Yes. The responsible entity for CE is the "manufacturer" or "EU authorized representative," and the place of registration is irrelevant to compliance qualification—a Hong Kong company or an offshore company can both act as the manufacturer and sign the DoC. However, three points should be noted: ① Some EU member states require non-EU manufacturers to appoint an EU authorized representative (GPSR has made this obligatory); ② Platforms such as Amazon will verify whether the entity signing the DoC is consistent with the entity operating the store; ③ Some countries' COC (such as Saudi Arabia and Egypt) require a business license and manufacturer information, and offshore entities may need to provide additional explanations of the production relationship.
The most common pitfall is "the brand owner signs the DoC while the factory conducts testing." When the two entities are inconsistent, if selected for inspection, it is necessary to be able to prove the commissioned production relationship (OEM/ODM contract).