The importer is the gatekeeper. Art. 19(2) lists five mandatory checks before market placement: (a) conformity assessment per Art. 32 completed, (b) technical documentation per Art. 31 drawn up, (c) CE marking per Art. 30 affixed, (d) user information per Annex II and Art. 13(19)–(20) accompanies the product, (e) manufacturer identification and contact per Art. 13(15)–(16) present. If any check fails, Art. 19(3) prohibits market placement until the issue is resolved. Art. 19(9) adds that if you rebrand the product or make substantial modifications, you become the manufacturer under Art. 13 with full manufacturer obligations. CRACheck generates the documentation that either verifies the manufacturer's compliance or — if you are the de facto manufacturer — fulfils the manufacturer obligations directly. 15–25 minutes. €149.
€149 one-time · 8-document ZIP · 15–25 minutes · Browser-side
Art. 19(2) is not optional. Placing a product on the EU market without verifying the five checks exposes the importer to Art. 64(3) penalties — up to €10M or 2% of worldwide annual turnover. "The manufacturer told me they're compliant" is not verification.
Art. 19(9) is explicit: "An importer or distributor that places a product with digital elements on the market under its own name or trademark... shall be considered a manufacturer for the purposes of this Regulation and shall be subject to the obligations of the manufacturer under Article 13." Rebranding triggers full Art. 13 obligations including risk assessment, technical documentation, and vulnerability handling.
Art. 19(6) requires importers to keep a copy of the EU declaration of conformity for at least 10 years or the support period (whichever is longer). If a market surveillance authority requests it and the importer cannot produce it, the importer is in violation regardless of whether the manufacturer still has a copy.
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. The classification determines which conformity assessment module the manufacturer must have used — and which the importer must verify.
Annex VII. If you are a pure importer, this documents your verification of the manufacturer's file. If Art. 19(9) applies (rebranding/modification), this is your own full Annex VII file.
Per Art. 13(2)–(3). Required only if Art. 19(9) applies. Pure importers verify the manufacturer's assessment exists.
Per Annex II. Art. 19(2)(d) requires importers to verify this accompanies the product. Art. 19(5) requires importers to ensure storage and transport conditions do not compromise compliance.
Per Art. 28 and Annex V. Art. 19(6) requires the importer to keep a copy for 10 years or the support period.
Per Annex I, Part II, point (5). Pure importers verify the manufacturer's CVD policy exists. Art. 19(9) importers must have their own.
Per Art. 14. Art. 19(7) requires importers who have reason to believe the product is not in conformity to inform the manufacturer and market surveillance authorities. Art. 14(2): early warning within 24h, notification within 72h, final report within 14 days.
Maps importer-specific deadlines: verification before placement, 10-year retention, Art. 19(7) notification triggers.
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 audit your import verification process, map Art. 19 obligations, determine if Art. 19(9) applies, and produce compliance documentation.
CRACheck generates the documentation for importers: the Product Classifier confirms the conformity assessment module the manufacturer must have used, the verification checklist maps the five Art. 19(2) checks, the Obligations Calendar tracks the 10-year retention period and notification triggers. If Art. 19(9) applies (rebranding or substantial modification), CRACheck generates the full manufacturer documentation package per Art. 13.
CRACheck does not audit the manufacturer's compliance. It does not inspect the manufacturer's production facilities. It does not verify the substance of the manufacturer's technical documentation. It does not assess whether a modification qualifies as "substantial" under Art. 19(9). You must perform the verification. CRACheck structures the documentation of that verification.
Verify the manufacturer's compliance. Document your verification. CRACheck structures both.
Art. 64(2).
Art. 64(3).
Art. 64(4).
| Criterion | No verification | Regulatory consultant | Manufacturer assurance letter | CRACheck |
|---|---|---|---|---|
| Art. 19(2) five-check structure | Non-compliant | Yes | Partial — no structure | Yes — all 5 checks |
| Art. 19(9) assessment | Unknown | Yes | Not addressed | Classifier determines |
| Time to documentation | — | 4–8 weeks | 1–2 weeks | 15–25 minutes |
| Cost | €0 (+ fine risk) | €8K–€18K | €1K–€3K | €149 one-time |
Each product requires its own verification documentation per Art. 19. Different manufacturers may have different compliance levels. Volume pricing: €99/product (10-pack) or €79/product (30-pack).
Request volume pricingCRACheck generates a structured documentation package for importers according to Article 19 of Regulation (EU) 2024/2847, based on the information you provide. The accuracy of your verification results and product data is your responsibility as importer.
We guarantee that the document structure follows Article 19 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 verification will be accepted by a market surveillance authority in a specific case.
CRACheck is not legal advice. For specific questions about importer liability, Art. 19(9) manufacturer reclassification, or market surveillance proceedings, consult with a qualified regulatory professional.