What must an importer verify before placing a product on the EU market?

Article 19(2) of Regulation (EU) 2024/2847 requires importers to verify, before placing a product on the market, that: (a) the manufacturer has carried out the appropriate conformity assessment per Art. 32, (b) the manufacturer has drawn up the technical documentation per Art. 31, (c) the product bears the CE marking per Art. 30, (d) the product is accompanied by the user information per Annex II and Art. 13(19)–(20), and (e) the manufacturer has complied with Art. 13(15)–(16) on product identification and contact information.

Is the importer liable if the manufacturer's documentation is deficient?

Article 19(2) places a verification obligation on the importer. If the importer places a product on the market without verifying that the manufacturer's documentation exists and the CE marking is properly affixed, the importer is liable under Art. 64(3) for up to €10M or 2% of worldwide annual turnover. The importer does not need to audit the substance of the documentation, but must verify its existence.

When does an importer become a manufacturer under the CRA?

Article 19(9) of Regulation (EU) 2024/2847 states that an importer who places a product on the market under their own name or trademark, or who makes a substantial modification to a product already placed on the market, is considered a manufacturer under Art. 13 and bears all manufacturer obligations. Rebranding or significant firmware modification triggers this.

Must the importer keep documentation?

Yes. Article 19(6) requires importers to keep a copy of the EU declaration of conformity at the disposal of market surveillance authorities for at least 10 years after the product has been placed on the market or for the support period, whichever is longer. They must also ensure that the technical documentation can be made available to those authorities upon request.

Is this a subscription?

No. One-time payment. The licence includes a 30-day editing window and 10 regenerations. The downloaded PDF is yours permanently.

Can I request a refund?

Article 16(m) of Directive (EU) 2011/83 applies. Upon licence activation, you give express consent for immediate generation of the digital content, waiving the 14-day withdrawal right. Refunds are accepted only for a reproducible technical defect.

What if the regulation changes?

If the regulation is amended during your licence validity period, you can regenerate the documentation using the updated version of the generator at no additional cost.

You import products with digital elements into the EU. Article 19 of Regulation (EU) 2024/2847 requires you to verify — before placing the product on the market — that the manufacturer has completed the conformity assessment, drawn up the technical documentation, affixed the CE marking, and provided the user information per Annex II. Five verification checks. One documentation package. CRACheck generates it.

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.

Generate CRA dossier — €149 Free: check your product classification

€149 one-time · 8-document ZIP · 15–25 minutes · Browser-side

Importer obligations at a glance

Art. 19

Importer obligations under the CRA

5 checks

Mandatory verifications before market placement

10 years

Declaration retention — Art. 19(6)

What the importer must verify

Conformity assessment completed

Art. 19(2)(a): verify that the manufacturer has carried out the appropriate conformity assessment procedure per Art. 32. Request evidence — the declaration of conformity and, for Modules B+C or H, the notified body certificate.

Technical documentation exists

Art. 19(2)(b): verify that the manufacturer has drawn up the technical documentation per Art. 31 and Annex VII. You do not need to audit the content, but must confirm its existence and availability upon request.

CE marking affixed

Art. 19(2)(c): verify that the product bears the CE marking per Art. 30. Check that it is visible, legible, and indelible. For software-only products, check the digital documentation.

User information accompanies the product

Art. 19(2)(d): verify that the product is accompanied by the user information per Annex II and Art. 13(19)–(20), including the support period end date, security properties, and vulnerability reporting contact.

Manufacturer identification present

Art. 19(2)(e): verify that the manufacturer has complied with Art. 13(15)–(16) — product identification (type, batch, serial number or equivalent) and manufacturer contact information on the product or documentation.

Add importer identification

Art. 19(4): indicate your name, registered trade name or trademark, and postal address on the product or its documentation. Your contact must be accessible to market surveillance authorities.

Run CRACheck

If you are the de facto manufacturer (Art. 19(9) — rebranding or substantial modification), CRACheck generates the full 8-document manufacturer package. If you are a pure importer, CRACheck generates the verification checklist and obligations calendar.

Three mistakes importers make

❌

NO VERIFICATION

Importing without verifying that the manufacturer's documentation exists

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.

❌

REBRANDING TRAP

Rebranding a product without realising you become the manufacturer

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.

❌

NO RETENTION

Not keeping a copy of the declaration of conformity

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.

What the ZIP contains

8 PDF documents generated from your data. Each cites the specific article of Regulation (EU) 2024/2847 it complies with.

Product Classifier

Category per Annex III/IV. The classification determines which conformity assessment module the manufacturer must have used — and which the importer must verify.

Technical Documentation

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.

Risk Assessment

Per Art. 13(2)–(3). Required only if Art. 19(9) applies. Pure importers verify the manufacturer's assessment exists.

User Information

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.

Declaration of Conformity

Per Art. 28 and Annex V. Art. 19(6) requires the importer to keep a copy for 10 years or the support period.

CVD Policy

Per Annex I, Part II, point (5). Pure importers verify the manufacturer's CVD policy exists. Art. 19(9) importers must have their own.

Notification Template

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.

Obligations Calendar

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.

What you pay

🧾 THE ALTERNATIVE

Engaging a regulatory consultant to audit your import verification process, map Art. 19 obligations, determine if Art. 19(9) applies, and produce compliance documentation.

€8,000–€18,000

4–8 weeks. Per product line.

✓ Last regulatory check: 1 May 2026 · No substantive changes detected · View history