We onboard a new supplier and want the documents first

Onboarding is the cheapest moment to settle compliance, because the duties start before the first unit is sold. Under the General Product Safety Regulation (EU) 2023/988, the importer must ensure before placing a product on the market that it meets the general safety requirement and that the manufacturer has drawn up the internal risk analysis and technical documentation, marked the product with an identifier and given its name and addresses (Article 11(1)). The importer keeps a copy of that documentation for 10 years after placing the product (Article 11(6)).^[1]

The supplier's identity matters in two directions. The manufacturer's name, registered trade name or trade mark and postal and electronic address go on the product (Article 9(6)). And on request, every economic operator must identify who supplied it with the product, or with a part, component or software embedded in it, and must be able to present that information for six years after being supplied (Article 15(3) and (5)). The Commission's Blue Guide adds that an importer needs no mandate from the manufacturer, but must make sure that contact with the manufacturer can be established, for example to make the technical documentation available to an authority. It calls it good practice for importers to refer to the applicable EU legislation in the contract with the supplier and to secure access to the technical file, or the manufacturer's signed obligation to provide it (footnote 139).^[1][4]

For products under Union harmonisation legislation, the sector act sets the documents. For the acts listed in Article 4(5) of Regulation (EU) 2019/1020, such as the Low Voltage Directive, the economic operator responsible in the Union also verifies that the EU declaration of conformity and the technical documentation have been drawn up and that the documentation can be made available on request (Regulation (EU) 2019/1020, Article 4(3)(a)). Customs suspend the release of products that arrive without the documentation their Union law requires (Article 26(1)(a)).^[2]

A newer question concerns how products are made. Regulation (EU) 2024/3015 prohibits economic operators from placing or making available on the Union market, or exporting, products made with forced labour (Article 3), defined as products for which forced labour was used in whole or in part at any stage of extraction, harvest, production or manufacture (Article 2(7)). The regulation applies from 14 December 2027 (Article 39) and states that it creates no additional due diligence obligations beyond those in Union or national law (Article 1(3)).^[3]