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- CE marking: dimensions, proportions and visual rules
CE marking: dimensions, proportions and visual rules
The graphic rules of the CE marking fit in three short points of Annex II to Regulation (EC) No 765/2008: the form of the letters, the duty to keep the proportions of the graduated drawing, and a 5 mm minimum height "where specific legislation does not impose specific dimensions". Everything else (where it goes, when it moves to the packaging, when a notified body number follows it, which waivers exist for small products) is spread across Decision No 768/2008/EC and the marking articles of each sector text, such as the LVD, the EMC Directive, the RED, the machinery, toy, PPE and medical device rules. This guide reads those texts article by article and separates what they require from what is commonly repeated about them.
Legal basis of the CE marking
Section titled “Legal basis of the CE marking”Regulation (EC) No 765/2008 (9 July 2008, applicable since 1 January 2010) holds the general principles in Article 30 and the form in Annex II. Its market surveillance chapters were repealed and replaced by Regulation (EU) 2019/1020, but the provisions on accreditation and on the CE marking remain applicable (Blue Guide 2022, section 1.2.2). Article 30 says, in summary:
- the CE marking is affixed only by the manufacturer or its authorised representative (30(1));
- it is affixed only to products for which Union harmonisation legislation provides for it, in the form of Annex II (30(2));
- by affixing it, the manufacturer takes responsibility for conformity with all applicable requirements (30(3));
- it is the only marking attesting conformity with that legislation (30(4));
- markings likely to mislead third parties about the meaning or form of the CE marking are prohibited, and any other marking is allowed only if the visibility, legibility and meaning of the CE marking are not impaired (30(5));
- Member States provide penalties, which may include criminal sanctions for serious infringements (30(6)).
Decision No 768/2008/EC is the model that the sector texts copy. In its Annex I, Article R11 sends the general principles back to Article 30 of the Regulation, and Article R12 sets the affixing rules (visibly, legibly, indelibly, on the product or data plate, before placing on the market, notified body number when the body is involved in production control). Article R34 lists "formal non-compliance", including a marking affixed in violation of R11 or R12, which the authority first asks the economic operator to correct before restricting, withdrawing or recalling the product. The modules in Annex II of the Decision say, module by module, who affixes the notified body number. The presumption of conformity is a separate rule (Article R8), not a function of the marking.
The sector texts each carry their own pair of articles, one on general principles (pointing to Article 30) and one on affixing. Most repeat R12 word for word, but several add their own height rule, packaging rule or notified body trigger. That is why the same product family can behave differently from one act to the next: see the table below.
What Annex II to Regulation 765/2008 actually says
Section titled “What Annex II to Regulation 765/2008 actually says”| Point | Text of Annex II | What it means in practice |
|---|---|---|
| 1 | "The CE marking shall consist of the initials 'CE' taking the following form" (followed by a graduated drawing) | The letters follow the drawing, not a typeface. Use the official artwork rather than typing "CE" in a font. |
| 2 | "If the CE marking is reduced or enlarged, the proportions given in the graduated drawing in paragraph 1 shall be respected." | Scaling is allowed in both directions; stretching or squeezing is not. |
| 3 | "Where specific legislation does not impose specific dimensions, the CE marking shall be at least 5 mm high." | 5 mm is the default. Any reduction below 5 mm must come from the sector text. |
The Blue Guide 2022 (section 4.5.1.4) adds three clarifications that the Regulation does not spell out. The marking "can take different forms (e.g. colour, solid/hollow) as long as it remains visible, legible and respects its proportions". Visibility means "easily accessible for all parties", so the back or underside of a product is acceptable. For products requiring assembly, the marking should remain visible after assembly but does not need to be visible after final installation and in normal use.
None of the texts fixes a colour, a contrast ratio, a stroke width, a letter spacing in millimetres or a position on a particular face. Those parameters follow from the drawing (spacing and stroke scale with the height) and from the general visibility and legibility duty.
Minimum height and small-product waivers, act by act
Section titled “Minimum height and small-product waivers, act by act”The 5 mm figure is a default, and the waiver for small products is not in Regulation 765/2008. It exists only where a sector text writes it. This table lists what each act says, from the text itself.
| Act | CE marking articles | Height rule in the act | Where the marking goes if not on the product | Extra affixing rule |
|---|---|---|---|---|
| Regulation 765/2008 | Art 30, Annex II | 5 mm unless specific legislation sets other dimensions | Not addressed (see R12) | Proportions of the drawing |
| Decision 768/2008 (model) | R11, R12 | Refers to 765/2008 | Packaging and accompanying documents, where not possible or not warranted | Notified body number when involved in production control |
| RED 2014/53/EU | Art 19, 20 | May be lower than 5 mm "on account of the nature of radio equipment", if visible and legible (Art 19(2)) | Product or data plate, unless not possible or not warranted | Also on the packaging, visibly and legibly (Art 20(1)); notified body number of the same height as the CE marking, only for Annex IV (Art 20(3)) |
| LVD 2014/35/EU | Art 16, 17 | No own rule: 5 mm | Packaging and accompanying documents | None |
| EMC 2014/30/EU | Art 16, 17 | No own rule: 5 mm | Packaging and accompanying documents | None |
| Machinery Directive 2006/42/EC | Art 16, Annex III | Components of substantially the same vertical dimension, not less than 5 mm; may be waived for small-scale machinery | Not addressed in Annex III | In the immediate vicinity of the manufacturer or authorised representative name, using the same technique; notified body number after full quality assurance |
| Machinery Regulation (EU) 2023/1230 (from 20 January 2027) | Art 23, 24 | No own rule: 5 mm under Annex II of 765/2008 | Packaging and accompanying documents | Notified body number for the procedures of Art 25(2)(a) to (c) and 25(3)(b) to (d) |
| Toys Directive 2009/48/EC | Art 16, 17 | No own rule | On the toy, an affixed label or the packaging; for small toys, a label or accompanying leaflet | On the packaging when not visible from outside it |
| Toys Regulation (EU) 2025/2509 (applies from 1 August 2030) | Art 17, 18 | No own rule | Packaging or accompanying documentation where size or nature of the toy does not allow it | On the packaging when not visible from outside it |
| PPE Regulation (EU) 2016/425 | Art 16, 17 | No own rule in the articles | Packaging and accompanying documents | Notified body number for category III PPE (Annex VII or VIII) |
| MDR (EU) 2017/745 | Art 20, Annex V | Not less than 5 mm; may be waived for small-scale devices | On the device or its sterile packaging, otherwise the packaging | Also in the instructions for use and on any sales packaging; number also in promotional material |
| ATEX 2014/34/EU | Art 15, 16 | No own rule | Packaging and accompanying documents | Followed by the specific marking of explosion protection and the group and category symbols |
| MID 2014/32/EU | Art 21, 22 | Metrology marking rectangle equal in height to the CE marking (Art 21(2)) | Accompanying documents and packaging | "M" plus last two digits of the year in a rectangle, immediately after the CE marking; number indelible or self destructive upon removal |
| Lifts 2014/33/EU | Art 18, 19 | No own rule | On each lift car and safety component, or a label inseparably attached to the safety component | Notified body number for the listed procedures |
The Blue Guide 2022 (footnote 236) lists the acts it considers to waive the minimum dimension for small devices or components: machinery, personal protective equipment, active implantable medical devices, medical devices, potentially explosive atmospheres, lifts (as regards small-scale machinery), in vitro diagnostic medical devices, radio equipment and marine equipment. For the acts reproduced in the table, the waiver is written in the RED, the Machinery Directive and the MDR; in the current PPE and ATEX articles, the reduction route is the general one of R12 (packaging and accompanying documents). Check the act that applies to your product rather than a general "small products" rule.
Position, visibility, legibility and indelibility
Section titled “Position, visibility, legibility and indelibility”Article R12(1) requires the marking to be affixed visibly, legibly and indelibly to the product or its data plate. The Blue Guide 2022 (section 4.5.1.4) gives the official reading of each word.
- Visible: easily accessible for all parties; the back or underside is acceptable. It does not have to be visible before opening the packaging, unless the sector text requires the marking on the packaging too.
- Legible: the 5 mm default "is required to ensure that it is legible". The texts set no contrast ratio; any colour or a hollow design is allowed if the result stays legible.
- Indelible: it "cannot be removed under normal circumstances without leaving noticeable traces"; the Blue Guide notes that some product standards provide for a rub test with water and petroleum spirits. The technological choice belongs to the manufacturer, and the marking does not have to form an integral part of the product.
Timing. The marking may in principle not be affixed until the conformity assessment is complete, usually at the end of production. Where it is stamped or cast, it can be applied earlier in production provided the conformity of the product is verified as part of the production process.
Packaging fallback. The Blue Guide gives two triggers for moving the marking off the product: affixing is impossible (its example: certain explosives) or not possible under reasonable technical or economic conditions, or the minimum dimensions or visibility, legibility and indelibility cannot be achieved. It then goes to the packaging, if any, and/or the accompanying documents. It "may neither be omitted nor be moved to the packaging or accompanying documents on purely aesthetic grounds".
Notified body identification number
Section titled “Notified body identification number”The Commission assigns each notified body a single identification number, even when the body is notified under several acts (Decision 768/2008, Article R23(1)), and publishes it in the NANDO list. Article R12(3) then says: "The CE marking shall be followed by the identification number of the notified body, where that body is involved in the production control phase." The number is affixed by the body itself or, under its instructions, by the manufacturer or authorised representative.
Which modules put a number after the CE marking
Section titled “Which modules put a number after the CE marking”From the module texts of Annex II to Decision 768/2008 and the reading in Blue Guide 2022, section 4.5.1.5:
| Module or combination | Body involved in production control? | Number after CE |
|---|---|---|
| A (internal production control) | No | No |
| A1, A2 with tests by an accredited in-house body | No notified body | No |
| A1, A2 with tests by a notified body | Yes | Yes |
| B + C | No (B is a design-phase examination) | No |
| B + C1 or C2 with an in-house accredited body | No notified body | No |
| B + C1 or C2 with a notified body | Yes | Yes, of the body that checks production |
| B + D, B + E, B + F | Yes | Yes, of the production body, not necessarily the one that issued the type certificate |
| D1, E1, F1, G, H, H1 | Yes | Yes |
Two consequences matter for electronics. Under the RED, the number follows the CE marking only where Annex IV (module H, full quality assurance) is applied; RED Annex III (modules B and C) leads to a CE marking with no number, even though a notified body issued the type examination certificate. Under the EMC Directive, the only notified body route is module B followed by module C (Annex III), so an EMC-only product never carries a number.
Where several acts apply and several notified bodies check production, several numbers follow the marking (Blue Guide 4.5.1.5). Conversely, a number next to the CE marking does not mean that a notified body intervened under every applicable act (Blue Guide footnote 238).
Format
Section titled “Format”The texts do not prescribe a separator, a space or a font for the number. The RED adds one dimensional rule: the number "shall have the same height as the CE marking" (Article 20(3)). The Blue Guide accepts that the CE marking and the number may be affixed separately, "as long as they remain combined", and even in a third country where the product is made.
The CE marking among other marks
Section titled “The CE marking among other marks”Article 30(5) of Regulation 765/2008 allows other markings as long as they do not mislead about the meaning or form of the CE marking and do not impair its visibility, legibility and meaning. The Blue Guide 2022 (section 4.5.1.7) adds that additional markings must fulfil a different function from the CE marking, and that Member States must not introduce national conformity markings with the same meaning.
Several acts require complementary markings that sit next to the CE marking without being part of it (Blue Guide section 4.5.2): the specific marking of explosion protection under ATEX, the supplementary metrology marking under the MID and the NAWI Directive, and the EU energy label. Decision 768/2008 (R12(2)) and several sector texts allow the CE marking to be followed by a pictogram indicating a special risk or use.
Marks from outside the EU, such as an FCC ID or UKCA, are "other markings" in this sense. No EU text fixes their order on a data plate; the only constraint is that they do not impair the CE marking or create confusion with it. Layout options for multi-market labels are covered in Multi-marking layouts.
Electronic display and online sales
Section titled “Electronic display and online sales”The Blue Guide 2022 is explicit: "electronic labelling only is not allowed" (section 4.5.1.4). Its footnote 237 records that an LCD display has been considered appropriate for certain products, such as lifts, provided visibility, legibility and indelibility are respected, "in particular, the word of 'indelibly' suggests that it must be a permanent indication that cannot disappear due to an electronic failure".
Recent texts digitise other documents, not the marking. Regulation (EU) 2023/1230 on machinery allows instructions for use and the EU declaration of conformity in digital format, while still requiring the CE marking on the machine (Article 24). The RED contains no screen-display option for the CE marking. For products sold online, the Blue Guide (section 4.5.1.4) says it is useful to show the CE marking and required warnings on the website before the purchase; this is a recommendation, not a substitute for the physical marking. The FCC and other non-EU e-label regimes are compared in E-label vs physical label.
The "China Export" mark
Section titled “The "China Export" mark”In 2007 a Member of the European Parliament asked about a "China Export" mark looking like the CE marking with the letters closer together (question P-5938/2007). In its answer of March 2008, the Commission said it was aware of the misconception attributing the meaning "Chinese export" to the CE marking, was not aware of the existence of a "China export mark", and considered that the mark referred to was the CE marking as foreseen in European legislation "without, however, respecting the dimensions and proportions prescribed therein".
The practical consequence is simple. A CE marking that does not follow the graduated drawing is a CE marking affixed in violation of Annex II, that is a formal non-compliance under the sector equivalent of Article R34 (for example LVD Article 22, EMC Article 40, RED Article 43). Calling it something else does not change the analysis.
Information that goes with the CE marking
Section titled “Information that goes with the CE marking”The CE marking is one item of the product marking. Decision 768/2008 requires other items whose placement rules differ:
- a type, batch or serial number or other identification element, on the product, or on the packaging or an accompanying document where size or nature does not allow it (R2(5));
- the manufacturer name, registered trade name or registered trade mark and a contact address, on the product or, where that is not possible, on the packaging or an accompanying document (R2(6));
- the same details for the importer (R4(3)).
The Blue Guide (section 4.2.2) notes that, unless the sector text says otherwise, the economic operator details need not be indelible, as opposed to the CE marking. Sector texts add their own items, such as the restriction-of-use indication of the EMC Directive (Article 18(2)) or the UDI and symbols of the MDR. See CE marking overview and CE technical file for the documents that support the marking.
Dated timeline of the texts
Section titled “Dated timeline of the texts”| Date | Event | Effect on the marking |
|---|---|---|
| 9 July 2008 | Regulation 765/2008 and Decision 768/2008 adopted | Article 30, Annex II and the R12 model |
| 1 January 2010 | Regulation 765/2008 applies | 5 mm default and proportions rule in force |
| 26 February 2014 | LVD, EMC, ATEX, lifts, MID, NAWI directives aligned on the Decision | Sector affixing articles copy R12 |
| 16 April 2014 | RED adopted | Height below 5 mm allowed, packaging marking, number height |
| 21 April 2018 | PPE Regulation 2016/425 applies | Number for category III PPE |
| 29 June 2022 | Blue Guide 2022 published (OJ C 247) | Official reading: colour and hollow allowed, no e-label only, no aesthetic move to packaging |
| 12 December 2025 | Toys Regulation 2025/2509 published | Toy affixing rules rewritten, applies from 1 August 2030 |
| 20 January 2027 | Machinery Regulation 2023/1230 applies (corrected date) | Annex III of the Directive, with its small-machinery waiver, disappears |
Claims the texts contradict
Section titled “Claims the texts contradict”| Common claim | What the texts say |
|---|---|
| "Annex II of Regulation 765/2008 allows the marking to be reduced for small products." (made by the earlier version of this page) | Annex II has three points and no small-product clause. Waivers sit in sector texts (RED Art 19(2), Machinery Directive Annex III, MDR Annex V). |
| "The CE graphic rules are in Annex I of Decision 768/2008, Article R12." | The form is in Annex II of Regulation 765/2008. Article R12 of the Decision (in its Annex I) covers affixing, not the drawing. |
| "Article R34 sets the role of the CE marking in the presumption of conformity." | R34 is formal non-compliance. Presumption of conformity is Article R8. |
| "No directive sets its own graphic rule." | The RED sets its own height rule and number height; the Machinery Directive and the MDR restate the drawing with their own waiver; the MID sizes the metrology marking on the CE marking. |
| "Under module B, the type examination body number follows the CE marking." | Blue Guide 4.5.1.5: a body involved only in module B does not put its number after the marking. B + C gives no number. |
| "The number must be four digits with exactly one space, CE-0344 is invalid." | No text prescribes separator, spacing or digit count. The RED requires the same height as the CE marking. |
| "E-labelling of the CE marking is permitted under the RED within four actions from the main menu." | The RED has no such provision. The Blue Guide says electronic labelling only is not allowed. |
| "Market surveillance uses a 4.5:1 contrast ratio." | No text sets a contrast ratio; the Blue Guide accepts any colour or a hollow design if legible. |
| "Regulation (EU) 765/2008." | It is Regulation (EC) No 765/2008, adopted before the Lisbon Treaty. |
| "The Machinery Regulation applies from 14 January 2027." | The corrigendum published in OJ L 169 of 4 July 2023 corrects Article 54 to 20 January 2027. |
Frequent pitfalls
Section titled “Frequent pitfalls”Typing "CE" in a font. The letters follow a graduated drawing, not a typeface. A font produces different curves and spacing, which is the kind of departure from the "dimensions and proportions" that the Commission identified in its 2008 answer. Use the official artwork and scale it without distortion.
Assuming a small-product waiver. Under the LVD and EMC Directive there is no height waiver: if 5 mm does not fit, the route is the packaging and accompanying documents under Article 17(1), not a smaller marking. Radio equipment, machinery under the Directive and medical devices have their own waivers.
Adding a number that should not be there. A number after a B + C marking (RED Annex III, EMC Annex III) wrongly tells the authority that a notified body checks production.
Moving the marking to the packaging for design reasons. The Blue Guide excludes purely aesthetic grounds.
Forgetting the packaging where it is required. RED Article 20(1) requires the marking on the packaging of radio equipment as well; toys and medical devices have their own packaging rules.
Key takeaways
Section titled “Key takeaways”- Form and proportions: Annex II of Regulation (EC) No 765/2008; colour and hollow designs are allowed if legible.
- 5 mm applies unless the sector text sets other dimensions; Annex II itself has no small-product waiver.
- Waivers below 5 mm are written in the RED, the Machinery Directive and the MDR; elsewhere the fallback is the packaging and accompanying documents.
- The notified body number follows the marking only when the body is involved in production control; module B alone never puts its number there.
- Electronic labelling only is not allowed; the marking must be permanent.
- Upcoming changes: the Machinery Regulation on 20 January 2027 and the Toys Regulation on 1 August 2030.
See also
Section titled “See also”- CE marking overview
- CE procedure
- CE technical file
- Multi-marking layouts
- Self-declaration vs notified body
- Choosing a notified body in NANDO
- Machinery Directive 2006/42 and Regulation 2023/1230
- Glossary
Sources & references
- Regulation (EC) No 765/2008, Article 30 (general principles of the CE marking) and Annex II (form, proportions, 5 mm), EUR-Lex eur-lex.europa.eu/eli/reg/2008/765/oj
- Decision No 768/2008/EC, Annex I Articles R11, R12, R23, R34 and Annex II (modules, notified body number), EUR-Lex eur-lex.europa.eu/eli/dec/2008/768/oj
- Blue Guide on the implementation of EU product rules 2022, section 4.5.1 (CE marking), European Commission, Official Journal C 247 eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52022XC0629(04)
- Directive 2014/53/EU (RED), Articles 19 and 20 (5 mm derogation, packaging, notified body number height), EUR-Lex eur-lex.europa.eu/eli/dir/2014/53/oj
- Directive 2014/35/EU (LVD), Articles 16 and 17, EUR-Lex eur-lex.europa.eu/eli/dir/2014/35/oj
- Directive 2014/30/EU (EMC), Articles 16 and 17, EUR-Lex eur-lex.europa.eu/eli/dir/2014/30/oj
- Directive 2006/42/EC (machinery), Article 16 and Annex III, EUR-Lex eur-lex.europa.eu/eli/dir/2006/42/oj
- Regulation (EU) 2023/1230 on machinery, Articles 23, 24 and 54, EUR-Lex eur-lex.europa.eu/eli/reg/2023/1230/oj
- Corrigendum to Regulation (EU) 2023/1230 (OJ L 169, 4.7.2023): application date 20 January 2027, EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1230R(01)
- Regulation (EU) 2017/745 (MDR), Article 20 and Annex V, EUR-Lex eur-lex.europa.eu/eli/reg/2017/745/oj
- Regulation (EU) 2016/425 (PPE), Articles 16 and 17, EUR-Lex eur-lex.europa.eu/eli/reg/2016/425/oj
- Directive 2009/48/EC (toys), Articles 16 and 17, EUR-Lex eur-lex.europa.eu/eli/dir/2009/48/oj
- Regulation (EU) 2025/2509 on the safety of toys, Articles 17, 18 and 59, EUR-Lex eur-lex.europa.eu/eli/reg/2025/2509/oj
- Directive 2014/34/EU (ATEX), Articles 15 and 16, EUR-Lex eur-lex.europa.eu/eli/dir/2014/34/oj
- Directive 2014/32/EU (MID), Articles 21 and 22 (supplementary metrology marking), EUR-Lex eur-lex.europa.eu/eli/dir/2014/32/oj
- Directive 2014/33/EU (lifts), Articles 18 and 19, EUR-Lex eur-lex.europa.eu/eli/dir/2014/33/oj
- Answer given on behalf of the Commission to written question P-5938/2007 (China Export mark), European Parliament www.europarl.europa.eu/doceo/document/P-6-2007-5938-ASW_EN.html
Frequently asked questions
- What is the minimum height of the CE marking?
- Annex II, point 3, of Regulation (EC) No 765/2008 sets 5 mm, but only "where specific legislation does not impose specific dimensions". Annex II itself contains no waiver for small products. A waiver comes from the sector text: Directive 2014/53/EU (RED) Article 19(2) allows less than 5 mm for radio equipment if the marking stays visible and legible, Directive 2006/42/EC Annex III waives it for small-scale machinery and Regulation (EU) 2017/745 Annex V for small-scale devices. Whatever the size, the proportions of the graduated drawing must be kept.
- Must the CE marking be affixed to the product itself?
- Yes, as a rule. Article R12(1) of Decision No 768/2008/EC, restated in each sector text, requires the marking on the product or its data plate. Only where that "is not possible or not warranted on account of the nature of the product" does it move to the packaging and the accompanying documents. The Blue Guide 2022 (section 4.5.1.4) adds that the marking may neither be omitted nor moved to the packaging on purely aesthetic grounds.
- When must the notified body number follow the CE marking?
- Only when a notified body is involved in the production control phase (Decision 768/2008, Article R12(3)). A body that only did the EU-type examination (module B) does not put its number after the CE marking, so module B followed by module C gives a CE marking with no number. Under the RED the number appears only when Annex IV (module H) is used, and it must have the same height as the CE marking. The texts do not prescribe a separator or spacing between "CE" and the number.
- What is the "China Export" mark?
- In its March 2008 answer to written question P-5938/2007, the Commission said it was not aware of any "China export mark" and considered that the mark in question was the CE marking affixed without respecting the prescribed dimensions and proportions. A CE marking that does not follow the graduated drawing of Annex II to Regulation 765/2008 is non-compliant, whatever its claimed meaning.
- Can the CE marking be shown only on a screen (e-labelling)?
- No. Section 4.5.1.4 of the Blue Guide 2022 states that "electronic labelling only is not allowed". A footnote notes that an LCD display has been considered appropriate for certain products such as lifts, provided the indication stays permanent and cannot disappear through an electronic failure. Digital instructions or a digital declaration of conformity, allowed by Regulation (EU) 2023/1230 on machinery, do not replace the physical CE marking.
- Can the CE marking be in any colour or hollow?
- Yes. The Blue Guide 2022 says the CE marking can take different forms, for example colour or solid/hollow, as long as it remains visible, legible and respects its proportions. Neither Regulation 765/2008 nor Decision 768/2008 sets a colour, a contrast ratio or a stroke width. What is fixed is the shape and the proportions of the graduated drawing.
- What does "indelible" mean for the CE marking?
- The Blue Guide 2022 explains that the marking must not be removable under normal circumstances without leaving noticeable traces, and notes that some product standards provide for a rub test with water and petroleum spirits. It is up to the manufacturer to choose a technique that achieves visibility, legibility and indelibility; the marking does not have to form an integral part of the product.
- Must the CE marking also appear on the packaging?
- Only where the sector text requires it. The Blue Guide 2022 says affixing to the packaging as well is only necessary when explicitly required. The RED (Article 20(1)) requires the marking on the packaging too, the toy rules require it on the packaging when the marking on the toy is not visible from outside, and the MDR (Article 20(3)) requires it in the instructions for use and on any sales packaging.