CE marking on Chinese machinery — what EU buyers must actually check

Ask a Chinese machinery supplier "is it CE certified?" and you will almost always hear "yes". Ask for the documents and you will usually receive a one-page "CE Certificate" in a gold frame, issued by a testing company you have never heard of. That document may be worth exactly the paper it is printed on — and if you import the machine on the strength of it, the legal problem is yours, not the factory's.

We sell Chinese aluminium-extrusion machinery to EU buyers, so we have no incentive to scare you away from importing. We do have an incentive to make sure your press is not stopped by customs or your labour inspectorate — because a blocked machine kills the deal for everyone. This article explains what CE actually is, how to verify what a supplier sends you, what changes under the Machinery Regulation (EU) 2023/1230, and what a realistic retrofit of a hydraulic extrusion press involves.

What CE marking legally is — and what it is not

CE marking is not a quality certificate and, for most machinery, it is not issued by anyone. It is the manufacturer's own declaration that the machine complies with all applicable EU legislation — for industrial machinery, primarily the Machinery Directive 2006/42/EC (until 19 January 2027) and, alongside it, the Low Voltage and EMC directives for the electrical equipment. The manufacturer performs a risk assessment, designs the machine to the essential health and safety requirements, compiles a technical file, draws up an EC Declaration of Conformity, and only then affixes the CE mark.

Three consequences follow, and each one matters when buying from China:

• A sticker proves nothing. The physical CE mark costs nothing to apply. Chinese factories routinely put it on machines that have never seen a risk assessment. (The popular story about a deliberate look-alike "China Export" logo is mostly myth — the real problem is simpler: a genuine-looking CE mark applied without any of the work behind it.)
• For most machinery, no third party is involved. The majority of machines are self-certified by the manufacturer under "internal production control". So a supplier can legitimately CE-mark a machine without any certificate from a lab — and conversely, a certificate from a lab does not make a non-compliant machine compliant.
• The paperwork is the product. What makes a machine legally saleable in the EU is the combination of: conformity with the essential requirements, a technical file, a Declaration of Conformity, instructions in the user's language, and the mark. Missing any element means the machine may not be placed on the EU market.

The typical "CE Certificate" from a Chinese supplier is a voluntary attestation from a commercial testing house — often issued after a document review, sometimes without anyone ever seeing the machine. It has no legal standing under the Machinery Directive. It is marketing.

Anatomy of a real EC Declaration of Conformity

The document you should demand is not a "certificate" but the EC (from 2027: EU) Declaration of Conformity — a document the manufacturer signs at their own legal risk. For machinery it must contain, at minimum:

Element	What to look for	Red flag
Manufacturer's name and full address	The actual factory, matching the sales contract	A trading company's office address, or no address
Person authorised to compile the technical file	Must be a named person established in the EU	Missing entirely — very common on Chinese DoCs
Machine identification	Type, function, model, serial number matching the nameplate	"Aluminium extrusion press" with no serial number
Legislation	Explicit sentence of conformity with 2006/42/EC (and LVD/EMC where applicable)	Only obsolete directives (98/37/EC), or none
Harmonised standards applied	For a hydraulic press expect e.g. EN ISO 12100, EN ISO 16092 series, EN 60204-1, EN ISO 13849-1	Generic "GB standards" or an empty list
Notified body details	Only if the machine actually requires one (see below)	A "notified body" that is not in NANDO
Place, date, signatory	Identified natural person with function, signing for the manufacturer	Unsigned, undated, or signed by the trader

Two of these rows do most of the filtering work. The EU-established person authorised to compile the technical file is required by the Machinery Directive and is almost never present on paperwork from factories that have not genuinely done EU conformity work. And the harmonised standards list tells you whether anyone engineered the machine to EU safety expectations: a press with no reference to EN ISO 13849-1 (safety-related control systems) has almost certainly not had its safety circuits designed to a required performance level.

Ask for the Declaration of Conformity before paying a deposit, machine-specific and serial-numbered, not a scanned template. A factory that has really done the work sends it in a day.

How to verify the certificate and the "notified body"

When a supplier does send a certificate, verify it in this order — it takes fifteen minutes:

1. Check the issuer in NANDO. The EU's NANDO database lists every notified body, with its four-digit identification number and the exact legislation it is notified for. If the issuer is not there, or is there but not for machinery, the certificate is a private opinion, not a conformity document.
2. Check the scope. Even genuine notified bodies issue voluntary certificates outside their notified scope. The document must say what it is: an EC type-examination certificate has a defined legal meaning; a "Certificate of Compliance" usually does not.
3. Check whether a notified body is even required. Here is a detail specific to our industry: Annex IV of the Machinery Directive (carried over into Annex I of the new Regulation) lists high-risk machinery where third-party involvement is mandatory — including presses for the cold working of metals with manual loading or unloading. An aluminium extrusion press works hot metal and is normally loaded automatically, so it typically falls outside that list and is self-certified. Consequence: a Chinese "CE certificate" for an extrusion press is neither required nor sufficient — what counts is the manufacturer's own declaration and the technical file behind it.
4. Ask for the technical file evidence. You will rarely get the full file (the manufacturer may keep it), but a serious supplier can show the risk assessment summary, electrical schematics to EN 60204-1 and the safety-circuit design. Silence here tells you everything.

Machinery Regulation (EU) 2023/1230 — what changes on 20 January 2027

The Machinery Directive is being replaced by the Machinery Regulation (EU) 2023/1230, which applies from 20 January 2027 — with no transition period for machinery placed on the market from that date. For anyone buying Chinese machinery, the most important change is that the Regulation spells out explicit obligations for importers — and the importer is whoever first places the third-country machine on the EU market. If you buy EXW or FOB from a Chinese factory and ship it to your plant, that importer is you.

Importer obligation under 2023/1230	What it means in practice
Verify the manufacturer carried out the conformity assessment	You must confirm the risk assessment, technical documentation and conformity procedure exist — "the factory said it's fine" is not verification
Verify CE marking, EU Declaration of Conformity and required documents accompany the machine	Missing DoC = you may not place the machine on the market
Ensure instructions are in a language easily understood by users	Polish plant, Polish instructions — machine translation of the Chinese manual will not survive an inspection
Put your own name, trade name, address and contact details on the machine or its documentation	The importer becomes traceable and accountable by name
Keep a copy of the EU Declaration of Conformity for 10 years, keep technical documentation available to authorities	You are the EU point of contact for market surveillance
Do not place non-compliant machinery on the market; inform the manufacturer and authorities of risks	If you know the guarding is missing, importing it is itself the infringement

Two more changes worth knowing. The Regulation allows digital instructions (with a free paper copy on request) — convenient for multi-machine lines. And it codifies the concept of substantial modification: whoever substantially modifies a machine already in service takes on manufacturer obligations for the modified machine. That matters for retrofits, as we will see below.

None of this makes importing Chinese machinery harder in engineering terms. It makes it harder to pretend — which, frankly, works in favour of buyers and honest suppliers.

Who carries the responsibility — four purchase setups

Setup	Who is the "importer"	Who answers for conformity
You buy directly from the Chinese factory (EXW/FOB)	You	You verify or commission the conformity work; your name goes on the paperwork; market surveillance calls you
You buy through an EU-established trader who imports and resells	The trader	The trader carries importer duties; you should still demand the DoC and instructions before acceptance
You buy through a supplier who does not clear customs in their own name	You	The supplier finds, verifies and negotiates; if clearance runs in your name, the importer obligations are yours — which is why we say so on every machine page instead of hiding it
You (or your integrator) substantially rebuild the machine after import	You, plus	Whoever performs the substantial modification assumes manufacturer obligations for the result

There is one more layer that surprises many buyers: even a fully CE-marked machine must satisfy the Work Equipment Directive 2009/104/EC as implemented in your country's labour law once it is put into service. Your labour inspectorate inspects the machine in your hall, not the paperwork in Foshan. This is also the legal hook through which a non-conforming machine already installed becomes the employer's problem — one more reason to settle conformity before shipment, not after.

And to kill a persistent myth while we are at it: the EU anti-dumping duties of roughly 22–32% apply to Chinese aluminium profiles, not to machinery. Machinery of this type typically enters the EU at 0–4.5% conventional duty plus VAT (deductible for VAT-registered businesses). The anti-dumping wall on profiles is precisely why producing profiles inside the EU on imported machinery makes economic sense.

What a hydraulic press retrofit actually involves

Chinese extrusion presses in factory standard are mechanically serious machines — forged cylinders, H13 tooling, Rexroth hydraulics, Siemens PLCs — but their safety engineering is built for the Chinese market, not for EN standards. A realistic EU conformity retrofit for a press like our 1000-tonne machine (EN page: 1000-tonne extrusion press) typically covers:

• Risk assessment to EN ISO 12100 — the document everything else hangs on;
• Guarding of the container, shear and runout zones: fixed guards to EN ISO 14120, safety distances to EN ISO 13857, interlocked access doors to EN ISO 14119;
• Safety-related controls: emergency stops to EN ISO 13850, safety circuits redesigned and validated to the required performance level under EN ISO 13849-1 — often the largest single work package, because it can mean a safety PLC and new wiring, not just extra buttons;
• Electrical conformity to EN 60204-1 (main disconnect, protective bonding, marking) and hydraulic system review against EN ISO 4413;
• Documentation: instructions in the user's language, updated schematics, the technical file, and the Declaration of Conformity signed by whoever takes manufacturer responsibility for the conformity work.

Indicatively, budget 5–15% of the machine price for a competent retrofit of a single press — for a 1000-tonne press in the €55–85k EXW class, think roughly €8–20k depending on how much of the safety design the factory implements before shipment versus what is done in Europe. These are estimates, not quotes: the honest number only exists after the risk assessment. The cheapest path is almost always to specify the EU safety package in the purchase contract — guards, safety circuits, documentation in English — so the factory builds it in and a European specialist verifies and completes it, rather than reconstructing safety around a finished machine.

Auxiliary machines are usually a much lighter case: a furnace or an anodising rectifier has a far shorter path to conformity than a 30-metre press line.

Our CE-status policy — three words, no promises

Every machine page on this site states one of three CE statuses, and we do not use a fourth:

• ce_certified — the manufacturer declares CE for this machine (true for a handful of auxiliary machines, e.g. the PA66 thermal break strip extruder). Even then, before any transaction we verify the certificate's scope and issuer against NANDO — a declared CE is a starting point for verification, not the end of it.
• retrofit_possible — the factory-standard machine does not meet EU requirements; conformity work is feasible and we quote it as a separate, visible line item. Most presses and furnaces are here.
• buyer_importer — you act as the importer and carry the obligations listed above; we support with documents and verification, but we will not pretend the responsibility sits elsewhere.

What we will never do is promise "we'll make it CE" as a done deal in a sales email. CE conformity is an engineering and documentation project with a named responsible party — anyone who offers it as a free checkbox is telling you they do not understand it, and their sticker will be your problem.

Checklist before you sign

1. Demand the machine-specific EU Declaration of Conformity draft before the deposit — check the seven elements in the table above.
2. Verify any certificate issuer in NANDO; check the scope and the document type.
3. Write the EU safety package and English documentation into the purchase contract, with acceptance at the FAT.
4. Decide who the importer is — and if it is you, plan for the 2023/1230 obligations from January 2027.
5. Budget the retrofit line honestly instead of discovering it at the labour inspection.

If you are pricing a press or a complete line and want the CE route mapped for your specific setup — direct import, retrofit scope, or a compliant contract structure — send us an inquiry. We will tell you which of the three statuses applies, what the conformity work costs, and where the risks genuinely sit. That is the whole point of publishing this instead of a gold-framed certificate.