Chapter III, obligations of economic operators dealing with products
Article 12: Identification of economic operators dealing with products
On request from a market surveillance authority, operators must identify who supplied them and whom they supplied, and keep that information for five years on each side.
- Citation
- Article 12, CELEX 32019L0882 (Directive)
- Binds
- Manufacturers, authorised representatives, importers and distributors.
- In the instrument
- Chapter III, obligations of economic operators dealing with products
- Applies from
- 28 June 2025 for products placed and services provided from that date (Article 31(2)). The Article 4(8) 112 duty may be deferred to 28 June 2027 where a member state uses Article 31(3).
- Source
- EUR-Lex, CELEX 32019L0882
What it requires
On request from a market surveillance authority, an operator covered by Articles 7 to 10 must identify the other economic operator that supplied it with a product and the other operator to which it supplied a product.
The information must be producible for five years after the operator was supplied and for five years after it supplied. That creates two clocks running in opposite directions along the chain. The Commission can extend the period for a specific product by delegated act, in proportion to the product's economically useful life, and any extended period must be longer than five years.
The article is a traceability duty, not a general data-retention licence. Keep the minimum needed to answer the question: who, which product or batch, and when.
In practice
Design the traceability log around the two questions an authority will ask: who supplied this unit, and who did you supply it to. A row needs the product or batch identifier, the counterparty, the role, the date and the document reference. Keep it for five years on both sides and test one retrieval before the first inspection.
What to do
- Keep a supplier and customer log with product or batch identifiers and dates.
- Run a five-year clock backwards from receipt and forwards from supply.
- Answer an authority request within its deadline from that log.
- Apply any longer delegated period for a named product where one is adopted.
Evidence to keep
- The traceability log with receipt and supply dates.
- The retention schedule showing both five-year clocks.
- The authority request and the extract supplied.
Dates
- 2025-06-28The identification duty applies to products in scope from this date. (Article 2(1), Article 12(2))
Cross-references
Where teams get this wrong
A single five-year archive keyed on invoice date does not answer the backward clock. The authority may ask who supplied you six years ago for a product you supplied last year.
Read from the Official Journal text of Directive (EU) 2019/882, OJ L 151/70, 7 June 2019, Article 12. Check it yourself: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019L0882. This page states the provision in our own words and is not legal advice; it does not certify any product or service.