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In order to be sold in the EU, several types of products require a "CE label" that certifies that the product meets certain standards and requirements. Question: If a product is being sold to DoD for use on a military base in the EU, does it need to meet the CE label requirement?

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My personal knowledge is 15 years out of date on this, so needs to be taken with a grain of salt. It will vary by country in theory and practice. Individual security agreements, treaties, and Status of Forces Agreements (SOFA) between the US and the host nation establish the theory and differ by country. In practice some European countries are more lenient in allowing the US to carry out its military mission and don’t insist on the letter of their law on US military installations. In general, US policy is to comply with local law to the extent feasible, but they reserve the right not to if military necessity dictates. Is the product for military use or for sale to customers in the BX?

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It would be helpful to know the actual, specific requirement and also to know what the CE Label is. Do do have any website cites that would answer those questions? Thanks.

If you are in US acquisition system, do you have access to the applicable SOFA or are you with industry, trying to sell the product to the US Military?

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Guest Vern Edwards

In order to be sold in the EU, several types of products require a "CE label" that certifies that the product meets certain standards and requirements. Question: If a product is being sold to DoD for use on a military base in the EU, does it need to meet the CE label requirement?

Tell us what research have you done about this? What have you read?

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Enough to learn that certain products are required to have the CE label and meet CE requirements if they are offered for sale in the EU. The question is whether those products need to meet the same requirements if they are sold only to the US military for use on a military base. (they are not for resale in a commissary or PX).

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Guest Vern Edwards

Fara Fasat:

Here is an answer: The EU CE directives apply only to products that are sold in the EU. Here is a list of the directives that require a CE mark:

List of European Union Directives that require the CE Mark.


  • 73/23/EEC - 2006/95/EC - Electrical Equipment designed for use within certain limits.
  • 87/404/EEC - Simple Pressure Vessels.
  • 88/378/EEC - Safety of Toys.
  • 89/106/EEC - Construction Products.
  • 89/336/EEC - 2004/108/EC - Electromagnetic compatibility.
  • 89/686/EEC - Personal Protective Equipment
  • 90/384/EEC - Non-automatic weighing instruments
  • 90/383/EEC - Active Implantable Medical Devices.
  • 90/396/EEC - Appliances Burning Gaseous Fuels.
  • 92/42/EC - New hot-water boilers fired with liquid or gaseous fuels.
  • 93/15/EEC - Explosives for civil use.
  • 93/42/EC - Medical Devices.
  • 94/9/EC - Equipment and protective systems intended for use in explosive atmospheres.
  • 94/25/EC - Recreational Craft.
  • 95/16/EC - Lifts.
  • 97/23/EC - Pressure Equipment
  • 98/37/EC - Machinery.
  • 98/79/EC - In Vitro diagnostic medical devices.
  • 1999/5/EC - Radio Equipment and telecommunications terminal equipment.
  • 2000/9/EC - Cableway Installations designed to carry persons.
  • 2004/22/EC - Measuring Instruments
  • 2004/108/EC - Replaces 89/336/EEC- July 2007 -
  • 2006/42/EC - Replaces 98/37/EEC - December 2009
  • 2006/95/EC - Replaces 73/23/EEC - January 2007

Those 21 directives do not apply if the product is not sold in the EU. Thus, if the U.S. military is buying a product sold only in the U.S., then there is no CE requirement, even if the product will be delivered to a U.S. base in the EU. If the product is sold in the EU, then it must have a CE mark if a CE directive requires it. That fact that it's sold to the U.S. military makes no difference as far as I was able to determine. See: Guide to the Implementation of Directives Based on the New Approach and the Global Approach (1999), published by the European Commission.

Products sold in the EU specifically for military or police purposes are generally exempt from CE requirements, but you have to check specific directives. See, for example, Directive 98/37/EC Machinery, which exempts "machinery specifically designed and constructed for military or police purposes." See also, Guide to Application of the Machinery Directive 2006/452/EC, 2d ed., June 2010, published by the European Commission.

Now, if you will think about our regulations, you should expect that European regulations and information about them are much too complicated for a simple answer like mine to be entirely reliable. So you should do some research. If the matter is crucially important to you, I suggest that you hire a qualified consultant.

I don't know how much research you did. You did not respond to my question by telling us what you have already read, so maybe you have already seen the documents that I have cited, in which case I have wasted my time trying to help you. That's my fault.

It took me about 40 minutes to research this answer and type it. If I had been willing to spend even an hour, I would have been able to tell you a lot more, because there are many more such documents.

To interns and trainees:

I was taught to do this kind of research by the people who trained me early in my contracting career. If I had gone to them with a question like the one asked here and had not done pretty thorough research beforehand, I would have been in serious trouble, as would anyone who worked for me and came to me with such a question before doing thorough research. I hope that you work for such people. Research is how you learn. The more research you do, the easier it gets and the more you'll know in the long run. The more you know, the more valuable and promotable you will be. A person who knows things or knows how to find things out can, in the long run, earn real money in this business. The rest of the people just don't get it, which is good news for the ambitious.

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Vern, the key is what does "sold in the EU" mean, since a US military base is in the EU. I believe you answered it with "Thus, if the U.S. military is buying a product sold only in the U.S., then there is no CE requirement, even if the product will be delivered to a U.S. base in the EU."

Thank you.

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If the buyer is in the EU, the sale is in the EU. It would seem that the buy would have to be made in the US, then shipped to the installation overseas.

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