Tech & Digital

Hardware Startups: CE Marking and Importing into the EU

Updated: 6 October 2026 Holdwise editorial team Hardware CE Import

To bring hardware into the EU, you need two things. The product needs a CE mark to show that it meets EU rules. At the customs border, you pay duties and VAT, and you need a responsible importer. Startups that arrange both before the first container avoid delays later. At Holdwise, we keep this answer up to date and change it when the rules change.

CE marking

CE marking is self-declared conformity against the directives that apply to your product: low-voltage, electromagnetic compatibility, radio equipment for anything wireless, machinery with mechanical parts, plus the restricted-substances rules. The core requirement is the technical file: standards applied, test reports, a risk assessment, and the declaration of conformity signed by the responsible party. Test houses handle the lab work, but you keep the file. Medical devices fall under their own, separate regime: that chapter.

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

The border and the roles

Under EU product law, each party has a role. The manufacturer is responsible for conformity. The importer places foreign goods on the EU market, checks the manufacturer's work and puts its name on the box. Distributors check the products further down the chain. If you sell from outside the EU, you also need an EU authorised representative for market surveillance. A Dutch BV can take on all these roles at one address. The same BV can also be the importer for customs. With the article-23 licence, you declare the import VAT in your periodic VAT return, so you skip the payment at the border. This is one reason why half of EU e-commerce logistics is handled through the Netherlands.

You can import into the EU through the Netherlands and pay zero VAT at the border. See fiscal representation for non-EU importers. There you read about the Article 23 licence, the EORI number and the monthly work involved.

The order of steps for a startup

Design the product to meet the directives from the first prototype. Book the test lab before you ship to your crowdfunding backers. Set up the BV as the importer of record, with an article 23 licence. Logistics companies in Rotterdam can then handle storage and delivery. See the hardware cluster in Eindhoven and the holding structure above the BV.

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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We help you with import and export: VAT, customs numbers and licences. Tell us where you stand or what you are planning. You get free advice on your next step.

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

Frequently asked questions

Can we CE-mark ourselves or do we need a certificate? +

For most consumer and industrial electronics, you can declare conformity yourself against harmonised standards, with test reports from an accredited lab in the file. For certain higher-risk categories, you also need a notified body. If you map the directives for your product, you usually have the answer within an afternoon.

What does article 23 save? +

The cash that you would otherwise pay as import VAT at the border. You declare the VAT in your periodic return, so you skip paying it at the border and reclaiming it later. For imports by the container, you keep a large amount of working capital in the company.

When was this last checked? +

Reviewed 18 August 2026. The directive framework and import rules described here are the current version.

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