Importers, do you REALLY do your obligations?

[tubatree]

This is for those people who import electrical goods into the UK.

According to the rules, importers are expected to:

You, or your authorised representative (where allowed for in the relevant legislation), must keep documentation to demonstrate that your product conforms with the regulatory requirements. This must be kept for up to 10 years after the product is placed on the market.

The information you must keep will vary depending on the specific legislation relevant to your product. You must keep general records of:

_ how the product is designed and manufactured_*
_ how the product has been shown to conform to the relevant requirements_*
_ the addresses of the manufacturer and any storage facilities_*

You should keep the information in the form of a technical file which can be supplied if requested by a market surveillance authority.

Getting the test certificates is a doddle, that's not a problem. The issue here is to follow the rules by the letter it includes getting what's referred to as "technical documentation" and this needs to be held in a record. Now, in the line of business I'm in the manufacturers simply will not just hand over designs and how the products are manufactured, they have previously cited intellectual property concerns and sensitive information disclosure and I totally get this. So my question is who on this forum who imports electrical goods follows all the rules and were you handed the product designs or what trading standards refer as "technical documentation"?

This is all really giving me a big headache, I've done some research on some major businesses in my field and the fact is they don't have this documentation either. I obviously wanna do the right thing and follow ALL the rules but it seems like it's impossible to do! Can anyone help me understand this madness?!

Many thanks in advance!

 

[MOIC]

The issue here is to follow the rules by the letter it includes getting what's referred to as "technical documentation" and this needs to be held in a record. Now, in the line of business I'm in the manufacturers simply will not just hand over designs and how the products are manufactured, they have previously cited intellectual property concerns and sensitive information disclosure and I totally get this. So my question is who on this forum who imports electrical goods follows all the rules and were you handed the product designs or what trading standards refer as "technical documentation"?

If you have access to the FULL REPORT on the product you're importing, then all the information will be contained within the report. Generally this can be 50 - 100 pages, although some factories will just supply a summary report or CoC (Certificate/Confirmation of Compliance), which may not be sufficient for your needs.

The full report will include the BOL (known as 'Bill Of Materials'), which gives the record of all the main components used on the product, model number and supplier of the component.

If a manufacturer is citing 'intellectual property concerns' be wary, as this has nothing to do with supplying you with the full report. You're not asking them for the source code of the software, which will be their IP.

You should also be aware that products need to conform to UKCA standards, which came into force after Brexit, but was given a 1 - 2 year transition period, based on your product.

Don't rely on the China supplier to offer the correct documentation, the onus is on you, as the importer to ensure you have it.

 

[MBE2017]

Don't rely on the China supplier to offer the correct documentation, the onus is on you, as the importer to ensure you have it.

As it always has been. Even if supplied certificates by manufacturers they should still be checked to be shown as genuine.

 

[fisicx]

There have also been cases where the documentation is correct but the actual goods were not of the correct standard. Which means you need someone like @MOIC to perform regular quality checks - especially on electrical goods.

An example: a specification called for a specific grade of cable with high temperature coating. Quality checks on arrival showed low grade cabling had been substituted which could have resulted in a fire.

 

[MBE2017]

There have also been cases where the documentation is correct but the actual goods were not of the correct standard. Which means you need someone like @MOIC to perform regular quality checks - especially on electrical goods.

An example: a specification called for a specific grade of cable with high temperature coating. Quality checks on arrival showed low grade cabling had been substituted which could have resulted in a fire.

Strangely enough, a competitor of mine approx 20 years ago imported thousands of Nokia home chargers for sale, after approx three months, and three house fires, he had to recall all of them and have them destroyed. The manufacturer had BS and CE markings on them, but they were total rubbish. It was this I was thinking about re my above post.

Thankfully no one got hurt, but several got large insurance pay outs, since most people charged their mobiles overnight in those days. My competitor took a very large financial loss, since the supplier had emails asking what certification did he want printed onto the chargers, but with no certificates.

 

[MOIC]

since the supplier had emails asking what certification did he want printed onto the chargers, but with no certificates.

It still happens!!