Product safety checklist for importers

Published by:
Netherlands Food and Consumer Product Safety Authority, NVWA
Netherlands Food and Consumer Product Safety Authority, NVWA

Do you import consumer products (non-food) from outside the EU? You may only sell products that are safe and comply with the rules. If your product is not safe, it can cost you a lot of money. You could face a claim for compensation, and you have to take the product off the market. Read here how to comply with the rules.

1. Check if your product is already banned on EU platform Safety Gate

Check on the EU Safety Gate platform if the product that you intend to import has been banned in the EU. Safety Gate lists products that are banned in the EU due to severe risks. Also check if Safety Gate lists banned products with similar properties as your product.

2. Check which safety rules apply to your product

You need to determine which safety rules apply to your product. These rules can be found in the EU directives for different product categories. Your product may fall under more than 1 product category. If so, you must comply with several EU directives. For example, if you import toys with a battery. Then your product must meet the safety obligations for toys, batteries, and electrical materials.

Hire a consultancy firm

For this step, you need specialised knowledge. Are you a small or medium-sized entrepreneur? Then it may be wise to hire a (commercial) consultancy firm. A consultancy firm can assist you in meeting all your obligations.

3. Check if the product is safe

Check if the product complies with the safety regulations. These rules may differ from one EU country to another. For this step too, you can enlist the assistance of an adviser. There are many consultancies that specialise in this. You or your adviser must check that the manufacturer:

  • has created a technical file (dossier), and that the technical file is complete
  • has put CE markings on the product, if this is mandatory
  • has included instructions for (safe) use of the product in an understandable language
  • has put the correct information on the label
  • meets all the rules for tracing the product

Do you not have enough information to determine whether the product meets the obligations? Then you must request this information from the manufacturer.

4. Put your contact details on the product

Put your contact details on the packaging or in a document accompanying the product. Because you are importing products from outside the EU, you are the contact person for both the consumers and the supervising authorities.

5. Ensure safe transport and storage

You must ensure that you transport and store the imported products safely. For example, you must ensure that the products do not get too wet, dry, cold, or hot during storage or transport. This can make a safe product unsafe.

6. Keep the correct records

You must keep the documentation of your product in your records for a minimum of 10 years. Some products demand a longer retention period. For example, medical devices. If requested by a supervising authority, you must be able to share these documents:

As an importer, you may also carry out administrative tasks on behalf of the manufacturer. The manufacturer must then appoint you as authorised representative.

7. Take immediate action if the product does not meet the obligations

Have you sold a product that does not comply with the obligations? Or do you think the product is unsafe? Then you may not sell it. And you must:

  • file a report via the EU platform Safety Gate to provide information to supervising authorities about the risks
  • inform consumers
  • recall unsafe products
  • provide supervising authorities with information on the manufacturer of the product
  • request the technical file from the manufacturer if this is asked for by a supervising authority.

Questions relating to this article?

Please contact the Netherlands Food and Consumer Product Safety Authority, NVWA