{
  "type": "problem",
  "slug": "retailer-supplier-portal",
  "lang": "en",
  "url": "https://www.conphora.com/solutions/problem/retailer-supplier-portal/",
  "markdown": "https://www.conphora.com/solutions/problem/retailer-supplier-portal.md",
  "title": "A retailer's supplier portal asks questions we cannot answer",
  "description": "Onboarding portals ask for safety, traceability and substance data per product. How to tell legal data from the retailer's own fields and answer them.",
  "answer": "Retailers ask because the General Product Safety Regulation makes them verify the identifier, the manufacturer and importer details, and the instructions before they sell. Sort the questions into legal data you must hold, data your supplier holds, such as REACH substance information, and the retailer's own requirements. Answer from your product file, request the rest in writing, and never guess an answer.",
  "theme": {
    "id": "marketplace-retailer",
    "label": "Marketplace and retailer demands"
  },
  "roles": [
    {
      "id": "manufacturer",
      "label": "Manufacturer"
    },
    {
      "id": "importer",
      "label": "Importer"
    }
  ],
  "regulations": [
    "GPSR",
    "REACH"
  ],
  "path": [
    "product-validation",
    "documentation-generator",
    "compliance-status-links"
  ],
  "trigger": "A new retailer or a retailer's new system asks you to fill in a product data form before listing",
  "keep": null,
  "why": [
    {
      "text": "A retailer that buys and resells your product is a distributor, and the law gives it checks of its own. Under the General Product Safety Regulation (EU) 2023/988, a distributor verifies before making a product available that the manufacturer and, where applicable, the importer have put the product identifier, their name and addresses, and instructions and safety information in place (Article 12(1), referring to Articles 9(5) to (7) and 11(3) and (4)). Products placed on the market before 13 December 2024 in conformity with Directive 2001/95/EC may still be made available (Article 51); the Commission's guidelines add that the new traceability information requirements do not apply to them (Commission Notice C/2025/6233, section 2.1). Where it has reason to believe they have not, it must not make the product available until the product is brought into conformity (Article 12(3)). A supplier portal is how many retailers collect the facts for that check.",
      "sources": [
        1
      ]
    },
    {
      "text": "For products under a CE act, the GPSR's Chapter III, Section 1, which contains these articles, does not apply (Article 2(1), third subparagraph, point (b)), and the sector acts set similar distributor duties. The Commission's Blue Guide describes what a distributor must know with due care: which products need the CE marking, which documents must accompany them, and what the language rules are. It also says the distributor is not expected to be in possession of the technical documentation, but must be able to identify who supplied the product so that authorities can obtain it (section 3.4). Questions in a portal that go further than this are the retailer's own requirements.",
      "sources": [
        1,
        4
      ]
    },
    {
      "text": "Some data the law makes you pass on whether or not a portal asks. Under REACH, Regulation (EC) No 1907/2006, any supplier of an article containing a substance of very high concern identified on the candidate list in a concentration above 0.1 % weight by weight must provide the recipient with sufficient information for safe use, including at least the name of the substance (Article 33(1)). Consumers can ask for the same information and must receive it free of charge within 45 days (Article 33(2)).",
      "sources": [
        2
      ]
    },
    {
      "text": "Traceability is the other recurring theme. On request, every economic operator must identify who supplied it with the product, or with a part or component, and to whom it supplied the product (GPSR Article 15(3)), for six years (Article 15(5)). Authorities can require the same supply chain information directly (Regulation (EU) 2019/1020, Article 14(4)(b)). Answers given to a retailer should match what you would give an authority.",
      "sources": [
        1,
        3
      ]
    }
  ],
  "steps": [
    {
      "name": "Sort the questions into three piles",
      "text": "Pile one is data the law makes you hold: identifier, manufacturer, importer or responsible person, warnings, languages, the acts that apply. Pile two is data someone upstream holds, such as substance content or test results. Pile three is the retailer's own requirements, such as audits, certificates or policies, set by agreement."
    },
    {
      "name": "Answer pile one from the product file",
      "text": "Take the answers from the technical documentation and the label, not from memory. Where a field asks for a document the product does not have, for example a declaration of conformity for a product without a CE act, say so and explain why.",
      "item": "product-validation"
    },
    {
      "name": "Request pile two from your suppliers",
      "text": "Ask in writing for exactly what the portal needs, per product: substances of very high concern above 0.1 % by weight in the article, test reports naming the model, material data. Record the request and the answer."
    },
    {
      "name": "Answer what you know, and say what you do not",
      "text": "Where you cannot confirm a fact, answer that it is not known yet and when you expect it. A wrong yes in a portal can later make a product non-compliant in the retailer's eyes. Do not tick boxes to get through the form.",
      "item": "documentation-generator"
    },
    {
      "name": "Keep one master record and reuse it",
      "text": "Keep the answers per product in one place, with the source of each, and update them when the product or a supplier changes. Share the same verified record with every retailer rather than retyping it per portal.",
      "item": "compliance-status-links"
    }
  ],
  "documents": [
    {
      "name": "Product identification, manufacturer and importer details as on the label",
      "from": "The product and its technical documentation",
      "ground": "GPSR Articles 9(5)-(6) and 11(3)"
    },
    {
      "name": "Instructions and safety information in the languages of the countries of sale",
      "from": "The manufacturer",
      "ground": "GPSR Articles 9(7) and 11(4)"
    },
    {
      "name": "Information on substances of very high concern in the article",
      "from": "Your supplier, passed on by you",
      "ground": "REACH Article 33(1)"
    },
    {
      "name": "Supplier and customer records",
      "from": "Your purchase and sales systems",
      "ground": "GPSR Article 15(3) and (5)"
    }
  ],
  "risks": [
    {
      "title": "The retailer may not sell the product",
      "text": "A distributor that has reason to believe a product is not safe or not in conformity with the identifier, contact details or instructions rules must not make it available until it has been brought into conformity (GPSR Article 12(3)).",
      "source": 1
    },
    {
      "title": "Substance information you must give anyway",
      "text": "Any supplier of an article containing a substance of very high concern on the candidate list above 0.1 % weight by weight must give the recipient sufficient information for safe use, at least the substance name (REACH Article 33(1)).",
      "source": 2
    },
    {
      "title": "Authorities ask the same questions",
      "text": "Authorities can require supply chain information and documents on compliance from any economic operator (Regulation (EU) 2019/1020, Article 14(4)(a) and (b)); Member States set GPSR penalties (Article 44).",
      "source": 3
    }
  ],
  "faq": [
    {
      "q": "Must we answer every question in the portal?",
      "a": "No. The law sets a baseline: the product must be safe, identifiable, carry the right operator details and come with instructions. Fields beyond that are the retailer's own terms, set by agreement. Decline or qualify what you cannot verify."
    },
    {
      "q": "The portal asks for a REACH declaration. What is that?",
      "a": "There is no REACH certificate. REACH Article 33(1) requires you to tell the recipient of an article if it contains a candidate-list substance above 0.1 % by weight, with at least its name. A statement based on supplier data answers the question."
    },
    {
      "q": "They want the technical file. Must we hand it over?",
      "a": "The law keeps the technical documentation for authorities. The Blue Guide says a distributor is not expected to hold it, only to identify who supplied the product so authorities can obtain it. How much a retailer sees is set by agreement."
    },
    {
      "q": "Why does the retailer care about our importer details?",
      "a": "Because it must check them. Before making a product available, a distributor verifies that the manufacturer and the importer have put their details, the identifier and the instructions in place (GPSR Article 12(1))."
    }
  ],
  "sources": [
    {
      "title": "Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EC) No 1907/2006 (REACH), consolidated text of 22 June 2026",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02006R1907-20260622",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1020-20260812",
      "accessed": "2026-10-04"
    },
    {
      "title": "The 'Blue Guide' on the implementation of EU product rules 2022 (2022/C 247/01)",
      "publisher": "European Commission, via EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52022XC0629(04)",
      "accessed": "2026-10-04"
    }
  ],
  "related": [
    "retailer-proof",
    "reach-svhc-question",
    "supplier-material-data",
    "documents-scattered",
    "retailer-compliance-audit",
    "b2b-customer-questionnaire"
  ],
  "reviewer": "Conphora compliance team",
  "reviewedAt": "2026-10-05",
  "notice": "General information, not legal advice."
}