The CE marking: the last thing you affix, not the first
Articles 29 and 30 are two of the shortest in the regulation, and the easiest to get formally wrong. Where the marking goes for hardware and for software, what it may not accompany, and why it is the closing step of conformity rather than a design element.
The CE marking is the one CRA obligation everyone recognises on sight and almost nobody reads the rules for. Articles 29 and 30 take five minutes; the mistakes they prevent are the kind an authority spots from across the room, because the marking is the first thing an inspector looks at and the only part of your conformity work printed on the product itself.
What the marking is, legally
Article 29 ties the CRA's CE marking to the general principles of Article 30 of Regulation (EC) No 765/2008: one marking, the prescribed shape and proportions, affixed by the manufacturer as a declaration that the product complies with every EU rule that requires it — not just the CRA. It is not a quality label and it is not awarded by anyone. You affix it yourself, and by doing so you take responsibility for what it claims.
That is also why it comes last. The marking may only be affixed once the conformity assessment is complete and the EU declaration of conformity can honestly be signed. A CE mark on a prototype, a beta build or a product whose technical file still has open essential requirements is a false claim in the most literal sense.
Where it goes: hardware
Article 30 asks for the marking to be affixed visibly, legibly and indelibly to the product with digital elements. For most hardware that means the device itself or its data plate. Where the product's nature makes that impossible or unwarranted — the device is too small, or the surface cannot carry a durable marking — it moves to the packaging and the accompanying documentation.
- A thermostat, a router, an industrial controller: on the device or its data plate, and usually repeated on the box.
- A module sold to integrators: on the module where feasible, otherwise packaging and documentation — and say which in the technical file.
- Minimum size and proportions come from Regulation 765/2008 Annex II: the familiar grid, at least 5 mm tall unless a sectoral rule says otherwise, enlarged or reduced only in proportion.
Where it goes: software
A product made available in a form other than physical cannot carry a printed mark, and the regulation says what to do instead: affix the CE marking either to the EU declaration of conformity or to the website accompanying the product. In practice the defensible answer is both — the declaration carries it as a matter of course, and the product or download page shows it where a buyer actually looks.
The website option is the accompanying website — the page from which the product is obtained or documented — not a marketing page in general. A CE image in a footer sitewide, including on pages for products that have not been assessed, claims too much.
The notified body number
Where a notified body is involved in the production control phase, its four-digit identification number follows the CE marking, affixed by the body itself or, under its instructions, by the manufacturer. Module A self-assessment involves no notified body, so a default-category product's marking stands alone; a Class I product that went through Module B+C because no harmonised standard is available will usually carry a number. Getting this backwards — a number where none belongs, or none where one does — is a formal non-conformity an authority does not have to argue about.
What an assessor will expect
- A statement in the technical file of where the marking is affixed — device, data plate, packaging, declaration, website — and why, if it is not on the product itself.
- For software: the declaration of conformity carrying the marking, and the accompanying page showing it.
- The notified body number present or absent to match the conformity route actually used.
- Evidence that the marking was affixed after the assessment concluded, not before — release checklists and dated artwork are enough.
None of this is hard, which is exactly why it is worth doing precisely. A wrong CE marking is the cheapest possible finding for a market surveillance authority: no lab, no technical argument, just a photograph. Do not hand them one.