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CE Marking Checks During Product Inspection | Label Placement, Declaration Matching, Inspection Limits

During product inspection, UTS checks whether the CE mark is on the correct product, whether the model and rating information match the approved files, and whether the production goods can be linked to the supplied EU Declaration of Conformity (DoC) where one is required.

Typical checks include the CE mark, model number, rating label, packaging, manual, warnings, DoC and specified components. If the production product differs from the approved version, our team records the exact difference for review.

Product inspection checks the goods being produced. It does not replace conformity assessment, technical document review or laboratory testing.


Check the CE Mark

For each relevant SKU, check:

  • CE mark is present

  • mark is in the approved position

  • mark is readable

  • shape and proportions are correct

  • size matches the approved artwork

  • printing, moulding or engraving is clear

  • the mark is not covered after assembly

  • old and new label versions are not mixed

The inspection instruction should name the approved reference.

For example:

Compare the production rating label with Artwork Rev. 4.

That is more useful than:

Check CE marking.

If five SKUs use five different label files, each version should be checked against the correct artwork.

Check the Position

The CE mark should normally appear on the product or its data plate. If the applicable EU rules allow another location because direct marking is not possible, the approved packaging or accompanying document should be checked instead.

Typical problems include:

  • CE mark missing from the product

  • mark printed only on the box although approved artwork shows it on the product

  • mark placed on removable protective film

  • another label covering part of the mark

  • mark hidden after final assembly

  • two production batches using different positions

  • correct marking on one SKU but missing on another

A close-up photo should show the mark. A second photo should show where it is located on the product.

Measure the Mark

The general minimum CE mark height is 5 mm unless the rules for the specific product provide another requirement.

Do not rely only on visual judgement when a clear measurement can be taken.

Example:

Approved artwork: 6.0 mm
Production: 3.8 mm
Difference: 2.2 mm

The report should record the measurement and the approved reference.

Factories often reduce the CE mark when they add more information to a small rating label, such as:

  • model number

  • voltage

  • power

  • manufacturer details

  • warnings

  • recycling symbols

  • batch number

The mark can still look normal at first glance but no longer match the approved artwork.

Check Print Quality

Look for:

  • blurred printing

  • missing parts of the logo

  • weak contrast

  • scratched labels

  • loose labels

  • ink that rubs off easily

  • shallow engraving

  • distorted moulded marks

If the working instruction requires a rubbing or adhesion check, UTS can perform the agreed on-site check and record the result.

A simple rubbing check only shows whether an obvious printing problem is present. It should not be described as proof of long-term legal durability.

Match the Product

Compare these five points:

Product → Rating Label → Packaging → Manual → DoC

They should identify the same product or a clearly covered variant.

Example:

  • KX-100

  • KX-100B

  • KX-110

  • KX-110EU

These products may use the same housing, but the suffix may identify a different:

  • voltage

  • plug

  • adapter

  • battery

  • PCB

  • wireless module

  • destination market

  • product revision

If the product says KX-100B and the DoC only says KX-100, report the difference.

Do not automatically write that the declaration is invalid. First check whether KX-100B is included in the manufacturer's documented model family.

Cover Every SKU

A 10,000-unit order may contain several different regulatory versions.

Example:

SKU Order Qty CE Mark DoC
A100 4,000 Checked Match
A110 2,500 Checked Match
A120 1,500 Checked Mismatch
A130 1,000 Checked Match
A140 1,000 Checked Match

The total order is 10,000 units, but the A120 problem would be missed if the inspection only focused on the largest SKU.

Separate versions should be covered when they differ in:

  • model

  • voltage

  • plug

  • rating label

  • packaging

  • manual language

  • destination market

  • technical configuration

Sample quantity and SKU coverage are two different controls.

Match the DoC

Check whether the supplied Declaration of Conformity clearly covers the production model.

Useful fields include:

  • manufacturer name

  • manufacturer address

  • product name

  • model or type

  • serial or batch reference where applicable

  • applicable EU legislation

  • standards or technical specifications

  • Notified Body information where applicable

  • issue date

  • signatory name

  • position

  • signature

Do not judge the document by how professional it looks.

A signed document with a CE logo is still the wrong document if it refers to another model.

Example:

Production model: Q700B
DoC model: Q700

The inspection finding should state exactly that.

Check Model Families

One DoC can cover several models when those models are clearly identified.

For example:

Product: AB-100EU
DoC: AB-100 Series

The next check is whether AB-100EU appears in:

  • the DoC

  • an annex

  • a model list

  • a technical model matrix

  • another approved document linking the variant to the declared series

Do not treat every character difference as the same type of problem.

DoC Production Check
AB100 AB-100 Confirm naming format
AB-100 AB-100EU Confirm variant coverage
AB-100 AB-200 Check different-model coverage
Version 1 Version 2 Check design and component changes

A hyphen may be only a naming difference. A new version number may represent a different technical product.

Check the DoC Date

Do not reject a DoC only because it is old.

Check whether anything important changed after it was issued.

Examples:

  • product design changed

  • component changed

  • material changed

  • manufacturer details changed

  • newer DoC exists

  • legislation changed

  • relevant standard changed

  • conformity assessment information changed

A 2023 DoC for an unchanged product may still be relevant.

A 2025 DoC may already be outdated if the production configuration changed in 2026.

The date alone does not answer the question.

Check Listed Standards

Do not treat a list of EN standards as proof that production complies with them.

During product inspection, our team can compare the standards shown on the supplied DoC with the buyer-approved file.

A routine factory inspection does not normally decide:

  • whether every listed standard applies

  • whether the edition is current

  • whether a transition period applies

  • whether another standard is missing

  • whether every clause has been tested

Those points belong to technical document review or laboratory testing.

Check the Rating Label

For electrical products, compare the rating label with the approved specification.

Typical fields include:

  • model

  • voltage

  • frequency

  • current

  • power

  • output

  • adapter rating

  • protection information

  • manufacturer details

Example:

Approved: 220–240 V~, 50/60 Hz, 800 W
Production: 220–240 V~, 50 Hz, 1000 W

The CE mark may be correct, but the product rating is not the same.

Another example:

Approved adapter: 12 V DC, 2 A
Production adapter: 12 V DC, 3 A

The approved adapter is rated at 24 W.

The production adapter is rated at 36 W.

That is a real technical difference and should be reported.

It does not automatically prove the product is non-compliant. The technical team needs to decide whether the existing evidence covers the changed adapter.

Match Packaging and Manuals

Check that the product, retail box, manual and carton all belong to the same version.

Common findings include:

  • correct product in the wrong retail box

  • EU product in packaging for another market

  • old model number on the carton

  • current product packed with an old manual

  • packaging rating different from product rating

  • different SKUs mixed in one carton

  • warning label for another version

The buyer-approved market language should also be checked.

The UTS high-chair working instruction supplied as a reference requires packaging information and manuals to match the specification and requires relevant warnings and instructions for the market where the product is sold.

Check Artwork Versions

Do not accept a label only because the information looks generally correct.

Check the revision.

Example:

  • V1 — original design

  • V2 — updated model

  • V3 — updated manufacturer information

  • V4 — current approved version

If V4 is approved but production uses V2, report:

Production rating label: Rev. 2
Buyer-approved artwork: Rev. 4

Also check whether both versions are mixed in the same lot.

If the same artwork-control problem appears across several orders, the issue may be related to the supplier's document-control system. A separate Quality Management System Audit can review how the supplier controls revisions and production documents.

Check Production Changes

Compare mass production with the approved configuration where reference information is available.

Important changes may include:

  • adapter

  • power supply

  • cord

  • plug

  • PCB

  • motor

  • battery

  • wireless module

  • fuse

  • transformer

  • insulation

  • plastic material

  • coating

  • enclosure construction

Example:

Approved adapter: Supplier A, ADP-1202
Production adapter: Supplier B, BX12-200

Record:

  • component manufacturer

  • model

  • rating

  • markings

  • connector

  • photos

Do not write:

CE approval is invalid.

Write what actually changed.

If these differences need to be found before production is finished, UTS can include the comparison in a During Product Inspection.

Check Notified Body Numbers

Do not expect a four-digit number beside every CE mark.

A Notified Body number is only required where the applicable conformity assessment procedure requires it in connection with the CE marking.

If the buyer's compliance file shows a number should be present, check:

  • number is present

  • number matches the approved file

  • number is readable

  • number is used on the correct SKU

  • another model has not copied it by mistake

Do not report a missing four-digit number as a defect just because a CE mark is present.

The conformity route must first be known.

Check EU Product Information

CE is only one marking on many EU products.

Depending on the product and applicable rules, the inspection file may also require checks for:

  • manufacturer name

  • manufacturer contact details

  • importer information

  • authorised representative where applicable

  • EU responsible economic operator where applicable

  • batch number

  • serial number

  • product type

  • warnings

  • safety information

These are separate requirements. They should not all be called “CE marking.”

For products covered by the relevant EU market-surveillance rules, economic-operator information may need to appear on the product, packaging, parcel or accompanying document.

For consumer products covered by the GPSR, applicable contact information can also include a postal and electronic address.

Our team should compare the production information with the approved buyer file instead of deciding the legal role of each company during a routine factory inspection.

Use the Correct Sample Size

UTS uses the agreed ISO 2859-1 or equivalent ANSI/ASQ Z1.4 sampling plan where applicable.

The sample size comes from:

  • lot size

  • inspection level

  • sampling table

It should not be calculated using an invented fixed percentage.

The UTS AQL reference gives this example:

Lot size: 4,000 units
Inspection: Normal
General Inspection Level: II
Code letter: L
Sample size: 200 units
AQL 2.5: Ac 10 / Re 11

This means 200 units are selected under that sampling example.

It does not mean every regulatory version can be ignored once 200 units have been selected.

If the 4,000 units contain several voltage, plug or label versions, the agreed inspection plan should still cover the relevant variants.

Do Not Use AQL as a CE Allowance

AQL is an inspection sampling method. It does not mean a legal requirement can be ignored because only a few sampled units are affected.

The UTS high-chair working instruction uses:

  • General Inspection Level II

  • Critical: None

  • Major: 2.5

  • Minor: 4.0

Those values belong to that working instruction and should not be copied automatically to every product.

The same document lists missing CE marking for European shipments as an item that must be checked.

If a CE-related issue is found, record:

  • model

  • number checked

  • number affected

  • approved reference

  • actual condition

  • photos

Example:

32 units checked
4 units missing the expected CE mark

Do not turn that into a made-up “acceptable CE failure rate.”

Check Repeated Problems

One damaged label and a repeated production error are not the same.

Example:

First finding: 1 wrong model sticker
Additional selected checks: 20 units
Same problem found: 8 units

Report:

  • 20 checked

  • 8 affected

  • SKU

  • carton or batch where available

  • photos

  • approved label reference

This gives the buyer enough information to decide whether the goods need sorting, rework or further inspection.

Write Facts in the Report

Do not write:

Product failed CE certification.

Write:

CE marking was missing on 4 of 32 inspected units of Model X200.

Do not write:

The DoC is invalid.

Write:

The inspected product is marked Q700B. The supplied DoC identifies Q700. Q700B was not found in the supplied document.

Do not write:

Product is not compliant with EU law.

Write:

Production adapter is AD-24B. Buyer-approved specification identifies AD-24A.

A third-party inspection report should show what was found, where it was found and how many sampled units were affected.

Decide the Next Action

Different problems need different actions.

Finding Next Step
Missing or wrong CE label Correct affected goods and verify the rework
Wrong packaging Replace or rework packaging
Wrong manual Replace the manual and check affected production
DoC model mismatch Confirm model coverage or obtain the correct document
Different adapter Technical review of the changed component
Different battery Review existing safety and technical evidence
Different PCB Review whether existing testing still applies
Different wireless module Review radio-related evidence
Product coverage unclear Keep the issue open until suitable evidence is available

Re-inspection can confirm that physical rework was completed.

It cannot decide whether a changed PCB, battery or power supply is covered by previous laboratory evidence.

Know the Inspection Limit

UTS product inspection can check:

  • physical marking

  • product identity

  • rating information

  • packaging

  • manuals

  • visible components

  • approved document references

A normal product inspection does not usually determine:

  • every applicable EU law

  • whether the complete technical file is sufficient

  • whether every standard was selected correctly

  • whether every required laboratory test was completed

  • whether a full risk assessment is sufficient

  • whether every internal material meets regulatory requirements

  • whether the complete conformity assessment was carried out correctly

The difference is simple:

Activity Main Question
Product inspection Does sampled production match the approved references?
Document review Do the available files support the product?
Laboratory testing Does the tested sample meet the selected technical requirements?
Conformity assessment Has the required EU process been completed?

UTS should not describe a shipment as “CE certified” based on a product inspection.

Use Lab Testing When Needed

Some questions cannot be answered by looking at the product.

Laboratory testing may be needed for:

  • electrical safety

  • EMC

  • radio performance

  • mechanical safety

  • chemical substances

  • flammability

  • material performance

  • other product-specific requirements

CE is not one single laboratory test.

The test plan depends on:

  • product type

  • intended use

  • electrical design

  • wireless functions

  • materials

  • target market

  • applicable legislation

UTS can arrange product-specific laboratory testing where the buyer needs technical evidence beyond the physical inspection.

Prepare the Inspection File

Before inspection, provide:

  • purchase order

  • model list

  • SKU list

  • approved specification

  • approved product photos

  • approved sample where available

  • current label artwork

  • current packaging artwork

  • current DoC where applicable

  • approved manual

  • warning artwork

  • destination market

  • language requirements

  • important component list

For products with several versions, use a model matrix.

Example:

Model Voltage Plug Packaging Manual DoC
X100-EU 230 V EU Rev. 4 V3 DoC-2026-01
X100-UK 230 V UK Rev. 2 V2 Buyer reference

This prevents the wrong label, manual or document from being compared with the wrong SKU.

Example

An order contains 8,400 rechargeable products:

  • R100 — 3,000 units

  • R110 — 3,000 units

  • R120 — 2,400 units

The buyer supplies Artwork Rev. 5, a current DoC, approved adapter information and current manuals.

R100

Production model, CE mark, rating label, packaging and document reference match the approved files in the inspected samples.

R110

The product says R110.

The supplied DoC lists R100 and R120.

R110 does not appear in the supplied declaration or model list.

Report:

R110 was not found in the DoC supplied for comparison.

The document coverage needs review.

R120

The label matches the approved artwork.

The approved charger is C12-2A.

Production uses C12-3A.

The output rating is also different.

Record:

  • charger model

  • rating

  • product model

  • approved reference

  • photos

The technical team can then decide whether the existing evidence covers C12-3A.

Finally

Before shipment, the buyer should know four things: which SKU was checked, what approved reference was used, how many sampled units were affected, and whether the problem is a label error, document mismatch or technical product change. Under the UTS sampling example, a 4,000-unit lot at General Inspection Level II uses a 200-unit sample, but different voltage, plug, label and market versions still need suitable coverage. Incorrect labels can be reworked and checked again. A DoC mismatch or changed adapter, battery, PCB or wireless module should stay open until the responsible technical team confirms that the production version is covered.

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