Distributors have lighter obligations than manufacturers and importers, but they are not exempt. Art. 20(1) requires verification of CE marking, manufacturer/importer identification, and user information. Art. 20(2) requires that storage and transport conditions do not compromise compliance. Art. 20(3) requires distributors to withhold products they believe are non-compliant and to inform the manufacturer and authorities if the product presents a significant cybersecurity risk. Art. 20(5) triggers full manufacturer obligations if you rebrand or substantially modify the product. CRACheck generates the documentation covering all distributor obligations — or, if Art. 20(5) applies, the full manufacturer package. 15–25 minutes. €149.
€149 one-time · 8-document ZIP · 15–25 minutes · Browser-side
Art. 20(1) is a mandatory pre-distribution check. A distributor who makes products available without verifying CE marking, manufacturer identification, or Annex II user information is liable under Art. 64(3). "We trusted the manufacturer" does not satisfy the verification requirement.
Art. 20(3) requires distributors to withhold non-compliant products and, if they present a significant cybersecurity risk, to inform the manufacturer and market surveillance authorities. Continuing to distribute after discovering non-compliance compounds the distributor's liability.
Art. 20(5) is clear: placing the product under your own name or trademark makes you the manufacturer under Art. 13. This applies even if you change nothing but the label. A distributor who rebrands without preparing Art. 13 documentation — risk assessment, Annex VII file, CVD policy — is a non-compliant manufacturer.
8 PDF documents generated from your data. Each cites the specific article of Regulation (EU) 2024/2847 it complies with.
Category per Annex III/IV. Confirms the product classification and the conformity assessment module the manufacturer should have used.
Annex VII. For pure distributors: documents the verification checklist. If Art. 20(5) applies: full Annex VII file as manufacturer.
Per Art. 13(2)–(3). Required only if Art. 20(5) applies. Pure distributors verify the manufacturer's compliance with Art. 13(1).
Per Annex II. Art. 20(1) requires distributors to verify this accompanies the product. Art. 20(2) requires storage conditions that do not compromise compliance.
Per Art. 28 and Annex V. Distributors verify the manufacturer's declaration exists.
Per Annex I, Part II, point (5). Required if Art. 20(5) applies. Pure distributors forward vulnerability reports to the manufacturer.
Per Art. 14. Art. 20(3) requires distributors to inform the manufacturer and authorities of non-compliance presenting significant cybersecurity risk. Art. 14(2): early warning within 24h, notification within 72h, final report within 14 days.
Maps distributor-specific deadlines: pre-distribution verification, Art. 20(3) notification triggers, Art. 20(4) cooperation with authorities.
See before you buy — Download sample dossier (PDF, fictional company) — Real structure, real articles, real format. Fictional data.
Generated from your data, in your browser. No data leaves your device.
Engaging a regulatory consultant to map your distributor obligations under Art. 20, assess whether Art. 20(5) applies, and produce due diligence documentation.
CRACheck generates the documentation for distributors: the Product Classifier confirms the product category, the verification checklist maps the three Art. 20(1) checks (CE marking, identification, user information), the Obligations Calendar tracks notification and cooperation obligations. If Art. 20(5) applies (rebranding or substantial modification), CRACheck generates the full 8-document manufacturer package per Art. 13.
CRACheck does not physically inspect your products. It does not verify CE marking on actual units. It does not audit your storage and transport conditions per Art. 20(2). It does not determine whether a modification is "substantial" under Art. 20(5). You must perform the due diligence. CRACheck structures the documentation of that due diligence.
Check the product. Document the check. CRACheck structures the documentation.
Art. 64(2).
Art. 64(3).
Art. 64(4).
| Criterion | No due diligence | Regulatory consultant | Manufacturer assurance | CRACheck |
|---|---|---|---|---|
| Art. 20(1) three-check structure | Non-compliant | Yes | Not structured | Yes — all 3 checks |
| Art. 20(5) assessment | Unknown | Yes | Not addressed | Classifier determines |
| Time to documentation | — | 3–6 weeks | 1–2 weeks | 15–25 minutes |
| Cost | €0 (+ fine risk) | €5K–€12K | €1K–€3K | €149 one-time |
Each product requires its own verification documentation per Art. 20. Different manufacturers have different compliance levels — your due diligence must cover each. Volume pricing: €99/product (10-pack) or €79/product (30-pack).
Request volume pricingCRACheck generates a structured documentation package for distributors according to Article 20 of Regulation (EU) 2024/2847, based on the information you provide. The accuracy of your verification results and product data is your responsibility as distributor.
We guarantee that the document structure follows Article 20 and, where applicable, Article 13 and Annex VII of Regulation (EU) 2024/2847 and that all legal references cited are correct. We do not guarantee that a specific due diligence process will be accepted by a market surveillance authority in a specific case.
CRACheck is not legal advice. For specific questions about distributor liability, Art. 20(5) manufacturer reclassification, or market surveillance proceedings, consult with a qualified regulatory professional.