Blank checklist, printable form
Supply Chain Compliance Checklist
EAA Articles 7\u201312 \u2014 Manufacturer, Importer & Distributor Obligations
Blank checklist for offline completion.
Tick one box per row. Add comments and evidence references in the Notes column as needed.
Manufacturer Obligations (Article 7)
EAA Article 7, Manufacturers must design compliant products, prepare documentation, maintain conformity, and cooperate with authorities.
| Ref | Severity | Requirement | Status | Notes / Evidence |
|---|---|---|---|---|
| EAA Art. 7(1) | Critical | Products are designed and manufactured in accordance with applicable Annex I accessibility requirements.All products placed on the EU market must meet the accessibility requirements in Annex I that apply to their category. This is the core manufacturer obligation. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 7(2) | Critical | Technical documentation has been prepared in accordance with Annex IV.The technical documentation must demonstrate how the product meets accessibility requirements. It must include a general product description, list of applied harmonised standards, and explanations of how requirements are met. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 7(2) | Critical | Conformity assessment procedure (Annex IV) has been carried out.The manufacturer must perform the internal production control procedure described in Annex IV. This includes verifying the manufacturing process produces compliant products. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 7(2) | Critical | EU Declaration of Conformity has been drawn up.A formal written declaration following the Annex IV model must be prepared. Use the EU Declaration of Conformity Generator to create this document. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 7(2) | Critical | CE marking has been affixed to the product.The CE marking must be affixed visibly, legibly, and indelibly to the product, its data plate, or packaging before market placement. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 7(3) | Critical | Technical documentation and EU Declaration are retained for at least 5 years after the last product is placed on market.Both the technical file and the declaration must be kept available for authorities for a minimum of 5 years. Set a document retention policy. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 7(4) | Major | Procedures are in place to ensure series production remains in conformity.It is not enough to test one unit. The manufacturing process must be monitored to ensure every unit produced meets accessibility requirements. Changes to production or standards must trigger reassessment. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 7(5) | Major | Product bears a type, batch, or serial number for identification.Every product must be individually identifiable. Affix a model number, batch code, or serial number on the product or packaging. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 7(6) | Major | Manufacturer name, registered trade name, and contact address are on the product or packaging.Consumers and authorities must be able to identify and contact the manufacturer. Include legal name and postal address (a URL alone is not sufficient). | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 7(7) | Critical | Instructions and safety information are provided in an accessible and understandable language.Product instructions must be in the official language(s) of the Member State where the product is sold, and must be accessible (e.g. Available in HTML or accessible PDF, not just a printed leaflet). | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 7(8) | Critical | When non-conformity is identified, corrective measures are taken immediately (correction, withdrawal, or recall).If you discover that a product on the market does not meet accessibility requirements, you must act immediately, correct the product, withdraw it from sale, or recall it from consumers. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 7(8) | Critical | Market surveillance authorities are informed immediately when non-conformity is identified.You cannot quietly fix the issue. National authorities must be notified of the non-conformity, the details of any corrective action taken, and the markets affected. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 7(9) | Major | A complaints register is maintained and monitored.Keep a log of all accessibility-related complaints received from consumers, distributors, or authorities. Review complaints regularly and use them to improve compliance. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 8 | Critical | If the manufacturer is established outside the EU, a written mandate has been issued to an EU-based authorised representative.Non-EU manufacturers must designate an authorised representative established in the EU. The mandate must specify the representative's powers and be signed by both parties. The representative takes on the manufacturer's obligations under Article 7(2)–(9). | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 7(10) | Major | The manufacturer cooperates with authorities on request, providing documentation and information.When a market surveillance authority requests information or documentation, you must respond promptly. This includes providing the technical file, EU declaration, and test results in an accessible format. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A |
Importer Obligations (Article 9)
EAA Article 9, Importers must verify compliance before placing products on the EU market and maintain documentation.
| Ref | Severity | Requirement | Status | Notes / Evidence |
|---|---|---|---|---|
| EAA Art. 9(1) | Critical | Only compliant products are placed on the EU market.Before importing, verify that the manufacturer has met all Article 7 obligations. Do not import products that you know or should know are non-compliant. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 9(2) | Critical | Before placing on market: manufacturer has completed Annex IV conformity assessment.Request and review evidence that the manufacturer performed the conformity assessment procedure. Do not rely on verbal assurances. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 9(2) | Critical | Before placing on market: technical documentation exists.Obtain confirmation that the full technical file exists and can be produced on request. You do not need to hold a copy, but you must be satisfied it exists. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 9(2) | Critical | Before placing on market: CE marking is affixed and required documents accompany the product.Physically verify CE marking on the product or packaging. Check that required documentation (instructions, safety information, declaration reference) is present. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 9(3) | Major | Importer's name, registered trade name, and contact address are on the product or packaging.In addition to the manufacturer's details, the importer must display their own identification and contact information on the product or packaging. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 9(4) | Major | Instructions and information are provided in an accessible language required by the Member State.The importer must ensure instructions are available in the official language(s) of the target market, in an accessible format. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 9(6) | Critical | A copy of the EU Declaration of Conformity is kept for at least 5 years.The importer must retain a copy of the EU declaration and be able to provide the technical documentation to authorities on request for 5 years. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 9(7) | Major | A complaints register is maintained by the importer.Like manufacturers, importers must keep a log of accessibility complaints and non-conforming products, and inform distributors of issues. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 9(8) | Critical | Corrective measures are taken immediately when non-conformity is identified.If you discover that an imported product does not comply, you must correct, withdraw, or recall it, and notify the manufacturer and authorities. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A |
Distributor Obligations (Article 10)
EAA Article 10, Distributors must exercise due care and verify compliance before making products available.
| Ref | Severity | Requirement | Status | Notes / Evidence |
|---|---|---|---|---|
| EAA Art. 10(1) | Critical | Due care is exercised before making a product available on the market.Distributors must verify that the product bears CE marking, is accompanied by required documents, has manufacturer and importer identification, and has accessible instructions in the correct language. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 10(2) | Critical | Non-compliant products are not made available until brought into conformity.If a distributor identifies or suspects non-compliance, they must not sell the product. Inform the manufacturer or importer and, where there is a risk, inform authorities. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 10(3) | Minor | Storage and transport conditions do not jeopardise compliance.Products must be stored and transported in conditions that preserve their accessibility features. Environmental damage or packaging degradation that affects accessibility is the distributor's responsibility. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 10(4) | Critical | Corrective measures are taken when non-conformity is identified.If a product on sale is found non-compliant, the distributor must ensure correction, withdrawal, or recall, and notify the manufacturer/importer and authorities. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 10(5) | Major | The distributor cooperates with authorities on request.Provide all requested information and documentation to market surveillance authorities. Cooperate with corrective actions. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A |
Supply Chain Traceability (Article 12)
EAA Article 12, Economic operators must be able to identify their suppliers and customers for 5 years.
| Ref | Severity | Requirement | Status | Notes / Evidence |
|---|---|---|---|---|
| EAA Art. 12(1) | Critical | Each economic operator can identify every operator that supplied them a product.You must be able to tell authorities who you bought each product from, by name, with documentation. This applies to manufacturers, importers, and distributors alike. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 12(1) | Critical | Each economic operator can identify every operator they supplied a product to.You must be able to tell authorities who you sold or distributed each product to. Maintain sales records that link to product identification numbers. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 12(2) | Critical | Traceability information is retained for at least 5 years.Keep supply chain records for a minimum of 5 years after the last transaction. The Commission may extend this period for products with longer economic life via delegated acts. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A |
Rebranding & Modification (Article 11)
EAA Article 11, When an importer or distributor places a product under their own brand or modifies it, they take on full manufacturer obligations.
| Ref | Severity | Requirement | Status | Notes / Evidence |
|---|---|---|---|---|
| EAA Art. 11 | Critical | If a product is placed on market under the importer/distributor's own name or trademark, all manufacturer obligations (Article 7) apply.White-labelling, rebranding, or own-brand products trigger the full set of manufacturer obligations, conformity assessment, technical documentation, CE marking, 5-year retention, complaints register, and authority cooperation. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A | |
| EAA Art. 11 | Critical | If a product is modified in a way that may affect compliance, all manufacturer obligations apply.Any modification that could change the product's accessibility characteristics (hardware redesign, firmware update, UI changes) makes the modifier a deemed manufacturer. A full Annex IV conformity assessment must be repeated. | ☐ Pass ☐ Partial ☐ FAIL ☐ N/A |