Machinery, electronics and connected products in Europe: CE marking and the importer

The roles for CE-marked products

With CE marking the manufacturer declares that the product meets every EU rule that applies to it, such as the machinery rules, the low voltage directive for electrical equipment, the directive on electromagnetic compatibility (EMC), 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, the procedure that shows the product meets those rules, itself. Some high-risk machinery and equipment must also be examined by a notified body, an independent testing organisation designated by an EU country.

Many CE-marked products, such as machinery, toys and electrical and radio equipment, need an economic operator established in the EU, a requirement of the market surveillance regulation since 16 July 2021 (Regulation (EU) 2019/1020, Article 4). The importer is the company that brings the product into the EU. It checks that the conformity assessment was done and that the EU declaration of conformity and the technical documentation exist, and it checks the CE marking, the type number and the manufacturer’s name and address on the product, as well as instructions in the language of the country of sale. The importer then puts its own name and address on the product or its packaging. The authorised representative is appointed by the manufacturer under a signed mandate, keeps the declaration and the technical documentation, and answers the authorities. One Dutch company can take both roles.

The new machinery rules from 20 January 2027

Regulation (EU) 2023/1230 on machinery replaces Directive 2006/42/EC from 20 January 2027 with immediate effect, so every machine placed on the market from that date must meet the regulation. It covers machines, partly completed machinery, lifting accessories, safety components and interchangeable equipment. For a manufacturer outside the EU, the regulation allows digital instructions, with a paper copy on request, and sets specific requirements for safety functions controlled by software and for machines whose behaviour changes as they learn. Machines on the high-risk list in Annex I need extra checks, by a notified body for those in Part A, while for Part B machines, such as certain presses and woodworking machines, the manufacturer can assess the machine itself when it applies the harmonised European standards in full (Article 25(3)). The duties of importers and authorised representatives are now written into the regulation itself.

A product that meets the current directive today needs a comparison with the new regulation (gap check) for shipments and for unsold stock after 20 January 2027. The technical file, the risk assessment, the declaration of conformity and the instructions are updated, while the CE mark stays the same. The CE partner does that check, and your Dutch company keeps the updated file as importer.

The Cyber Resilience Act for connected products

The Cyber Resilience Act, Regulation (EU) 2024/2847, applies to every product with digital elements that connects to a device or a network, such as 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. For radio equipment, the cybersecurity requirements of the radio equipment directive have applied since 1 August 2025.

The Act takes effect in two steps. Since 11 September 2026 the manufacturer must report an actively exploited vulnerability or a severe incident, with an early warning within 24 hours and a notification within 72 hours, followed by a final report within 14 days after a fix is available for a vulnerability or within one month for a severe incident. That duty also covers products already on the market. From 11 December 2027 the full requirements apply, namely security built into the product design, a process for handling vulnerabilities, security updates for at least five years, technical documentation and CE marking that includes cybersecurity. Importers check that the manufacturer has done this work, and an authorised representative, if you appoint one, keeps the documentation. A manufacturer of connected products outside the EU that sells in Europe relies on its EU importer for the importer checks and for contact with the authorities.

Why the Netherlands for industrial and electronic products

Containers and air freight enter Europe through Rotterdam and Schiphol. Many machinery and electronics brands from Asia and the United States distribute from logistics parks at Venlo and Tilburg. In the Netherlands the Dutch Authority for Digital Infrastructure (RDI) supervises electronics and radio equipment, the Netherlands Labour Authority supervises machinery used at work, and the Netherlands Food and Consumer Product Safety Authority (NVWA) supervises consumer products.

As importer, your Dutch company holds the EU customs number (EORI) and the Article 23 licence, which lets it report import VAT in its VAT return and avoid paying that VAT at the border, although any customs duty is still due at import. Corporate tax is 19% on the first €200,000 of profit and 25.8% on profit over that amount. Service engineers you bring to the Netherlands may be entitled to the 30% ruling, a tax relief on part of their salary. Importing and distributing through the Netherlands and setting up a subsidiary in Europe cover these subjects in more detail.

Based on Regulation (EU) 2019/1020 (market surveillance), Regulation (EU) 2023/1230 (machinery, as amended by Regulation (EU) 2026/1744), 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. The European Commission describes the reporting duties in Cyber Resilience Act reporting obligations and the summary of the Cyber Resilience Act. Specialised partners prepare the technical files, and we coordinate their work.