Most Common Mistakes in the CE Technical File
One of the most critical stages for manufacturers seeking CE certification is the correct preparation of the technical file. The technical file is the core evidence proving that a product complies with EU legislation, and it is the first document inspected during market surveillance and audits.
However, many manufacturers unknowingly repeat the same mistakes when preparing their CE technical documentation. These errors can delay the CE marking process—or even render the CE mark completely invalid. In this article, we explain the most common mistakes in CE technical files and how to avoid costly compliance failures.
What Is a CE Technical File?
A CE technical file is the official documentation that proves a product:
- Is safe to use
- Has been tested
- Complies with applicable EU directives and regulations
During inspections, the technical file must:
- Be available immediately upon request
- Contain accurate and complete information
- Reflect the actual design and configuration of the product
An incomplete or incorrect technical file may result in the CE marking being declared invalid.
Most Common Mistakes in CE Technical Files
The following errors are frequently encountered by both manufacturers and importers and often lead to serious penalties.
1. Selecting the Wrong EU Directive or Regulation
Many manufacturers begin the CE process without clearly determining which EU legislation applies to their product.
- Evaluating electrical products only under the Low Voltage Directive (LVD) while ignoring EMC requirements
- Performing EN 71 toy tests but neglecting chemical compliance obligations
- Ignoring RED requirements for IoT and wireless devices
Wrong legislation leads to a wrong technical file and an invalid CE marking.
2. Missing or Invalid Test Reports
- Test reports not issued by accredited laboratories
- Testing performed according to incorrect standards
- Incomplete or poorly documented reports
- Outdated reports or reports mismatched with the product version
- Reports related to an old or modified design
A technical file without valid test reports invalidates the CE process immediately.
3. Missing Product Drawings and Technical Schematics
- Product dimensions and layouts
- Electrical circuit diagrams
- Bill of Materials (BOM)
- Material specifications
- Engineering and assembly drawings
Product drawings are among the first documents requested during inspections.
4. No Risk Assessment or an Incorrect One
- No risk assessment conducted
- Using non-standard or self-created methods instead of EN ISO 12100
- Listing only theoretical risks
- Ignoring foreseeable misuse scenarios
No risk assessment means no valid CE marking.
5. Incomplete or Non-Compliant User Manual
- Manual not provided in the correct language(s)
- Missing safety warnings
- Non-compliance with CE regulatory requirements
- Missing installation, maintenance, or disposal instructions
An incorrect user manual can invalidate CE conformity.
6. Incorrect or Missing Declaration of Conformity (DoC)
- Missing directive or regulation references
- Incomplete standard listings
- Incorrect manufacturer details
- Missing product model identification
- No authorized signature
If the Declaration of Conformity is incorrect, the CE marking is legally invalid.
7. Failure to Update the Technical File
- Component changes not documented
- Software updates without technical file revision
- New standards applied while old test reports remain
The CE technical file must always be kept up to date.
Consequences of an Incorrect Technical File
- CE marking declared invalid
- Product withdrawal from the market
- Customs detention
- Administrative fines
- Safety Gate (RAPEX) notifications
- Suspension from Amazon, Etsy, or eBay
- Severe brand reputation damage
How SERTIFIKE Supports CE Technical File Compliance
- Identifying missing or incorrect documentation
- Determining applicable directives, standards, and test requirements
- Reviewing technical files for regulatory compliance
Conclusion: The Technical File Is the Heart of CE Certification
The CE mark is not just a logo—it is a legal declaration backed by a complete and accurate technical file.
Correct technical file = Valid CE marking = Safe and compliant product.
