Are YOU A Responsible Person?

Of course you are! You’re reading this blog and you’re an Amazon Seller. But are you a RESPONSIBLE PERSON? If you’re an Amazon Seller in the EU, you know exactly why I’m asking this question! By now, you’ve seen this notification!

As you know, EU sellers have extra compliance requirements that don’t apply to .com sellers! And now, here’s the latest. On July 16, 2021 a new EU regulation will come into effect. Called the “Market Surveillance Regulation (EU) 2019/1020” it affects sellers that have products marked with CE (that are NOT manufactured in the EEA). For those products, you will now be required to provide a Responsible Person as your point of contact for all product compliance issues. And the clock is ticking! You have until June 11th to assign this person!

What is the CE marking? And do I need a Responsible person?

CE marking is a certification mark applied to a product by the manufacturer that indicates conformity with health, safety, and environmental protection standards for products sold within the European Economic Area (EEA). However, not all products are required to be CE marked. Usually the required products are toys, electronics, personal protective equipment, machinery, construction products, gas appliances, recreational and personal watercraft, pressure vessels, and measuring equipment. You can find the full list here.

If the item requires CE marking, then EU legislation will require the manufacturer to include a Declaration of conformity assuring the consumer that the product conforms. Here’s a sample of this form:

If you are not the manufacturer, you will need to ensure that your CE products bear labeling that lists the Responsible Person on each item. You will need to check your dashboard to see how many ASINs in your catalogue this could affect. 

Who can be an EU Responsible Person?

An EU Responsible Person can be any of the following:

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

What does the Responsible Person have to do?

  1. Collect the product’s EU Declaration of Conformity (or Declaration of Performance)
  2. Ensure that additional documents demonstrating EU conformity of the product can be made available from the brand owner upon request in a language understood by an authority.
  3. Inform authorities of any risk posed by the product.
  4. Cooperate with market surveillance authorities, including ensuring that the brand owner takes necessary corrective actions to remedy any non-compliance of the product. 

Contact information of the Responsible Person must be displayed on the product or on its packaging, the parcel, or an accompanying document.

How do I find a Responsible Person?

Amazon has provide EU sellers with a list of “RPs” here….

We have a customer with only 7 ASINs affected….so they’ve decided to remove them from their catalogue! Another customer has presented us with over 150 ASINs and will need a “RP” to assist them! Has your account been suspended or are you at risk of account suspension? The experts at Axelligence can audit and review your account and help you address potential violations in a timely matter. Has your account been suspended or are you at risk of being suspended? The experts at Axelligence can help you write a professionally customized Plan of Action to get your account reinstated as soon as possible.

Good luck and let us know how many of your ASINs are affected by this!

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