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SPEAC

Safe non-food consumer Products in the EU and China

Product Safety Checklist

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Introduction

This factsheet has been produced to assist all those in the chain of distribution satisfy themselves that all the key elements of the EU’s product safety system have been put in place. This use of the checklist will help ensure that no important elements are overlooked.

Using the Checklist

All products on the EU market must be safe. This is a shared responsibility for all actors involved in the distribution chain, but the manufacturer is the one who will have the biggest influence on the safety of a product. If the manufacturer gets it right from the beginning, then the other actors merely have to ensure that their activities don’t compromise the product safety.

If the manufacturer is located outside the EU, then the importer, the trader or the online seller are best suited for checking that the manufacturer fulfils his obligations. (The importer and the online seller are even obliged to do this.)

This checklist can facilitate such checks. It describes what an importer, a trader or an online seller should check when they trade a product. The list applies a two-layer approach whereby the business can start with some initial checks (the “first level test”). If the product passes these checks, it would normally be a good indication that the product is OK and that further investigation most likely will not uncover errors. If the checks give rise to suspicion, then the checklist includes a number of “second level tests” allowing a more thorough examination of the documentation and the product.

Please note that these investigations cannot replace the conformity assessment of the product that the manufacturer must undertake. The investigations can merely give an indication that the manufacturer has fulfilled his obligations correctly.

Checklist

Test object
First level test
Second level test
Remark

EU Declaration of Conformity (DoC)

  • Does it exist?
  • Check that it is a “Declaration of Conformity” and not a “Certificate of Conformity”.
  • Is it sent to the importer (or the authorised representative of the EU economic operator)?
  • Does the declaration show a picture of the right product?
  • Is it dated and signed?
  • Does the DoC contain all the required elements?
  • Is the manufacturer clearly identified?
  • Is the product clearly identified so it can be traced?
  • Is the actual version of the product mentioned on the DoC?
  • Does it list correct directives?
  • Does it list correct standards in valid versions?
  • The EU Declaration of Conformity is only required for products that require CE marking.
  • The SPEAC ACADEMY has several videos showing the required contents of the DoC.

Technical documentation

  • Does it exist? Ask for table of contents to check this.
  • Will the manufacturer keep it for 10 years?
  • How will he provide the file if an EU market surveillance authority asks for it?

Ask for copies of test reports and certificates:

  • Do they refer to the applicable directives in the correct versions?
  • Do they use the correct standards in valid versions?
  • Do the test reports cover the correct product?
  • Are the tests relevant?
  • Are certificates outdated?
  • Can you link the certificates to the test reports.
  • Can you find the certificates on the test laboratory’s website?

Traceability

  • Is it the same product that features in all papers in the technical documentation, in the Declaration of Conformity, on the marking plate, and as the product itself?
  • Do all papers mention exactly the correct model name and type name?

Marking

  • Is the product CE-marked?
  • Is it marked with brand name, type number and batch number?
  • Is the manufacturer identified on the product and can you see his contact address?
  • Is the importer identified on the product and can you see his contact address?
  • Is the authorised representative identified on the product and can you see his contact address?
  • Is the EU economic operator identified on the product and can you see his contact address?
  • CE only required for CE-marked products.
  • Authorised representative not required, but must be indicated if the manufacturer uses one.
  • Importer and EU economic operator only relevant in certain cases. Must be identified on product if the manufacturer uses any one of them.

User’s guide

  • Does it exist?
  • Does it come in the required languages?

Examination of product

  • Make a visual check to ensure that the product is 100% identical to the specifications.
  • Screen tests (indicative “desktop tests”).
  • Screen tests can be carried out if the tests and measurements are simple and can be carried out with ordinary (uncalibrated) tools.

Disclaimer

The provided information was updated in 2024. Please note that some of the provided information could change during possible subsequent revisions of legislation, standards, and guidance documents. For any updates of official information on the EU product safety rules, please follow the Link to the webpage of the European Commission.

This document was produced with the financial support of the European Union. Its contents are the sole responsibility of SPEAC project and do not necessarily reflect the views of the European Union.