Given the prevalence of fake certificates, verification is critical. Below is a step-by-step checklist based on industry best practices and compliance expert recommendations [2].
Step 1: Determine What You Need — Before requesting documents, assess which CE marking regulations and directives apply to the specific light tower model. For a typical LED light tower, this includes the Low Voltage Directive, EMC Directive, RoHS Directive, and potentially the Machinery Directive if the tower includes motorized mast elevation. Understanding the applicable directives helps you know what documentation to request.
Step 2: Request Complete Documentation — Don't accept a certificate image alone. Request the full Declaration of Conformity (DoC), product test reports from accredited laboratories (SGS, TÜV, Intertek, etc.), product and packaging label files, technical documentation summary, and user instructions. A legitimate supplier should provide all of these without hesitation.
Step 3: Declaration of Conformity Check — Verify the DoC contains: correct product name/model, product image matching the actual product, manufacturer name matching business registration, all applicable EU regulations and directives listed, all applicable standards listed with current versions, and notified body information if applicable. Missing or mismatched information is a red flag.
Step 4: Test Report Check — The Declaration of Conformity must be supported by test reports. Verify: test reports issued within the last 1-2 years, product name/model matching the DoC, manufacturer name matching, all applicable standards included and up-to-date, test reports issued by known testing companies (SGS, TÜV, Intertek, UL, etc.). Contact the testing company directly to verify the test report is authentic—fake test reports are not unheard of [2].
Step 5: Label Check — Obtain product and packaging label files to determine if the product is correctly labelled. Verify: product name/model correct, serial or batch number present, manufacturer name matching, manufacturer's address and contact point present, CE mark present with correct proportions and size, required warnings and safety information present, notified body number specified if applicable.
Step 6: EC-Type Examination Certificate — If the product requires Notified Body certification (certain high-risk machinery), verify the EC-type examination certificate. Check product name/model, manufacturer name, and certificate validity. Contact the issuing Notified Body to confirm the certificate is valid for the particular product you intend to procure.
Step 7: Other Files — Request technical documentation (though manufacturers may be reluctant to provide sensitive information), instructions for installation/maintenance/disposal, and any warnings required by applicable EU regulations. For lighting products, photobiological safety information (EN 62471) may be required.
"You cannot accept a printed CE mark at face value and plead ignorance in case of a recall. Importers are obliged to check the documentation that supports the CE mark. Test reports should be verified by contacting the issuing company—I would personally not trust test reports that cannot be verified by a third party." [2]