EU Product Compliance for China Imports: CE, REACH, RoHS and GPSR in Plain Terms

When you import into the EU, you are the importer in law, and if your brand is on the product you are usually treated as its manufacturer. A Chinese supplier can help with tests and documents, but this does not remove your legal responsibilities as importer or manufacturer. This guide shows which rules apply to which products, what each one actually requires, and what to hold before the first shipment.

First: which rules apply to your product?

Product group	Main EU rules	CE marking?
Kitchenware, tableware, food storage	Food-contact framework Regulation (EC) 1935/2004; plastics Regulation (EU) 10/2011; the BPA ban in Regulation (EU) 2024/3190; national rules; GPSR; REACH	Food-contact status alone does not require CE. Use food-contact wording or the glass-and-fork symbol where the intended use is not obvious
Household, storage and cleaning goods without electrics	GPSR; REACH	No
Toys	Toy Safety Directive 2009/48/EC, being replaced by a new Toy Safety Regulation after a transition period; EN 71 standards; REACH	Yes
Electrical and electronic goods	RoHS Directive 2011/65/EU; Low Voltage Directive 2014/35/EU and EMC Directive 2014/30/EU where applicable; Radio Equipment Directive 2014/53/EU for radio equipment, including products with Bluetooth or Wi-Fi	Yes
Batteries, and products sold with them	Batteries Regulation (EU) 2023/1542	Yes. Additional battery labelling rules are phased in
Oven gloves for home use	Personal Protective Equipment Regulation (EU) 2016/425	Yes, a common surprise
Textiles such as aprons and tea towels	Textile Labelling Regulation (EU) 1007/2011 (fibre composition); REACH	No

CE marking: what it is, and what it isn't

• CE is the manufacturer's declaration that the product meets every piece of EU harmonisation legislation that applies to it, after the required conformity assessment. It belongs only on products covered by those laws. CE on a mug or a storage box is not just unnecessary; it's a false claim.
• For most consumer goods, CE is self-declared: a technical file, test reports (usually against harmonised EN standards) and an EU Declaration of Conformity signed by the manufacturer. A notified body is needed only in specific cases, such as some toys and higher-risk protective equipment.
• A "CE certificate" from a Chinese lab is not CE marking. It is usually a test report or a voluntary certificate. What you need is the Declaration of Conformity naming your product and model, the legislation and the standards applied, plus test reports that match the product.
• As importer you must check that the declaration and technical documentation exist, that the CE mark and labelling are on the product, put your own name and address on the product or its packaging, and keep the declaration for 10 years.

REACH: no certificate, but real limits

There is no such thing as a "REACH certificate". Under Regulation (EC) 1907/2006, two parts matter to importers of finished products:

1. Restrictions (Annex XVII): substances banned or limited in certain articles. Common ones for our categories: nickel release from items in prolonged skin contact (entry 27), azo dyes in textiles and leather (entry 43), PAHs in rubber or plastic parts that touch the skin (entry 50), the four main phthalates in plasticised materials (entry 51), and lead in articles children can put in their mouths (entry 63).
2. Substances of very high concern: if any component contains a Candidate List substance above 0.1% by weight, you must give your customers enough information for safe use, answer consumers within 45 days if they ask, and notify the product to ECHA's SCIP database.

Ask suppliers for material declarations per component and test reports for the restrictions that apply: PAH tests for rubber handles, phthalate tests for PVC, and so on.

RoHS: electrical and electronic equipment within scope

The RoHS Directive restricts ten substances in electrical and electronic equipment: lead, mercury, hexavalent chromium, PBB, PBDE and four phthalates (DEHP, BBP, DBP, DIBP) at 0.1% by weight, and cadmium at 0.01%, each measured in the homogeneous material. It covers LED lights, chargers, electric kitchen gadgets and toys with electronics, and it is part of their CE marking.

XRF screening at inspection catches metals such as lead and cadmium in solder, cables and plastics. It cannot detect phthalates, which need a lab test.

GPSR: general product safety

The General Product Safety Regulation (EU) 2023/988 has applied since 13 December 2024. It covers consumer products within its scope, including those without CE marking, and complements product-specific EU safety legislation. The following are core GPSR duties; their applicability depends on the product and the sector-specific rules:

• a safe product, backed by the manufacturer's risk analysis and technical documentation kept for 10 years;
• traceability on the product or packaging: a type, batch or serial number, the manufacturer's name with postal and electronic address, and an EU-based responsible economic operator;
• the same information in online listings;
• accidents reported to authorities through the EU's Safety Business Gateway.

If you sell under your own brand, you are the manufacturer under GPSR, even though a factory in China makes the product.

The compliance file to hold before the first shipment

• Product specification and bill of materials, with the material of every component
• List of the EU rules that apply
• Test reports that match the product, materials and model, recent, from an accredited lab
• EU Declaration of Conformity, signed (CE products only)
• GPSR risk assessment
• Label and packaging artwork showing the required information
• Instructions and warnings in the languages of each market
• Supplier declarations on REACH substances and, for electrical goods, RoHS
• A written commitment from the supplier to notify you before any material or component changes

What to ask your Chinese supplier

1. "Which EU rules has this product been tested against, by which lab, and for which model numbers? Please send the reports."
2. "Has any material or component changed since those tests?"
3. "Who is named as applicant and manufacturer on the reports?" They should match the company you buy from.

FAQ

Can I use the supplier's existing test reports? Sometimes, if they match your product exactly and are recent. For private label, retailers and marketplaces often want reports for your model.

Who pays for testing? It's negotiable. Agree it in writing before ordering.

Is this legal advice? No. It is a buyer's map of the rules. For borderline products, check with a test lab or a compliance specialist before you order.

We check documents and test reports against the product as part of supplier verification and quality control. For food-contact items, see what food-contact certification actually means.