An email lands before the PO is confirmed: Please send the CE certificate and the FCC certificate for this model. You open your compliance folder and find a test report, a declaration of conformity, and sometimes an FCC ID on the label. There is no CE certificate. There is no FCC certificate either, not in the form the buyer imagines. The order is real, the deadline is real, and the three common responses - relabelling the report, buying a certificate, or refusing outright - all damage the deal more than the paperwork ever would.
Requests like this are weekly routine in export sales. The buyer is rarely wrong on purpose; they are repeating a line from their own compliance checklist, a customs broker, or a marketplace requirement they only half understood. The job is to translate the request into the documents that actually exist, send those, and close the one real gap if there is one. Every such request falls into one of three situations.
First, work out which of the three situations you are in
| What the buyer asked for | What they usually mean | What actually satisfies it |
|---|---|---|
| "CE certificate" | Proof of EU compliance | Test report(s) + Declaration of Conformity signed by the manufacturer; a notified body EU-type examination certificate only where the radio route requires one |
| "FCC certificate" | Proof of US compliance | FCC ID + grant of equipment authorisation (radio), or test report + SDoC statement (most non-radio electronics) |
| "RoHS certificate" | Proof of substance compliance | Test reports to the EN IEC 62321 series + DoC referencing Directive 2011/65/EU |
| "ISO certificate" | Supplier vetting | The factory's ISO 9001 certificate - it exists, but says nothing about the product's compliance |
| "Certificate of Conformity" | Market-specific approval | Depends on the programme: real and required in some (for example Saudi SABER), not something a laboratory adds to an EU file |
Most impossible requests are situation one: the buyer used a shorthand for prove this product is compliant. Fewer are situation two, where the document exists but for a different product or a different company. Only a minority are situation three, where the request is legitimate and the missing document is a real gap.
Situation 1: the document does not exist for anyone
CE. For ordinary electronics there is no certificate called CE. The manufacturer affixes CE marking under Regulation (EC) No 765/2008, and the content of the Declaration of Conformity is defined by the applicable directive - Annex IV of the EMC Directive 2014/30/EU, Annex IV of the Low Voltage Directive 2014/35/EU, Annex VI of the Radio Equipment Directive 2014/53/EU. The DoC is signed by the manufacturer or its authorised representative; no laboratory issues it. The only CE-adjacent certificate is an EU-type examination certificate from a notified body, and that exists only where the applicable route requires notified body involvement - see when a product actually needs a notified body.
FCC. Radio equipment approved under the Certification procedure gets a grant of equipment authorisation, issued through a Telecommunication Certification Body and searchable by FCC ID. That grant is the closest thing to a certificate, and it belongs to the grantee. Equipment approved under the Supplier's Declaration of Conformity procedure (47 CFR 2.906) - most non-radio digital electronics - has no certificate at all: no filing with the FCC, no number, nothing to send except the test report and the SDoC compliance statement. If you need the vocabulary sorted out first, start with the difference between a test report, a certificate and a declaration.
RoHS. No certificate here either. Compliance is demonstrated with test reports to the EN IEC 62321 series for the restricted substances and a DoC referencing Directive 2011/65/EU, with the technical documentation assembled as described in EN IEC 63000:2018. A one-page RoHS certificate from a document broker proves nothing that the report does not already prove better.
The reply that works in situation one is short: name the legal instrument, attach the real documents, and let the buyer's compliance person check them against whatever checklist they are working from. Most buyers accept this immediately once the substitution is explained in their own template's language.
Situation 2: the document exists, but not for your product
This is the trickier case, because the file the buyer wants does exist - it just does not cover what you are shipping.
- A notified body certificate for a sibling model. An EU-type examination certificate covers the type as examined. A variant with a different radio mode, antenna or firmware is not covered by goodwill; extending coverage follows the same logic as adding a model to an existing report.
- A CB Test Certificate. The IECEE CB Scheme issues a CB Test Certificate and CB Test Report against IEC standards, mainly product safety. It is not EMC, not radio approval, and not market access in itself - and it belongs to whoever applied for it.
- ISO 9001. It certifies a factory's quality management system at a specific site. It says nothing about whether the product meets CE or FCC requirements. Buyers sometimes request it as supplier vetting, which is legitimate - but it is not a substitute for product compliance files.
- A certificate naming your company. Certificates name the applicant. If you ship under your own brand with the factory's documents, the certificate will keep saying the factory's name. What you can produce is the full report, written authorisation to reference it, and a DoC in your own name.
Situation 3: the buyer is right, and the document is missing
Some requests that look excessive are genuine requirements. A Certificate of Conformity issued through an approved body is a real market-access document in several programmes - for many product categories imported into Saudi Arabia, a CoC issued through the SABER platform is mandatory, and no amount of EU paperwork replaces it. Where a radio product uses a proprietary protocol and the manufacturer has not applied, or has only partially applied, the harmonised standards, RED Article 17 routes the equipment through EU-type examination by a notified body - and a buyer asking for the NB certificate is simply better informed than you are. Medical devices and several national schemes (KC, giteki, BIS) similarly produce documents that exist for every compliant unit.
In situation three the honest answers are a scope and a date: what has to be tested, against which standard, and when the document can exist. What never helps is a broker offering a CE certificate in the same week. Fabricated certificates are a known problem for EU market surveillance, and a fake file turns a document gap into a fraud problem.
How to write the reply
A reply that survives the buyer's compliance department has four parts:
- Restate their requirement and name the real documents. The CE certificate for this product category does not exist; EU compliance is demonstrated by the attached test reports and the Declaration of Conformity signed by the manufacturer.
- Send the pack. The full report with annexes, plots and photographs, the DoC, and the FCC ID or grant where one exists - the files, not screenshots.
- Give one line of legal grounding. A QA person can only accept your substitute if they can justify it internally. Citing the directive annex that defines the DoC does that work for them.
- If there is a gap, name it with a date. Silence about the missing part is how a document question becomes a shipment held at customs.
When the request is hiding a real problem
Some of these requests deserve more than a polite reply, because the buyer has accidentally identified a genuine defect in your compliance file. Four patterns show up repeatedly:
- The adapter in the report is not the adapter in the box. Sourcing switched adapter suppliers to cut cost after testing, and the report still describes the old one. The buyer asking for documents for the shipped configuration is technically right, and the fix is a delta test on the new adapter, not a nicer PDF.
- The buyer's template cites a standard edition you did not test. Reports issued against EN 60950-1 or EN 60065 do not satisfy a file that expects EN 62368-1, the hazard-based safety standard that replaced both; that transition closed at the end of 2020. The report is old, not wrong - but it no longer matches the requirement.
- The buyer wants documents in their own name. That usually means they intend to act as the EU importer or the FCC responsible party, both of which carry obligations. The DoC has to be signed by whoever holds that role - a laboratory cannot sign it for them, and neither can you on their behalf. What you can give them is the report, access to the technical file and a support letter.
- Only one radio mode was declared. The report covers Wi-Fi; the buyer's checklist lists Bluetooth as well, because the product ships with it enabled. Adding a mode after the fact is a scope and permissive-change question, and it is much cheaper to answer before the shipment than after.
This is also where a laboratory earns its place in the process. We spend a fair share of our week reading buyers' document requests against the files that exist, telling manufacturers which of the three situations they are in, and closing the gaps that turn out to be real - a delta test on a changed adapter, a retest against the current standard edition, or an extra radio mode added to the scope. That review sits inside our testing and certification programme, and it regularly ends with the finding that you already have everything you need, which is the cheapest possible outcome.
The short answer
When a buyer asks for a certificate you cannot provide, first determine whether the document exists for anyone. For most consumer electronics there is no CE certificate: EU compliance is demonstrated by test reports plus a Declaration of Conformity signed by the manufacturer under the applicable directive (for example Annex VI of Directive 2014/53/EU), and most non-radio products entering the US have no FCC certificate either, because the SDoC route of 47 CFR 2.906 involves no filing with the FCC. Send the report, the DoC and the FCC ID where one exists, with one line of legal grounding so the buyer's QA team can file it. If the document does exist - a notified body EU-type examination certificate, a market-specific Certificate of Conformity such as Saudi SABER, or a report against the current edition of a standard - then the buyer has found a real gap, and the only fix that survives customs or a marketplace audit is testing, with a scope and a date. Never relabel a report, never buy a certificate, and never sign a DoC on behalf of a company that did not authorise you.
Send us the buyer's exact document request together with the compliance pack you currently hold - report, DoC, FCC ID or grant. We will tell you which of the three situations you are in, which substitute documents satisfy the request, and whether a real gap needs testing, with the scope and the standard named.