Nobody in the company owns product compliance

EU product law does not address departments or job titles. Its duties fall on the economic operator: the manufacturer, the importer, the distributor. Under the General Product Safety Regulation (EU) 2023/988, the manufacturer carries out an internal risk analysis and draws up technical documentation before placing a product on the market, keeps it up to date and at the disposal of authorities for 10 years, and ensures that procedures are in place for products produced in series to remain in conformity (Article 9(2) to (4)). It provides channels for complaints, investigates them and keeps an internal register (Article 9(11) and (12)). An importer ensures before placing a product on the market that the manufacturer has met its documentation and marking duties (Article 11(1)).^[1]

The Regulation adds one organisational requirement: economic operators shall ensure that they have internal processes for product safety in place, allowing them to comply with the relevant requirements (Article 14). The Commission's guidelines give staff trained on product safety issues and knowledgeable on EU product safety legislation as an example (Commission Notice C/2025/6233, section 3.1.1). It does not say what the processes look like or who runs them. That is the company's decision, and a company in which nobody owns the question has not made it.^[1][5]

Several duties cannot wait for someone to feel responsible. Where a manufacturer considers or has reason to believe that a product is dangerous, it must immediately take corrective measures, inform consumers and inform the authorities (Article 9(8)). An accident caused by a product is notified without undue delay from the moment the manufacturer knows about it, and importers and distributors that learn of an accident inform the manufacturer without undue delay (Article 20(1) and (3)). On request, an economic operator identifies its suppliers and business customers, for six years (Article 15(3) and (5)). Each of these presupposes that information arriving in one part of the company reaches a person who can decide.^[1]

The duties do not shrink when one person does the work next to another job; the manufacturer and importer articles make no exception for small operators. They do give the work a structure. Some duties are gates: they must be met before a product is placed on the market, and an importer that has reason to believe they are not must not place the product (Article 11(2)). Some are clocks, such as immediate action on a dangerous product (Articles 9(8) and 11(8)) and accident notification (Article 20(1)). The rest is continuous: keeping the documentation up to date and series production in conformity (Article 9(4)), keeping the register. The amount of documentation is itself tied to risk: the file contains at least a general description of the product and its essential characteristics relevant for assessing its safety, and the analysis of the possible risks and solutions adopted, test reports and the standards applied are added where appropriate with regard to the possible risks (Article 9(2)), so a simple low-risk product needs a short file. The Commission must also adopt specific guidelines for economic operators, with particular regard to the needs of SMEs, including micro-enterprises, on how to fulfil the Regulation's obligations (Article 17(2)).^[1]

For products under a CE act, the GPSR chapter containing these organisational articles does not apply (Article 2(1), third subparagraph, point (b)); the sector acts set their own. Under the Low Voltage Directive 2014/35/EU, for example, manufacturers ensure that procedures are in place for series production to remain in conformity and adequately take into account changes in product design or characteristics and in the standards or specifications by reference to which conformity is declared (Article 6(4)). The Commission's Blue Guide states the principle behind all of it: the manufacturer has ultimate responsibility for the conformity of the product and may in no circumstances discharge itself from its responsibilities to an authorised representative, a distributor or a subcontractor (section 3.1). When authorities find a non-compliance, they require the relevant economic operator, the company, to act (Regulation (EU) 2019/1020, Article 16(2)).^[2][3][4]