We import and do not know what an importer must check

The importer is defined by what it does. Under the General Product Safety Regulation (EU) 2023/988, the importer is any natural or legal person established within the Union who places a product from a third country on the Union market (Article 3(10)); placing on the market is the first making available on the Union market (Article 3(7)). The Commission's Blue Guide describes the importer as not a simple re-seller: it has a key role in guaranteeing that imported products comply, and its obligations build on the manufacturer's.^[1][4]

For consumer products under the GPSR, Article 11 sets the list. Before placing a product on the market, the importer ensures that it meets the general safety requirement and that the manufacturer has drawn up the risk analysis and technical documentation and put the identifier and its contact details on the product (Article 11(1), referring to Article 9(2), (5) and (6)). It adds its own name and addresses without obscuring the manufacturer's label (Article 11(3)), ensures instructions and safety information in a language consumers easily understand as determined by the Member State (Article 11(4)), protects the product in storage and transport (Article 11(5)), keeps a copy of the technical documentation for 10 years (Article 11(6)), and investigates complaints and acts on dangerous products (Article 11(8) to (10)). Where a product is dangerous, the duty to inform the manufacturer and ensure the authorities are informed through the Safety Business Gateway applies already before placing (Article 11(2)).^[1]

For products subject to Union harmonisation legislation, the GPSR's Chapter III, Section 1 does not apply (Article 2(1), third subparagraph, point (b)), and the sector act sets the importer duties. Under the Low Voltage Directive 2014/35/EU, importers place only compliant equipment on the market; before doing so they ensure that the manufacturer carried out the conformity assessment, drew up the technical documentation and affixed the CE marking; they add their details, ensure the instructions, carry out sample testing where appropriate, keep the declaration for 10 years and provide documentation to the authorities in a language they easily understand (Article 8); where equipment presents a risk, they inform the manufacturer and the market surveillance authorities before placing it (Article 8(2)). The Blue Guide adds that a person who places second-hand products from a third country, or products not designed or manufactured for the Union market, must assume the role of the manufacturer (section 3.1). The GPSR's rule on online offers in Article 19 still applies to these products.^[1][2]

Both regimes require traceability: on request, importers name the operator that supplied them and those they supplied (GPSR Article 15(3); LVD Article 11). At the border, customs control products declared for release for free circulation and suspend the release where documentation, marking or the EU operator's details are missing (Regulation (EU) 2019/1020, Articles 25 and 26).^[1][2][3]