It is the manufacturer’s sole responsibility to draw up the technical documentation and accompanying declarations (for specific legislations, an Authorised Representative can be mandated to draw up some of the documentation). But this does not mean that other actors are free of obligations. A due diligence system is defined in many legislation under the “Obligations of Economic Operators,” where commonly, importers and distributors hold the responsibility to verify that the manufacturer has performed certain tasks. 

Importers must essentially verify that the manufacturer has completed every obligation to show compliance including verifying that the product has the technical documentation. 

Distributors hold a lesser degree of responsibility; they must only verify that all information that reaches the customer is in place. This includes accompanying documents, labelling, and, when applicable, that the product is CE marked.

No actors except the consumer/end-user (except ancillary actors, e.g. transport) are therefore allowed to “trust” or “assume” that the product is compliant. Therefore, they must take the same steps to ensure that the product they import or distribute comply.

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