Chapter III, obligations of economic operators dealing with products
Article 9: Obligations of importers
Importers must verify the manufacturer's conformity work before placing a product, label themselves, keep the declaration for five years and act on non-conformity.
- Citation
- Article 9, CELEX 32019L0882 (Directive)
- Binds
- A Union-established importer that brings a product made outside the Union onto the Union market.
- 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
Paragraph 1 states the outcome: an importer brings only compliant products onto the market. Paragraph 2 sets the verification: before placing, the importer must ensure the Annex IV procedure has been carried out, the technical documentation exists, the product bears CE marking, the required documents accompany it, and the manufacturer has met the identification and contact duties in Article 7(5) and (6).
Paragraphs 3 and 4 deal with doubt and identity. If the importer suspects, or has grounds to suspect, that the product does not conform, it must hold it back until it is made compliant, and must tell the manufacturer and the surveillance authority. The importer's own name, trade mark and a contact address go on the product, or on the packaging or accompanying document where that is not possible.
Paragraphs 5 to 9 carry the rest: instructions and safety information in an understandable language; storage and transport conditions that preserve conformity; a copy of the declaration kept for five years with the technical file available on request; corrective action, withdrawal, notice to authorities and a non-conformity register; and cooperation with a reasoned authority request.
What to do
- Run a supplier verification checklist before the first shipment is placed.
- Check CE marking, the declaration, the technical file and the language of the instructions.
- Add the importer's name and a single contact address to the product or its documents.
- Keep a copy of the declaration for five years and make the file available on request.
- Control storage and transport so conformity is not lost.
Evidence to keep
- The completed supplier verification checklist per model and shipment.
- A copy of the EU declaration and evidence that the technical file can be produced.
- The importer identification on the product, packaging or document.
- The five-year retention index and the non-conformity register.
Dates
- 2025-06-28Applies to products placed on the market from this date. (Article 2(1))
Cross-references
Where teams get this wrong
An importer that receives a PDF declaration and no technical file has not verified anything. The article requires the file to exist and to be available to the authority for five years.
Read from the Official Journal text of Directive (EU) 2019/882, OJ L 151/70, 7 June 2019, Article 9. 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.