Importing electrical goods

This advice is designed to provide basic guidance to traders. It is not a complete or authoritative statement of the law. Please note that some of the advice we provide to businesses is chargeable.

 

Duties to retain and provide information

An importer must, for a period of 10 years after the day on which the electrical goods are placed on the market:

  • keep a copy of the EC declaration of conformity* (drawn up by the manufacturer) and
  • ensure that the technical documentation can be made available to an enforcement authority if requested.

*Please see link below for an example EC Declaration of Conformity and blank template for use.

Example EC Declaration of Conformity and blank template for use:

The technical documentation referred to above shall contain:

  • a general description of the electrical equipment
  • conceptual design and manufacturing drawings and schemes of components, sub-assemblies, circuits etc
  • descriptions and explanations necessary for the understanding of the drawings and schemes referred to in (b) and the operation of the electrical equipment
  • a list of the standards applied in full or in part and descriptions of the solutions adopted to satisfy the requirements of regulation 5(1) where standards have not been applied
  • results of design calculations made, examinations carried out etc
  • test reports
Test report checklist

It is strongly advised that you get any electrical goods independently tested. However if you intend on relying on a manufacturer's test certificate then it is important that you make a number of checks, such as the following:

  • is it from a genuine accredited test house (checks can be made on China National Accreditation Service or Hong Kong Accreditation Service websites)
  • when were the tests conducted (check dates), if over 12 months then its relevance should be questioned
  • the product description/photograph matches the actual product
  • current applicable standards have been applied including any amendments
  • have all relevant aspects of the standard been applied
  • does the test certificate relate to a pre or post production product (This may be difficult to determine)
  • if further importations of the same product are made, ensure that no components or materials have changed from the original specification, otherwise the test certificate may not be applicable

If you have any doubts about the validity of the test certificate please contact your local trading standards authority.

Labelling

Ensure the following are marked on the product:

  • A CE mark (it should be at least 5mm high and in the following format)
    CE mark
  • The name, registered trade name or registered trade mark of the manufacturer; and a single postal address at which the manufacturer can be contacted
  • The name, registered trade name or registered trade mark of the importer; and a postal address at which the importer can be contacted
  • A type, batch or serial number or other element allowing its identification*
  • Any specific labelling required by the standard(s) e.g. ratings plate, class mark.

Exceptions should be provided for in cases where the size or nature of the electrical equipment does not allow it. This includes cases where the importer would have to open the packaging to put his name and address on the electrical equipment. Where it is not possible to indicate the information specified above on the electrical equipment, the importer must ensure the information is indicated on the packaging; or in a document accompanying the electrical equipment. The CE mark must appear on the packaging and the accompanying documents, if it is not possible to mark it on the electrical equipment.

* It is important the identification numbering allows a clear link to the relevant documentation, that demonstrates the conformity of the specific type of product, in particular the declaration of conformity.

Own branding

If a business 'own brands' goods it takes on the obligations of the manufacturer, and must complete and sign the EC Declaration of Conformity.

Due diligence

Below are just some of the precautions we recommended you adopt to show you have exercised all due diligence to avoid committing an offence of selling unsafe electrical goods. The larger your business the more precautions you will be required to take.

  • Do not simply rely on information or assurance from suppliers or agents
  • It is important to ensure an adequate level of sampling and testing
  • Sample the actual goods imported, not just a pre-import sample
  • Ensure staff are fully trained on what checks to make on products and documentation, and what to do if inconsistencies are found
  • Have written procedures for all operations carried out in the business
  • Regularly review your quality systems and make improvements where necessary
  • Keep records of any checks, tests, invoices etc
  • Keep up to date with changes in legislation that might affect your product
  • Have plans and procedures in place so you can take action such as a product recall in the event of a serious safety problem with one of your products
  • Consider looking at product recall websites (see links below), in case any similar products which you have imported, are recalled
Plugs and sockets

All manufacturers and importers are required to ensure that electrical items they supply in the UK are fitted with UK three-pin plugs with the proper fuse. The only exceptions to this rule are for certain fixed electric lights, appliances intended to be permanently wired into the mains and appliances with an RCD plug or plug transformer. Distributors and retailers must not sell any appliances without a correct fused plug fitted. For more information please see the Electrical plugs and chargers webpage.

If you discover that you have placed an unsafe product on the market, you are obliged to notify your local trading standards authority.

Further information

You may feel you need further advice on how you can comply with the law in this area and we will be happy to help. Please register on our website if you require further advice.

You may also find these links to further guidance helpful:

RAPEX is the EU rapid alert system for all dangerous consumer products, with the exception of food, pharmaceutical and medical devices.

This guide does not replace the Regulations and anyone in the business of supplying electrical equipment should refer to the Regulations for a full statement of the legal requirements.