CE

What CE marking is, and what it is not

CE is not a certificate issued by an outside body. It is a declaration the manufacturer or the EU importer makes, backed by a technical file, stating that the product meets every EU directive and regulation that applies to it. Nobody “grants” you CE. That distinction matters commercially: a supplier who offers to “sell you a CE certificate” is describing something that does not exist in the way the phrase implies.

What does exist is a Declaration of Conformity — a signed document naming the product, the directives applied, the harmonised standards used, and the person legally responsible — plus the test reports that support it. That package is what a customs officer, a marketplace compliance team, or a distributor’s lawyer will ask to see.

Which directives apply to a battery pack

This is where buyers are most often misled, so it is worth being precise. The Low Voltage Directive (2014/35/EU) applies from 75V DC upward. An e-bike battery pack at 36V, 48V, or 52V nominal sits below that threshold, so LVD generally does not apply to the pack on its own. It does apply to the mains charger, which runs on 230V AC.

For the pack itself, the live obligations are typically the EMC Directive (2014/30/EU) where the pack contains active electronics such as a BMS with communication, RoHS as a precondition of CE marking, and since 2024 the EU Battery Regulation 2023/1542, which brings its own duties around carbon footprint declarations, due diligence, labelling, and end-of-life. The complete e-bike is a separate matter: it is CE-marked as a machine, normally against EN 15194 for EPACs.

The practical consequence is that “the battery is CE marked” and “the bike is CE marked” are two different claims covering two different scopes. Ask which one a supplier is making.

What we supply, and what stays your responsibility

We provide the pack-level Declaration of Conformity, the supporting EMC and safety test reports, the RoHS documentation, and the technical file content for the pack. Where you are the EU importer, the legal responsibility for the finished product placed on the EU market is yours — including registration duties under the Battery Regulation and WEEE, which we cannot discharge on your behalf.

Our EU importer checklist walks through the obligations that land on the importer rather than the factory. If you are evaluating paperwork from several suppliers, the guide to verifying battery certificates covers how to check that a document is genuine and that its scope actually covers the pack you are buying.