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Responsible Person requirement for CE-marked products

What is coming?

On July 16, 2021, a new EU Regulation on product safety (called the “Market Surveillance Regulation (EU) 2019/1020”) is coming into effect. This new regulation adds the requirement for CE-marked products to have someone present in the European Union acting as the point of contact for product compliance (a “Responsible Person”).

This page outlines what is changing and offers some guidance on what you can do to prepare for the changes. This material is for informational purposes only. It is not intended as legal advice. We encourage you to consult your legal counsel if you have questions about the laws and regulations concerning your products.

What does this mean for me?

If you sell CE-marked products that are manufactured outside of the EU, you will need to ensure that such products have a Responsible Person in the EU prior to July 16, 2021. After July 16, 2021, it will be illegal to sell CE-marked products in the EU without an EU Responsible Person.

Prior to July 16, 2021, you will need to ensure that your CE-marked products are labelled with the contact information of the Responsible Person. This labelling can be done on the product, its packaging, the parcel, or an accompanying document.

How will I know if I need an EU Responsible Person?

The first step is to confirm that your products are subject to CE-marking legislation. Common examples of products that are required to be CE-marked include toys, electronics, personal protective equipment, machinery, construction products, gas appliances, recreational and personal watercraft, pressure vessels, and measuring equipment.

We also have some additional guidance for CE-marking legislation here. If you are unsure if the products you sell are required to be CE-marked, we recommend that you reach out to your supplier/legal counsel to investigate further.

I am the brand owner of CE-marked products; what should I do next?

If you are the brand owner of CE-marked products, we recommend that you take the following steps:

  1. Verify compliance of your products: Ensure that your products satisfy all the relevant CE marking requirements (more information can be found here) and that the corresponding documents (Test reports and Declaration of Conformity) have been drawn up. The Responsible Person of your product is required to have access to the documents.
  2. Enrol in Amazon Brand Registry: We encourage you to register your brand in Amazon Brand Registry to take advantage of the tools we offer to brand owners. For more information about Amazon Brand Registry, including a list of frequently asked questions, visit our Brand Registry information page .
  3. Appoint an EU Responsible Person for your products: A brand owner has flexibility in who they can appoint as the Responsible Person. Some options you should consider:
    1. If you have a subsidiary in the EU or already have an EU importer, it may be possible to appoint them as the Responsible Person for your products.
    2. The testing laboratory or the certification company that you use for your products may be offering Responsible Person services.
    3. If you do not sell exclusively on Amazon, you may want to take advantage of the providers offered in Amazon’s Service Provider Network. Visit this help page to learn more about these options.
    4. If you sell exclusively on Amazon, we will contact you again in the future with more information about additional Responsible Person services.

I already have a Responsible Person for my brand/ASINs; do I need to let Amazon know?

Yes. Amazon needs to collect the contact information of the Responsible Person for non-EU brands/ASINs. We will communicate shortly on how to notify Amazon of your Responsible Person.

I don’t own a brand but I still sell CE-marked products; am I still impacted?

Yes. If you are a reseller of CE-marked products, we recommend talking with your upstream suppliers to confirm they are aware of the upcoming changes and to ensure they are taking appropriate actions to appoint a Responsible Person. You can also confirm with your manufacturer/supplier if options a. and b. from the list above may be applicable to them.

Other frequently asked questions

Who can be an EU Responsible Person?

An EU Responsible Person can be one of the following:

  • The manufacturer or brand, if established in the EU.
  • An importer established in the EU.
  • An authorised representative established in the EU, who is appointed in writing as the Responsible Person by the manufacturer or brand.
  • A fulfilment service provider established in the EU.

What does the Responsible Person have to do?

For products impacted by the new regulation, the Responsible Person is required to do the following:

  1. Collect the product’s EU Declaration of Conformity (or Declaration of Performance) and ensure that additional documents demonstrating EU conformity of the product can be made available from the brand owner upon request in a language understood by an authority;
  2. Inform authorities of any risk posed by the product; and
  3. Cooperate with market surveillance authorities, including ensuring that the brand owner takes necessary corrective actions to remedy any non-compliance of the product.

In addition, the contact information of the Responsible Person is required to be displayed on the product or on its packaging, the parcel, or an accompanying document.

Can Amazon act as the Responsible Person on my behalf?

If you are a brand owner based outside of the EU, Amazon will be contacting you again in the future to provide additional information on how Amazon can support your compliance with the Market Surveillance and Compliance of Products Regulation and the actions that you will need to take.

Where can I get more detailed information on the Market Surveillance and Compliance of Products Regulation?

The EU Regulation 2019/1020 on Market Surveillance and Compliance of Products, published on June 20, 2019, sets out a framework aimed at increasing accountability for product safety and technical compliance, as well as enforcement of technical compliance breaches.

We strongly encourage you to visit the European Commission’s website for more information on EU Regulation 2019/1020 on Market Surveillance and Compliance of Products:

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