Machinery, electronics and connected products in Europe: the importer behind the CE mark
A machine, a power tool, a router or a sensor from the United States, China, Japan, Korea, Taiwan or India enters the EU with a CE marking and a company established in the EU behind it. Two new rules change the work: the Machinery Regulation from 20 January 2027 and the Cyber Resilience Act, with reporting duties since 11 September 2026. A Dutch company can be the importer and the authorised representative for all of it.
Ask about your situationProducts with CE marking, such as machinery, electrical equipment, radio equipment and pressure equipment, may only be sold in the EU with an economic operator established in the EU: the manufacturer, an importer, an authorised representative or a fulfilment service provider. The importer checks the conformity assessment, the declaration of conformity and the technical file, and puts its own name on the product. From 20 January 2027 the Machinery Regulation replaces the machinery directive. Products with digital elements fall under the Cyber Resilience Act (CRA): manufacturers report actively exploited vulnerabilities and severe incidents since 11 September 2026, and the full requirements apply from 11 December 2027. Holdwise sets up the Dutch company that is your importer and authorised representative, and works with CE and cybersecurity specialists for the technical files.
On this page: the roles behind the CE mark, what changes in 2027, the cyber rules for connected products, why the Netherlands, and the steps to the first shipment.
The roles behind the CE mark
CE marking means that the manufacturer declares that the product meets the EU rules that apply to it: the machinery rules, the low voltage directive for electrical equipment, the electromagnetic compatibility directive, the radio equipment directive for anything with a wireless connection, the pressure equipment directive, and the restriction of hazardous substances. For most products the manufacturer does the conformity assessment itself; for some high-risk machinery and equipment a notified body is involved.
The market surveillance regulation has required, since 16 July 2021, that an economic operator established in the EU exists for every CE-marked product. The importer is the company that brings the product into the EU. It checks that the conformity assessment was done, that the EU declaration of conformity and the technical documentation exist, that the product has the CE marking, the type number and the manufacturer’s name and address, and that instructions are in the language of the country of sale. It then puts its own name and address on the product or its packaging. An authorised representative is appointed by the manufacturer in writing to keep the declaration and the technical documentation and to answer the authorities. One Dutch company can be both.
What changes on 20 January 2027: the Machinery Regulation
The Machinery Regulation (EU) 2023/1230 replaces the machinery directive from 20 January 2027, without a transition: a machine placed on the market from that date must meet the regulation. It applies to machines, partly completed machinery, lifting accessories, safety components and interchangeable equipment. The main changes for a manufacturer outside the EU: instructions may be supplied in digital form, with a paper copy on request; machines with self-evolving behaviour and safety functions driven by software get specific requirements; a list of high-risk machinery, such as certain presses and woodworking machines, needs a notified body; and the duties of importers and authorised representatives are written into the regulation itself.
A product that meets the current directive today needs a gap check against the regulation for shipments after 20 January 2027. The technical file, the risk assessment, the declaration of conformity and the instructions are updated; the CE mark stays. The CE partner does that check; your Dutch company as importer keeps the updated file.
Connected products: the Cyber Resilience Act
The Cyber Resilience Act, Regulation (EU) 2024/2847, applies to every product with digital elements that connects to a device or a network: routers, smart home products, industrial controllers, connected machinery, sensors, wearables, and the software that comes with them. Medical devices, vehicles and aviation products have their own rules and are excluded.
The rule applies in two steps. Since 11 September 2026 the manufacturer must report an actively exploited vulnerability or a severe incident: an early warning within 24 hours, a notification within 72 hours, and a final report within 14 days after the fix. This applies to products already on the market. From 11 December 2027 the full requirements apply: security by design, a vulnerability handling process, security updates for at least five years, technical documentation, and CE marking that covers cybersecurity. Importers check that the manufacturer did this; authorised representatives keep the documentation. A manufacturer outside the EU that sells connected products in Europe needs an EU company that can do that checking and answer the authorities.
Why the Netherlands for industrial and electronic products
Rotterdam and Schiphol bring containers and air freight into Europe within hours of arrival. The logistics parks at Venlo and Tilburg are the distribution base for many machinery and electronics brands from Asia and the United States. The Dutch market surveillance authority for electronics and radio equipment is the Dutch Authority for Digital Infrastructure (RDI); for machinery at work it is the Netherlands Labour Authority; for consumer products the Netherlands Food and Consumer Product Safety Authority (NVWA). All three work in English.
A Dutch company as importer holds the EORI number and the Article 23 licence, so import VAT is reported in the VAT return and nothing is paid at the border. Corporate tax is 19% on the first €200,000 of profit and 25.8% above that. Service engineers you bring to the Netherlands can use the 30% ruling. Read more on importing and distributing through the Netherlands and setting up a subsidiary in Europe.
Based on Regulation (EU) 2019/1020 (market surveillance), Regulation (EU) 2023/1230 (machinery), Directives 2014/35/EU, 2014/30/EU and 2014/53/EU, Regulation (EU) 2024/2847 (Cyber Resilience Act) and the guidance of the RDI, as applied in September 2026. Technical files are prepared by specialised partners; Holdwise coordinates.
Who does what
Holdwise sets up and runs the Dutch company and stays your single point of contact. Specialist partners do the licence and product work. You keep one contact, one file and one invoice.
Your company
- Own the product, the design and the technical documentation
- Do the conformity assessment and sign the declaration of conformity
- Run the vulnerability handling for connected products
- Sign the power of attorney and the representative mandate
The Dutch base
- Sets up the Dutch company (a BV), by power of attorney, with the notary
- Registered office, the address that goes on your products
- KVK number, tax number, VAT number, EORI number, the Article 23 licence
- Bank account, bookkeeping, VAT returns, annual accounts, corporate tax, payroll for service staff
- Producer registrations for packaging, batteries and electronics in the Netherlands
- Single point of contact for the CE partner, the warehouse and the customs agent
Licences and product rules
- CE gap check against the Machinery Regulation and the electrical, EMC and radio rules
- Cyber Resilience Act readiness: reporting process, documentation, conformity route
- The authorised representative mandate and the importer checks per shipment
- Notified body contact where a high-risk machine or radio product needs one
- Warehousing, installation partners and service logistics in the EU
The route, step by step
What happens from your first question to the day your first product is on the European market.
- One question. You tell us what you make, which EU rules it falls under today, whether it connects to a network, and which countries you sell in. We answer in writing with the structure that fits and one written proposal.
- The Dutch company. The notary sets up the BV by power of attorney with the parent as shareholder. You receive the KVK number, the tax number, the VAT number and the EORI number. The bank file starts on day one.
- The roles. Your Dutch company becomes the importer and the authorised representative. The partner drafts the mandate and checks the technical files.
- The 2027 check. The CE partner reviews each product against the Machinery Regulation and, for connected products, against the Cyber Resilience Act, and lists what must change before the dates.
- The label. The Dutch name and address on the product, instructions in the languages of your markets, producer registrations in place.
- Operations. Stock in a Dutch warehouse, machines delivered and installed across the EU, invoices from your own company, VAT and bookkeeping done. One monthly overview, one point of contact.
Related guides
The other parts of the route to Europe, on the same site.
Common questions
Ask about your own situation
Tell us what you make or sell, where your company is and which countries you want to sell in. You get a written answer. Where a Dutch company fits, we write down what it would look like and what it costs.
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