CE Compliance in Electronics Manufacturing:
Responsibilities in EMS and E²MS Services
Who Is Responsible for CE Marking in Electronics Manufacturing?
For many companies outsourcing the production of electronic assemblies, one crucial question arises:
Who is responsible for CE compliance and CE marking – the customer or the EMS provider?
The answer depends entirely on the type of service provided:
pure manufacturing (EMS) or engineering plus manufacturing (E²MS).
As an experienced provider of Electronic Manufacturing Services (EMS) and Electronic Engineering & Manufacturing Services (E²MS), we clearly outline how CE responsibilities are distributed under European law.
EMS: Pure Electronics Manufacturing without CE Manufacturer Responsibility
When we act as an EMS provider, producing electronic assemblies strictly according to customer specifications (“build-to-print”), the following applies:
Our customer remains the legal manufacturer who is responsible for
- CE Declaration of Conformity
- technical documentation
- risk assessment
- compliance with all relevant EU directives (e.g., EMC, Low Voltage, RED, RoHS)
- selection of standards and components
- design, functionality and safety of the product
Because the EMS provider has no influence on design or product safety, it cannot and must not issue a CE Declaration of Conformity.
We support our customers with:
- high-quality electronics production (SMT, THT, cable assembly, box build)
- process and quality documentation (AOI, ICT, functional testing)
- material compliance (RoHS, REACH, POP)
- traceability of components and batches
These documents contribute to the customer’s CE file —
but they do not replace the customer’s CE obligations.
Key principle:
EMS ≠ CE manufacturer
E²MS: Engineering + Manufacturing = Shared CE Responsibility
In E²MS projects, we provide not only manufacturing but also electronics design, software development, prototyping as well as qualification and test development.
Under these circumstances, the legal situation changes clearly:
We become a co-manufacturer
Any party involved in product design or development is legally responsible for:
- risk assessment
- selection and application of harmonized standards
- functional and electrical safety
- documentation and verification testing
- supporting or issuing the CE Declaration of Conformity
The division of responsibilities is defined transparently in a development agreement.
Your benefits as a customer in E²MS
- streamlined development and production processes
- one partner for design, industrialization and series manufacturing
- reduced compliance risks
- secure CE assessment across all project stages
Key principle:
E²MS = shared CE responsibility
Why Clear CE Responsibility Matters
CE marking is a legal requirement and confirms compliance with:
- product safety regulations
- EMC requirements
- electrical safety directives
- health and environmental protection standards
The entity acting as “manufacturer” under EU law assumes:
- product liability
- market surveillance obligations
- recall responsibility in case of defects
By clearly distinguishing between EMS and E²MS roles, we ensure legal compliance, process transparency and safe market access for our customers.
Your Advantage: Transparent Processes and Legally Secure CE Allocation
Whether you choose pure manufacturing or a full engineering & manufacturing solution, we provide:
- clear CE responsibility allocation
- comprehensive quality documentation
- certified production processes (ISO 9001)
- material compliance management (RoHS, REACH, POP)
- reliable and scalable series production
You always know exactly:
- which CE obligations rest with you
- which tasks we take over
- and how we support your compliance documentation
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We are looking forward to your visit and to your inquiry!
Contact us
We are looking forward to your visit and your inquiry!