CE marking: dimensions, proportions and visual rules
Guide. CE marking, graphic rules
The graphic rules of the CE marking form one of the most standardised chapters of European product law, yet they remain one of the most frequently cited sources of non-conformity by market surveillance authorities and customs services. The exact shape of the letters, their height, their position on the product and their contrast with the substrate are not at the manufacturer's discretion: they are set by Annex II of Regulation (EU) 765/2008, reaffirmed by Annex I of Decision 768/2008, and reproduced without modification in every sectoral directive (LVD, EMC, RED, toys, machinery, PPE). This guide examines, rule by rule, what an authority can require and what it cannot.
Legal basis of the CE marking
Section titled “Legal basis of the CE marking”The legal framework of the CE marking rests on three main texts, which complement each other.
Regulation (EU) 765/2008 sets the general principles of the CE marking for the marketing of products. Its Article 30 defines the meaning of the CE marking and lays down the rules for affixing. Its Annex II contains the graphic template of the letters and imposes the minimum height of 5 mm.
Decision No 768/2008/EC complements the regulation by providing a common framework for the marketing of products. Its Annex I, Article R12, restates the affixing rules in similar terms, and its Article R34 clarifies the role of the CE marking in the presumption of conformity.
The sectoral directives (EMC 2014/30/EU, LVD 2014/35/EU, RED 2014/53/EU, toys 2009/48/EC, machinery 2006/42/EC, PPE 2016/425, etc.) reproduce the graphic rules by reference to Annex II of Regulation 765/2008. No directive sets its own graphic rule. Where a directive adds a specific mention (for example the Notified Body number or a protection class), it specifies the relative position of that mention with respect to the CE marking, not the shape of the marking itself.
Three practical consequences follow. First, the graphic rules are uniform across all directives: the same template applies to a medical electrical device, a radio equipment, a toy or a machine. Second, a national authority cannot impose a template different from that of Annex II. Third, a graphic non-conformity falls directly under Regulation 765/2008 and the corresponding sectoral directive, which opens the detention routes provided by Regulation (EU) 2019/1020.
The graphic template of the letters
Section titled “The graphic template of the letters”Annex II of Regulation 765/2008 provides the reference outline of the two glyphs "C" and "E". The CE marking is not a logotype composed in a generic font: each letter follows a precise template, based on a circular outline.
Geometric construction
Section titled “Geometric construction”The two letters "C" and "E" are each inscribed in a square grid of equal size. The height of the two glyphs is equal. The width of each letter is roughly equal to its height, producing an almost square character, far from the oblong proportions of a standard text font.
The letter "C" is drawn as an arc of a circle open to the right. The outer radius of the arc is equal to half the height of the letter. The inner radius is smaller. The opening of the arc covers about one quarter of the circumference. The stroke thickness remains constant along the entire curve, without serif.
The letter "E" uses the same circular construction for its main body. The middle horizontal bar is shorter than the upper and lower bars, which immediately distinguishes the glyph from an "E" in a generic font. The three horizontal bars are the same thickness as the curved stroke of the "C".
The spacing between the two letters equals roughly half the width of a letter. This spacing is one of the most frequently mistaken points when the marking is composed in a generic font: the default tracking produces a gap that is too narrow ("China Export" mark) or too wide (two separate letters).
ASCII representation of the template
Section titled “ASCII representation of the template”Annex II publishes a template drawn on a grid. An ASCII representation can convey the overall logic, without claiming pixel-accurate proportions.
.CCCCCC. EEEEEEEE CC C EE CC . EECC EEEEEECC EE CC . EE CC C EE .CCCCCC. EEEEEEEEThis representation shows: the "C" as an arc open to the right, the "E" as a glyph with three horizontal bars, the shorter middle bar, the identical height of the two letters, and the spacing between the two glyphs.
Preserving proportions when enlarging
Section titled “Preserving proportions when enlarging”Article 30(5) of Regulation 765/2008 allows the CE marking to be enlarged beyond the minimum dimension, provided that the proportions are preserved. Homothetic enlargement is admitted without an upper limit. Distortion by vertical or horizontal stretching is not. The same rule applies to reduction below 5 mm: it remains limited to products where the minimum dimension is not practicable.
Minimum dimension and derogation for small products
Section titled “Minimum dimension and derogation for small products”The minimum height of 5 mm is set in Annex II of Regulation 765/2008. This dimension corresponds to the vertical height measured on the "E" glyph, upper and lower bounds included. It can be measured with a caliper or by optical projection on the finished product.
Article 30(5) explicitly provides: "Save where otherwise specified in specific Community harmonisation legislation, the CE marking shall be constituted [.] with a minimum height of 5 mm. The dimensions of the CE marking may be reduced for small-scale products."
Typical cases for the derogation
Section titled “Typical cases for the derogation”Practice distinguishes several typical cases.
| Product type | Practicable minimum dimension | Decision |
|---|---|---|
| Enclosure larger than 30 mm on the rear face | 5 mm | Direct affixing at 5 mm |
| Enclosure between 10 and 30 mm | 3 to 5 mm depending on surface | Direct affixing, justified reduction |
| Component smaller than 10 mm | Reduction or affixing on packaging | See decision tree below |
| Expansion card, radio module | Depending on usable surface | Direct affixing if continuous surface |
| Equipment integrated into another product | On the documentation, by reference of the final product | Accompanying documentation |
Decision tree
Section titled “Decision tree”The decision tree for determining the marking carrier follows this logic.
Product to mark ? | v Usable surface allowing 5 mm ? / \ Yes No | | v v Direct Proportional reduction affixing at possible and legible ? 5 mm minimum / \ Yes No | | v v Direct Affixing on affixing packaging + accompanying at reduced documents height | v Justification in the technical fileThe final box "Justification in the technical file" is essential. Falling back to the packaging instead of the product is never discretionary: the technical justification must be retained and available for inspection by the market surveillance authority.
Position, visibility, contrast
Section titled “Position, visibility, contrast”Article 30(5) of Regulation 765/2008 sets three cumulative requirements for affixing: visible, legible, indelible.
Visibility
Section titled “Visibility”The marking must be visible on the product without disassembly or specific handling. Affixing inside a closed enclosure, under a tool-access cover, or on a face hidden during normal use does not meet the requirement. For a product intended to be installed against a wall, the front face or a side face accessible after installation must carry the marking. On a portable device, the rear face or the battery compartment are admitted, provided no non-standard tool is required to access the marking.
Legibility
Section titled “Legibility”Legibility requires sufficient contrast between the stroke of the marking and the colour of the substrate. A black marking on a black background, or grey on grey, does not meet the requirement. The rule does not set a numerical contrast ratio, but the practice of market surveillance authorities aligns with the empirical threshold of WCAG 2.1 (ratio 4.5:1 for body text), used here as a reference and not as a legal rule. No decoration, pattern or texture must overlay the marking to a point where its recognition is compromised.
Indelibility
Section titled “Indelibility”Indelibility is assessed over the expected lifetime of the product. The affixing process must withstand the intended use conditions: temperature, humidity, cleaning, handling, UV exposure, contact with standard solvents where the use case implies it. Sectoral directives do not set an indelibility test protocol, but the technical file must demonstrate the stability of the marking through tests or documented justifications of the chosen process.
Notified Body identification number
Section titled “Notified Body identification number”When a Notified Body is involved in the production control phase, its four-digit identification number is affixed immediately after the CE marking. The rule appears in Article 30(4) of Regulation 765/2008 and is restated in Article R12 of Decision 768/2008.
Form and position
Section titled “Form and position”The four-digit number follows the CE logotype without dash, without parenthesis, without separator, with a single space. Valid examples:
CE 0344CE 0123CE 2797Non-valid examples:
CE-0344 (dash not admitted)CE(0344) (parenthesis not admitted)CE0344 (missing space)CE 344 (the number must have four digits)The font of the number is not regulated. The height of the number must be legible at the same distance as the CE marking, which implies a height of the same order of magnitude, without a strict equality rule.
When is the number required?
Section titled “When is the number required?”| Procedure (module) | Notified Body number | Example |
|---|---|---|
| Module A (self-declaration) | No | CE only |
| Module A1, A2 (self-declaration with internal control) | No | CE only |
| Module B (EU type examination) | Yes | CE 0344 |
| Module D, E, F (production control) | Yes | CE 0344 |
| Module G (unit verification) | Yes | CE 0344 |
| Module H (full quality assurance) | Yes | CE 0344 |
When the procedure combines a module B (EU type examination) followed by a module C (conformity to type) without Notified Body involvement during production, the practice is to display the number corresponding to module B.
Layout: single marking and multiple marking
Section titled “Layout: single marking and multiple marking”The CE marking is rarely alone on a product intended for several markets. It frequently coexists with other regulatory markings (FCC, UKCA, ANATEL, EAC, KC, NCC, etc.), with voluntary certification marks (TUV, NF, GS, ENEC), and with technical mentions (power, voltage, protection class, IP rating).
Linear or two-line layout
Section titled “Linear or two-line layout”Regulation 765/2008 does not impose a single layout. The CE marking and the Notified Body number may appear on a single line (CE 0344) or on two lines, the number below the logotype. The condition is the preservation of proportions and legibility.
Sequence of multiple markings
Section titled “Sequence of multiple markings”A typical data plate for radio equipment placed on several markets carries the following sequence.
+------------------------------------+| Manufacturer name || Model: XYZ-100 || S/N: 25-04-0001234 || Power: 5 V, 1 A || || CE 0344 FCC ID: 2ABCD-XYZ100 || UKCA IC: 12345A-XYZ100 || ANATEL 04321-25-12345 || || Made in France || 2025 |+------------------------------------+The sequence is free, but practice favours grouping European regulatory markings (CE, UKCA) on one side, and identifier markings (FCC ID, IC, ANATEL) on the other. No third-party marking must visually replace or overlay the CE marking.
Voluntary marks
Section titled “Voluntary marks”Voluntary certification marks (TUV, NF, GS, ENEC, VDE) may appear next to the CE marking without position constraint, provided they cannot be confused with it and do not impair its legibility. These marks fall under private law and their own usage rules.
CE marking and the "China Export" mark
Section titled “CE marking and the "China Export" mark”A mark visually close to the CE marking has been circulating since the mid-2000s on products of Chinese origin. Its origin and status are ambiguous: some sources describe it as a "China Export" mark, others as a mere imitation devoid of official meaning. The European Commission, in a 2008 reply to a parliamentary question, indicated that no "China Export" marking was recognised in European law and that the use of this mark did not waive any conformity obligation.
Graphic differences
Section titled “Graphic differences”The so-called "China Export" mark has several stroke differences compared with the European CE marking.
| Characteristic | CE marking | "China Export" |
|---|---|---|
| Spacing between C and E | About half a letter width | Noticeably reduced, letters touching |
| Shape of the "C" | Open arc of a circle | More closed arc, reduced opening |
| Middle bar of the "E" | Shorter than the upper and lower bars | Bars sometimes equal |
| Overall proportions | Square letters inscribed in a grid | Letters sometimes more oblong |
Legal consequences
Section titled “Legal consequences”Affixing a "China Export" mark on a product intended for the European market does not count as CE marking. The product remains subject to all the obligations of the applicable sectoral directive. When a market surveillance authority identifies this mark in place of a compliant CE marking, the routes of Regulation 2019/1020 (detention, withdrawal, recall) are open. The mention "CE" in a commercial text without a compliant template falls under Directive 2005/29/EC on unfair commercial practices.
Affixing processes
Section titled “Affixing processes”The affixing process is not regulated as such: any process that meets the requirements of visibility, legibility and indelibility is admitted. The choice is a trade-off between cost, industrial constraints, substrate material and use environment.
| Process | Typical substrate | Durability | Indicative cost |
|---|---|---|---|
| Laser engraving | Metal, technical plastic | Very high | High setup, low per unit |
| Pad printing | Plastic, metal, ceramic | High | Moderate |
| Screen printing | Plastic, metal, glass | High | Moderate |
| Adhesive label (resin) | All substrates | Varies with adhesive | Low |
| Punch marking | Metal | Very high | Low per unit |
| Varnished paper label | Cardboard, low-stress plastic | Low | Very low |
| Riveted data plate | Industrial equipment | Very high | Moderate |
| E-labelling display | Equipment with built-in screen | Tied to screen lifetime | Low per unit |
The chosen process must be retained in the technical file, with justifications of its durability over time. See CE technical file for the expected structure.
Digital affixing, e-labelling
Section titled “Digital affixing, e-labelling”For products with a built-in screen and a user interface, displaying the CE marking and the regulatory information on screen is admitted subject to cumulative conditions. This practice, called e-labelling, is expressly framed for radio equipment (RED directive, 2022 amendment) and progressively recognised by other directives.
The substantive conditions are as follows:
- The display must be accessible to the user without a tool and within fewer than four actions from the main menu,
- The display must be permanent until user action, without inappropriate automatic clearing,
- The CE marking must be present on the packaging and in the documentation, even when e-labelling is used on the product,
- The translation of the information must be available in the official language or languages of the Member State of placing on the market.
E-labelling does not waive physical affixing on the packaging and the documentation. It only replaces affixing on the product itself, when that affixing is technically constrained.
CE marking versus product label
Section titled “CE marking versus product label”The CE marking is one element of the product label, but it is not synonymous with it. A complete product label contains, in addition to the CE marking:
- the manufacturer identification (company name and postal address),
- the importer identification when established in the Union and the manufacturer is not,
- the product identification (model, type, reference),
- the serial number or batch number,
- the main technical characteristics (voltage, current, power, insulation class, IP rating),
- the specific mentions imposed by the sectoral directive,
- the risk or handling pictograms where applicable.
See CE marking overview for the general framework and CE procedure for the assessment sequence.
Special case of medical devices
Section titled “Special case of medical devices”Regulation (EU) 2017/745 on medical devices (MDR) adds specific requirements beyond Regulation 765/2008: Unique Device Identifier (UDI), harmonised symbols ISO 15223-1 (manufacturing date, expiry date, storage conditions, sterilisation), processing and reprocessing mentions where relevant. The CE marking for medical devices follows the same graphic rules as for the other directives, but coexists with a much denser set of information.
Frequent pitfalls
Section titled “Frequent pitfalls”The main reasons for graphic non-conformity observed by market surveillance authorities and customs services fall into five categories.
Letters in a generic font. A "CE" composed in Arial, Times New Roman or any other text font produces a stroke that does not match the template of Annex II. The curves of the "C" are not circular, the thickness is not uniform, and the spacing between letters reflects the default tracking of the font. The width-to-height ratio of each letter departs from a square. Solution: use a vector template of the CE marking compliant with Annex II, available as an SVG or EPS file in the guides published by the European Commission or national authorities (DGCCRF in France, NANDO for the list of bodies).
Notified Body number missing or wrongly placed. When the conformity procedure involves a Notified Body in the production phase, the absence of the four-digit number after the CE marking is a direct non-conformity. Conversely, a number affixed when the chosen procedure does not require one (module A) is a non-conformity by excess. Solution: re-read the procedure followed, identify the modules actually applied, and display the number only when the module requires the intervention.
Marking on packaging only when the product could carry the marking. Falling back to the packaging is a derogation, not a default option. A product whose outer face offers a flat surface larger than 5 mm in height must carry the marking directly. Justifying the use of the packaging by an aesthetic preference is not sufficient. Solution: document the usable surface of the product and objectively justify the technical impossibility of direct affixing.
Insufficient contrast. A marking engraved in a material of the same shade as the substrate, or printed in a colour close to the background, is hard to read. The legibility rule is a substantive requirement, not a formal one. Solution: choose a process that produces durable contrast (laser engraving on anodised metal, white screen printing on a dark background, marking by subtraction of coloured material).
Marking that fades. A label that peels off after six months, ink that fades on cleaning, an engraving too shallow that wears down through use: each process must be chosen according to the use environment. Solution: integrate marking durability into the tests of the technical file, particularly for products exposed to harsh conditions (outdoor, humid environment, food contact, chemical cleaning).
Key takeaways
Section titled “Key takeaways”- The graphic rules of the CE marking are set by Annex II of Regulation (EU) 765/2008 and reaffirmed by Annex I of Decision 768/2008.
- The minimum height is 5 mm, measured on the letter "E". Reduction is admitted only for products where this height is not practicable.
- The two letters "C" and "E" follow a precise geometric outline, based on an arc of a circle, and cannot be composed in a generic text font.
- The four-digit number of the Notified Body follows the CE marking when the conformity procedure requires it, without dash or parenthesis.
- The marking must be visible, legible and indelible throughout the expected lifetime of the product.
- Affixing on the packaging and accompanying documents is a justified derogation, not a default option.
- Digital affixing (e-labelling) is admitted under strict conditions, for products fitted with a built-in screen.
- The so-called "China Export" mark has no legal value in Europe and does not waive any regulatory obligation.
For the full procedure and the place of the marking in the conformity sequence, see CE procedure and CE technical file. The Glossary covers the definitions of the terms used (Notified Body, module, presumption of conformity).
Sources & references
- Regulation (EC) No 765/2008 of the European Parliament and of the Council (Annex II: CE marking) , EUR-Lex eur-lex.europa.eu/eli/reg/2008/765/oj
- Decision No 768/2008/EC on a common framework for the marketing of products (Annex I: CE marking) , EUR-Lex eur-lex.europa.eu/eli/dec/2008/768/oj
- Blue Guide 2022 on the implementation of EU product rules , European Commission, Publications Office op.europa.eu/en/publication-detail/-/publication/06962183-c595-11ec-b6f4-01aa75ed71a1/language-en
- Directive 2014/53/EU (RED), Annex VI (control modules, CE marking) , EUR-Lex eur-lex.europa.eu/eli/dir/2014/53/oj
- Directive 2014/35/EU (LVD), Annex III (EU declaration of conformity and marking) , EUR-Lex eur-lex.europa.eu/eli/dir/2014/35/oj
- Directive 2014/30/EU (EMC), Annex I section 5 (CE marking) , EUR-Lex eur-lex.europa.eu/eli/dir/2014/30/oj