You source private-label electronics from China and sell them on Amazon EU under your own brand. Amazon suspends your listings: missing cybersecurity documentation under Directive 2014/53/EU. You call your Shenzhen supplier. They say CE marking is your problem. They are correct: Art. 14 makes you the manufacturer because you market under your brand. You need technical documentation under Art. 21, a declaration of conformity under Art. 18 and a simplified declaration under Art. 10(9). REDCheck generates all 5 documents. 30 minutes. €99 per product. Upload to Amazon Seller Central and reinstate your listings.
€99 one-time payment · 5 PDF documents in ZIP · 30 minutes · 100% in your browser
Art. 14 of Directive 2014/53/EU treats you as the manufacturer if you sell under your own brand.
You enter your product specifications. REDCheck structures the cybersecurity documentation requirement by requirement.
Art. 14 of Directive 2014/53/EU: 'An importer or distributor shall be considered a manufacturer for the purposes of this Directive where he places radio equipment on the market under his name or trade mark.' If the brand on the product is yours and not the factory's, you are the manufacturer under EU law. All obligations of Art. 10 — including technical documentation, conformity assessment and CE marking — are yours.
If the CE marking was applied by your Shenzhen supplier for EMC and safety under the supplier's own declaration, that declaration covers the supplier as manufacturer — not you. When you rebrand and sell under your own name, you need YOUR OWN declaration of conformity, including the cybersecurity requirements. The supplier's CE does not transfer to your brand.
Amazon EU accounts for significant revenue for many FBA sellers. More importantly, Amazon may flag your account globally for compliance issues. Reinstating later requires starting the compliance process from scratch — new documentation, new review, new approval timeline. It is faster and cheaper to comply now.
5 PDF documents per product.
Art. 1, Del. Reg. (EU) 2022/30 + Art. 3(3), Dir. 2014/53/EU.
Art. 21 + Annex V.
Arts. 3(3)(d) and (e).
Art. 18 + Annex VI.
Art. 10(9) + Annex VII.
Look before you buy — Download sample dossier (PDF, fictitious product)
Generated from your data, in your browser. No product data leaves your computer.
Art. 14 assigns every obligation of Art. 10 to whoever places the product on the EU market under their own brand. Technical documentation (Art. 10(3)), conformity assessment (Art. 10(3)), CE marking, post-market surveillance (Art. 10(5)). REDCheck generates the cybersecurity documentation.
If you sell under the factory's original brand (not your own), you are a distributor (Art. 13) or importer (Art. 12). Your obligations are lighter: verify documentation exists, not produce it. But you lose your brand identity and differentiation.
REDCheck solves the Art. 14 manufacturer obligation. €99 per product. Your brand stays. Your documentation is complete.
Art. 46 of Directive 2014/53/EU requires effective, proportionate and dissuasive penalties.
Amazon suspends listings for missing cybersecurity documentation without prior warning on repeat compliance failures. Reinstatement requires documentation upload + review (5–15 business days).
As the manufacturer, Art. 10(11) requires you to take corrective measures, withdraw or recall. Art. 46 penalties apply to YOU, not to your Shenzhen supplier.
Amazon.de is the largest EU Amazon marketplace. Produktsicherheitsgesetz applies to whoever places the product on the German market — that is you.
| Alternative | Cost | What you get |
|---|---|---|
| Hire a compliance consultant | $3,000–5,000/product | Weeks. You need it now. |
| Ask your Shenzhen supplier | Usually impossible | "CE is your responsibility." |
| Drop EU listings permanently | $0 in fees | $5,100+/month in lost revenue. Forever. |
| REDCheck | €99/product | 5 documents, 30 min, upload today |
6+ ASINs? The Professional Pack covers 70 generations for €999 — one key, all your products.
Request volume pricingREDCheck generates a document structured under Art. 21 and Annex V of Directive 2014/53/EU based on the information you enter. The truthfulness, accuracy and completeness of that information is your responsibility as manufacturer of the radio equipment.
We guarantee that the document structure follows Art. 21 and Annex V of Directive 2014/53/EU and that the legal references cited are correct as of the latest verification date. We do not guarantee that a specific document will be accepted by a market surveillance authority in a specific case, nor by a commercial buyer in a procurement process.
REDCheck is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.
Five PDF documents per product. Art. 21 and Annex V. Under YOUR name as manufacturer. Upload to Seller Central.