If you’re selling CE-marked products into the EU then you need to be aware of the Market Surveillance Regulation (EU) 2019/1020 which is coming into effect on the 16th of July. It basically means that you will require an economic operator established in the EU by July. This impacts all sellers outside the EU which due to Brexit includes the UK as well as the US, Far East and the rest of the world.
The EU Market Surveillance Regulation together with the guidelines for its implementation will come into force on the 16th of July 2021. Sellers will be required to put the name and contact details of their economic operator in the EU on the product or the product packaging.
Market Surveillance Regulation and Amazon
You will need a Responsible Person if you sell goods into the EU that are CE Marked. Amazon have given some specific advice so if you use Amazon FBA in the EU, you need to notify Amazon of the Responsible Person for your CE-marked products through the Responsible Person Dashboard by the 11th of June 2021, to avoid Fulfilled by Amazon (FBA) inbound shipment blocks into the EU/EEA.
Common examples of products that are required to be CE-marked include toys, electronics, personal protective equipment, machinery, construction products, gas appliances, recreational and personal watercraft, pressure vessels, and measuring equipment. All CE-marked products are covered by this rule except for medical devices, explosives for civil uses, and certain lifts and cableway installations.
Brand Owners and the EU Market Surveillance Regulation
If you are the brand owner of CE-marked products (other than medical devices, explosives for civil uses, and certain lifts and cableway installations), Amazon recommend that you take the following steps:
- Verify compliance of your products
- Enrol in Amazon Brand Registry
- Appoint an EU Responsible Person for your products
Ensure that your products satisfy all the relevant CE marking requirements and that the corresponding documents (e.g.Test reports and Declaration of Conformity) have been drawn up. You will need to provide the Declaration of Conformity (or Declaration of Performance) to your Responsible Person and be able to provide other technical documentation on request.
Amazon encourage you to register your brand in Amazon Brand Registry to take advantage of the tools we offer to brand owners. For more information about Amazon Brand Registry, including a list of frequently asked questions, visit our Brand Registry information page .
A brand owner has flexibility in who they can appoint as the Responsible Person. Some options you should consider:
If you have a subsidiary in the EU or already have an EU importer, it may be possible to appoint them as the Responsible Person for your products.
The testing laboratory or the certification company that you use for your products may be offering Responsible Person services.
You may want to take advantage of the third-party providers offered in Amazon’s Service Provider Network.
Amazon offers a Responsible Person Service for FBA products, which could make sense for you if you sell your products through Amazon’s FBA service.
Non Brand owner resellers
Amazon has enabled a dashboard in Seller Central to allow you to declare your EU Responsible Person for your brand/ASINs. When you access the dashboard, the CE-marked ASINs you sell will be listed. Amazon encourage you to review them and ensure there is a Responsible Person for each ASIN sold by you. Please note that any Responsible Person Information you add for these ASINs is specific for units sold by you.
If your products do not have a Responsible Person, Amazon recommend talking with your upstream suppliers to confirm they are aware of the upcoming changes and to ensure they are taking appropriate actions to appoint a Responsible Person.
Amazon Service Provider Network Responsible Person providers
Some testing laboratories or certification companies on Amazon’s Service Provider Network are offering services to act as the point of contact for product compliance – they can act as your Responsible Person. You can view the up to date list on Amazon here.
Amazon Responsible Person Service
The Amazon Responsible Person (ARP) Service is a solution for sellers using Fulfilment by Amazon to comply with the new Market Surveillance Regulation. Once subscribed to this service, Amazon will act as the EU Responsible Person for applicable CE-marked products that you designate. You can find out more about ARP here.
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