business in the Netherlands, the complete 2026 guide.

Frequently asked questions

The manufacturer says the product is CE-ready. Is that enough? +

You must verify it yourself. Keep the declaration of conformity, check the CE mark and the other markings, and make sure you can show the technical file on request. Agree in the supplier contract that the documents come with each product. You then receive them automatically.

We sell the product under our own brand. Does that change our role? +

Yes. If you sell under your own name, you count as the manufacturer, with all the conformity duties. This choice has a real cost. Many brands make this choice and keep a test lab on retainer.

When was this last checked? +

Reviewed 19 August 2026. The importer rules are stable EU product law.

Sources Belastingdienst · KVK · wetten.overheid.nl Last updated: 6 October 2026