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# EU Importer Duties for CE-Marked Products

EU importers have legally distinct obligations from manufacturers under CE marking law. Importing a non-compliant product — even unknowingly — can expose the importer to enforcement action. Knowing your duties before you sign a supply agreement protects both your business and your customers.

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## Core importer obligations

### Verify manufacturer compliance

Before placing a product on the EU market, importers must verify that the non-EU manufacturer has completed the conformity assessment, prepared the technical file, affixed the CE mark, and drawn up an EU Declaration of Conformity.

### Ensure CE mark and documentation are correct

The importer must check that the CE mark is correctly affixed, that the EU DoC exists and is correct in format, and that the product carries the required labelling including the manufacturer's name and address.

### Add own name and address to the product

EU importers must ensure their own name and address appears on the product or its packaging. This is a separate requirement from the manufacturer identification and must appear on every unit.

### Maintain copy of EU DoC for 10 years

Importers must keep a copy of the Declaration of Conformity for 10 years after the last unit is placed on the market and provide it to authorities on request.

### Carry out product sampling

Importers must investigate complaints and, where necessary, keep a register of non-conforming products and product recalls. They should carry out sample testing where there are concerns.

### Cooperate with market surveillance authorities

Importers must cooperate fully with national market surveillance authorities, provide all required documentation, participate in recall and withdrawal procedures, and ensure the manufacturer takes corrective action when required.

## When an importer must refuse to place a product on the market

*   The product does not carry a CE mark when one is required
*   The EU Declaration of Conformity does not exist, is incomplete, or was not drawn up for the applicable directives
*   The technical file cannot be provided by the manufacturer in a reasonable timeframe
*   The product presents an obvious safety risk visible upon inspection
*   The required labelling information (manufacturer name/address, serial number, etc.) is missing

## Frequently asked questions

### Can an EU importer sign the EU Declaration of Conformity?

No. The EU Declaration of Conformity must be drawn up and signed by the manufacturer or their authorised representative. An importer cannot sign a DoC on their own — their role is to verify the manufacturer has done so correctly, not to take over the manufacturer's CE marking obligations.

### What happens if I import a product that turns out to be non-compliant?

Importers can be held liable under EU market surveillance law if they placed a non-compliant product on the market and did not take reasonable steps to verify compliance. Penalties include fines, forced withdrawal, and prohibition from placing further products on the market. Importers who can demonstrate they exercised appropriate due diligence are in a stronger position than those with no compliance verification process.

### Does the importer need to keep the full technical file?

Importers must keep a copy of the EU DoC for 10 years. They do not need to hold the full technical file — but they must be able to ensure the technical file is provided to market surveillance authorities within the timeframe required (often 10 working days). This means having a clear agreement with the manufacturer about technical file access.

**Disclaimer:** Educational resource only. Not legal advice. Importer obligations vary by directive. Always verify your specific duties with a qualified legal or compliance professional before importing CE-marked products.

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