Importer

Under RoHS Directive 2011/65/EU Article 3(13), an importer is any natural or legal person established within the EU who places EEE from a third country on the EU market. Importers have significant RoHS obligations under Article 10: ensure the EEE has been subjected to the conformity assessment procedure; ensure the manufacturer has drawn up a Declaration of Conformity; ensure CE marking is affixed; verify the manufacturer’s technical documentation; attach their own name and contact address to the product; and not place non-compliant EEE on the market. Importers must also cooperate with market surveillance authorities and maintain copies of the DoC for ten years.

Directive 2011/65/EU, Articles 3(13) and 10.

Importers face full product liability for RoHS compliance of products they bring from non-EU manufacturers into the EU market. When a manufacturer is outside the EU, the importer effectively steps into the manufacturer’s shoes for EU compliance purposes. EU importers should conduct thorough due diligence on non-EU suppliers’ RoHS compliance documentation before importing. If a non-EU manufacturer has appointed an Authorised Representative, importers may rely on that representative’s documentation, but should verify its adequacy.