Affixing the CE mark
The CE mark must be affixed visibly, legibly, and indelibly to the product before it is placed on the EU market. Where the nature of the product does not permit this, the mark is affixed to the packaging and the accompanying documents. The graphic form, minimum size, and proportions are set in Annex II of Regulation (EC) No 765/2008. Article 30 of the same Regulation states the principles: only the manufacturer or authorised representative may affix it, it must not be applied to products outside the scope of legislation that mandates it, and other markings must not impair its visibility or legibility.
This page sets out the formal requirements for affixing the mark — graphic, size, location, indelibility — and the rules for the four-digit Notified Body identification number that accompanies the mark where third-party assessment has taken place. The legal nature of CE marking and its meaning are covered in what CE marking is.
Legal basis
- Regulation (EC) No 765/2008, Article 30 (general principles of the CE marking) and Annex II (form of the CE marking).
- Decision No 768/2008/EC, Annex I, Article R12 (rules and conditions for affixing the CE marking and other markings).
- Sectoral acts repeat these provisions and may add specifics — e.g., Article 17 of Regulation (EU) 2023/1230 sets minimum height for machinery; Article 20 of Regulation (EU) 2017/745 (MDR) covers medical device-specific marking; Article 17 of the Toy Safety Regulation 2025/2509 covers toys.
The graphic form
The CE marking consists of the letters "CE" drawn according to the proportions in Annex II of Regulation 765/2008. The mark is constructed as follows:
- The two letters have the same vertical dimension, which is not less than 5 mm.
- Each letter is constructed on a notional grid of two semicircles and straight segments. The "C" is a circular arc with an opening on the right, and the "E" comprises three horizontal arms attached to a vertical spine.
- When the mark is reduced or enlarged from the model in Annex II, the proportions in that Annex must be respected. The Commission publishes a vector model of the mark on its CE marking affixing page.
The figure above is a simplified illustration of the construction principle. The normative graphic is in Annex II of Regulation 765/2008 and in the Commission's downloadable model. Any rendering used by a manufacturer must be derived from the normative version.
Minimum size
The default minimum height is 5 mm. Sectoral acts may permit a smaller mark on very small products:
- Toy Safety Regulation (EU) 2025/2509, Article 17(5) — for very small toys, the CE mark may be on a label or accompanying leaflet.
- Medical Devices Regulation (EU) 2017/745, Annex V — the 5 mm minimum may be waived for small devices where the size of the device makes it impossible.
- Pyrotechnic Articles Directive 2013/29/EU — small fireworks may have the mark only on the packaging.
- Ecodesign delegated regulations — minimum sizes can be larger for energy-related products where on-product visibility is important.
Where a sectoral act sets a different minimum, that minimum applies. The default 5 mm cannot be reduced merely because the marking surface is congested with other text — design must accommodate the mark.
Placement on the product
The CE mark must be on the product itself. Article 30(4) of Regulation 765/2008 specifies that "where this is not possible or not warranted on account of the nature of the product, [the mark] shall be affixed to the packaging and to the accompanying documents". The qualifications are interpreted narrowly:
- "Not possible" covers physical impossibility — e.g., a product too small to bear a 5 mm mark.
- "Not warranted by the nature" covers cases such as bulk-supplied components, certain measuring instruments, or pressure equipment where surface conditions or product use make on-product marking impractical.
Commercial preference is not a justification. A manufacturer cannot place the mark only on the packaging because on-product marking is aesthetically undesirable.
Where the mark appears on packaging or documents in addition to the product, all instances must comply with Annex II. Affixing it on the box but not on the product itself, where on-product marking is feasible, is non-compliance.
Visibility, legibility, indelibility
Article 30(4) requires the mark to be "visible, legible and indelible". These three criteria mean:
- Visible — placed where it can be seen during normal use of the product. A mark hidden behind a removable panel that is not accessible in normal use does not satisfy this. For products requiring assembly, the mark must be visible after assembly.
- Legible — the letters must be readable at a normal viewing distance under normal conditions. Pale grey on grey, or a 5 mm mark on a high-clutter label, fails legibility.
- Indelible — the mark must persist for the product's expected service life under foreseeable conditions. Methods that satisfy indelibility include engraving, etching, embossing, durable printing, or labels with appropriate adhesive specifications. Stickers that can be removed without damage may fail indelibility tests.
Indelibility is a frequent finding in market surveillance. Where the rated environment includes chemicals, abrasion, UV exposure, or solvents, the affixing method must be chosen accordingly. A printed label that fades after a year of typical use does not meet the indelibility requirement.
The Notified Body identification number
Where a Notified Body has been involved in the production-control phase of the applicable conformity assessment module, its four-digit identification number must follow the CE mark. Modules in which the number appears on the product:
- Module A2 (random product checks)
- Modules D and D1 (production quality assurance)
- Modules E and E1 (product quality assurance)
- Modules F and F1 (product verification)
- Module G (unit verification)
- Modules H and H1 (full quality assurance, with or without design examination)
Modules in which the number does not appear:
- Module A (internal production control, no NB)
- Module A1 (some sectoral acts; check the act)
- Module B alone (design-only; the production-phase module determines whether a number is used)
- Modules C and C1 paired with B (where no NB role in production-phase)
The number appears immediately after the CE mark, in the same height as the mark. Where the number is applied to the packaging or accompanying documents (rather than the product itself), it must accompany the CE mark wherever the mark appears.
Who affixes the mark
Only the manufacturer or its authorised representative acting under written mandate may affix the CE mark (Regulation 765/2008, Article 30(1)). The mark is affixed at the end of the conformity assessment process, after the EU Declaration of Conformity has been drawn up and signed. Importers and distributors may not affix the mark; their obligations are to verify its presence and correctness (importer obligations, distributor obligations).
An economic operator placing a product on the market under its own name or trademark, or making substantial modifications to a product already on the market, is treated as the manufacturer (Decision 768/2008/EC, Article R6) and assumes full responsibility for affixing the mark and the underlying conformity assessment.
Other markings
The CE mark may be accompanied by additional markings required by sectoral acts or by separate EU legislation. Examples:
- Ex marking (ATEX Directive 2014/34/EU) — equipment category code, accompanying the CE mark on equipment intended for use in potentially explosive atmospheres.
- Equipment-specific safety symbols — e.g., the IEC 60417 symbols for hot surface, double insulation.
- WEEE crossed-out wheelie bin (Directive 2012/19/EU) — separate symbol for waste electrical and electronic equipment.
- Pictograms required by sectoral acts — toy age warnings, PPE category indicators, medical device patient-warning symbols.
Article 30(2) of Regulation 765/2008 prohibits affixing marks, signs, or inscriptions on a product that are liable to mislead third parties as to the meaning or the form of the CE marking. Decorative use of "CE"-like marks, fictional certification logos, or marks designed to mimic the CE graphic are prohibited.
The "China Export" myth
A claim persists that an unofficial "CE" mark stands for "China Export" and is distinguished from the EU mark by narrower letter spacing. The claim has no basis in EU law. There is one CE marking, defined by Annex II of Regulation 765/2008. The Commission has stated that no other "CE" marking is officially registered. Market surveillance treats marks with non-conforming proportions as either incorrectly drawn EU marks (an infringement) or as deliberate counterfeits (subject to enforcement and customs action), not as a separate scheme.
Affixing on packaging and documents
Where the mark is affixed on packaging or accompanying documents in addition to (or instead of, where the product cannot bear it) the product itself:
- The proportions, minimum size, and indelibility requirements apply to each instance of the mark.
- The mark must be visible and legible on the packaging in normal retail conditions (with the product on a shelf or in display packaging).
- The accompanying documents include the user manual, where one is required, and the EU Declaration of Conformity supplied with the product.
Common errors
- Incorrect proportions. Marks drawn in a generic sans-serif font, with unequal letter heights, or with the wrong arc-to-stroke ratio do not satisfy Annex II. Manufacturers should derive the mark from the Commission's vector source rather than redrawing it.
- Under-sized marks. A mark less than 5 mm high without sectoral derogation. Common on very small electronic products where designers prioritise aesthetics.
- Mark not visible after assembly. Placement on a surface concealed once the product is in normal use does not meet the visibility requirement.
- Removable labels failing indelibility. Sticker labels that detach during cleaning, shipping, or one year of use fail indelibility.
- Notified Body number with no Notified Body engagement. The four-digit number is meaningful; affixing it without an underlying certificate is a serious infringement.
- Notified Body number for a body that was engaged only for Module B. Module B is design-only; the number is not affixed unless a production-phase module (C2, D, E, F, G, H, A2) was performed.
- Mark on packaging only when on-product marking is feasible. The Article 30(4) exception is narrow.
- CE alongside misleading marks. Decorative "approved" or "certified" logos placed near the CE mark may suggest a certification scheme that does not exist.
- CE on a product not within scope of any act. Affixing the mark to a product not covered by a CE-mandating act is itself an infringement (Article 30(2)).
Worked example: a small wireless sensor
A 30 mm × 30 mm wireless sensor placed on the market under the Radio Equipment Directive 2014/53/EU, the RoHS Directive 2011/65/EU, and the Battery Regulation (EU) 2023/1542 (for its internal coin cell) requires the CE mark at the 5 mm default minimum. If the product's footprint cannot bear a 5 mm mark with adequate legibility, the manufacturer may affix it on the packaging and on the EU Declaration of Conformity supplied with the product, citing the impossibility of on-product marking. The mark must still be on every unit of packaging, the model number must be present, and the indelibility requirement must be met on each instance. If a Notified Body was engaged (for example, under the cybersecurity essential requirements added to RED by Commission Delegated Regulation (EU) 2022/30 where harmonised standards have not been applied in full), the four-digit number follows the CE mark.
Sources
- Regulation (EC) No 765/2008, Article 30 and Annex II — EUR-Lex.
- Decision No 768/2008/EC, Article R12 — EUR-Lex.
- European Commission — Affixing the CE marking — single-market-economy.ec.europa.eu.
- Regulation (EU) 2017/745 (MDR), Article 20 and Annex V — EUR-Lex.
- Commission Notice — Blue Guide 2022, Section 4.5 — EUR-Lex.