E-commerce

E-commerce

As a seller via E-commerce platforms, you often deal with a Chinese supplier. Whereas previously the responsibilities regarding CE marking rested with these suppliers, they now fall on a European market participant. Because E-commerce platforms are also seen as European market participants, they almost always demand that another European market participant takes on these responsibilities. This could be an Importer or a private labeler whose name should appear on the packaging and/or Declaration.

‘Market participant’ is defined as:

1. A manufacturer established in the Union (including private label).
2. An importer when the manufacturer is not established in the Union.
3. An Authorised Representative with a written mandate from the manufacturer designating the representative to perform the specified tasks on behalf of the manufacturer.
4. A fulfillment service provider established in the Union with respect to the products handled by that service provider, when no other market participant as referred to under 1), 2), and 3) is established in the Union.

Challenges in online sales

Whereas previously as a reseller you could offer your products on various E-commerce platforms such as bol.com, Amazon, and AliExpress, you can no longer do so without an EU-established market participant. Although these platforms are fulfillment service providers established in the Union, they do not want to bear the associated responsibilities. This poses the following challenges:

• Since E-commerce platforms require a European market participant to take on responsibilities, you must assume the role of importer or private labeler.
• You must ensure that the technical documentation of the product demonstrates compliance with European legislation.
• Additionally, the Declaration of Conformity/packaging must bear your own name.

As collaboration often occurs with Chinese suppliers, it’s challenging to get the technical documentation in order, therefore our experts can help you.

How Certification Experts can assist you

As an Importer or Private Labeler, you have an obligation to ensure that your product is safe and does not pose a risk to the consumer or end-user. You must be able to demonstrate this and therefore need access to the Manufacturer’s Technical Documentation. Based on the provided documentation, we can then offer the following services:

• Determining the applicable Directive(s) and/or Regulation(s)
• Determining the related (harmonised) standards
• Verification of available documentation
• Assessment of whether the available documentation demonstrates that the product complies with the applicable requirements
• Drafting findings
• Providing advice and recommendations
• Contacting the Chinese Supplier once
• Drafting template of Declaration of Conformity

Certification Experts also has experience in drafting a Private Label Contract between you and the Supplier to establish the responsibilities and obligations for both parties.

If any non-conformities are found during the entire process, we can also assist you. Together, we look for solutions and can draft necessary documents, perform tests, or contact the supplier, for example.

With E-commerce platforms such as Bol.com and Amazon, we have extensive experience and are capable of guiding and advising you from start to finish.

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