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09.06.21

Responsible Person updates

Who is responsible for your CE-marked products?

And why should it be Amazon?

As of July 16th, it will be illegal to sell CE-marked products in the EU without a ‘Responsible Person’ acting as the point of contact for product compliance. You’ll need to notify Amazon of the Responsible Person for your CE-marked products by using the Responsible Person Dashboard to avoid Fulfilment by Amazon (FBA) inbound shipment blocks into the EU/EEA.

There are a number of options you can use for your Responsible Person, but the easiest, safest and most efficient choice is to sign up to Amazon’s Responsible Person Service (ARP). I’ve put together a short guide to ARP and navigating the EU’s upcoming regulatory changes below. Not sure if any of your products are required to be CE-marked? We recommend that you reach out to your supplier/legal counsel to investigate further.

Changes coming on the 16th July

A new EU Regulation called the ‘Market Surveillance Regulation (EU) 2019/1020’ will require CE-marked products to have a ‘Responsible Person’ present in the European Union, acting as the point of contact for product compliance.

It is paramount to notify Amazon of the Responsible Person on applicable ASINs to avoid any inbound shipment blocks into the EU. After July 16th, it will be illegal to sell CE-marked products in the EU without an EU Responsible Person.

What is a CE-marked product?

A product which is required to meet EU safety, health or environmental requirements, such as:

Toys
Electronics
Personal protective equipment
Machinery
Construction products
Gas appliances
Recreational and personal watercraft
Pressure vessels
Measuring equipment

Unsure whether a product needs to be CE-marked? Speak to your supplier/legal counsel ASAP.

What options do you have?

You can choose from a number of options to be your EU Responsible Person:

  • The manufacturer or brand, if established in the EU
  • An importer established in the EU
  • An authorised representative established in the EU, who is appointed in writing as the Responsible Person by the manufacturer or brand
  • A fulfilment service provider established in the EU

Our advice? Let Amazon do it for you

Amazon offers a Responsible Person Service (ARP) for non-EU manufacturers, brand owners and authorised resellers.

For a flat fee of €25 per month, Amazon will act as the Responsible Person for all of those products which you have submitted the requested compliance documentation for.

That means subscribing to ARP is quicker, easier and less time consuming. It’s also safer as your Responsible Person won’t be disappearing any time soon, and it’s more cost effective – especially when covering multiple ASINs.

So, what do you need to do once you’ve subscribed? There are three things to remember:

1 – Submit the required compliance documentation for the relevant ASINs

2 – Ensure you have the technical documentation to support the compliance of your products

3 – Add Amazon’s contact information to your FBA inbound shipments

One final point – Don’t miss the deadline!

If you subscribe now, you can use ARP for free until January 2022. However, you should speak to your supplier/legal counsel to investigate further.

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