Supply Chain Due Diligence
What is Supply Chain Due Diligence?
Supply chain due diligence is the process by which a business identifies, assesses, and addresses compliance and safety risks across its supply chain before placing a product on the market. In the context of EU and UK product regulation, due diligence involves verifying that manufacturers, suppliers, and other parties in the supply chain have met their applicable regulatory obligations, and that the products sourced are safe, compliant, and correctly documented.
Why It Matters
EU and UK product regulations place obligations not only on manufacturers but on every economic operator in the supply chain, including importers and distributors. Businesses that source products from outside the EU or UK cannot simply assume that their suppliers have met all applicable requirements. They must take reasonable steps to verify compliance before placing or making products available on the market.
Where a non-compliant or unsafe product reaches consumers, competent authorities may investigate all parties in the supply chain. Businesses that cannot demonstrate adequate due diligence may be held accountable alongside the manufacturer, even where they did not produce the product themselves.
For importers, distributors, and ecommerce sellers sourcing products from third-country manufacturers, building robust supply chain due diligence processes is both a legal obligation and a practical safeguard against enforcement action, product recalls, and reputational damage.
Key Requirements
Who Is Required to Carry Out Supply Chain Due Diligence?
Supply chain due diligence obligations apply to all economic operators involved in placing or making products available on the EU or UK market, including:
- Importers placing products from third countries onto the EU or UK market
- Distributors making products available to consumers or other businesses
- Online marketplace operators facilitating the sale of products to EU or UK consumers
- Responsible Persons and Authorised Representatives verifying the compliance of the products they represent
This applies across multiple regulatory frameworks covering product categories including:
Toys and children’s products
General product safety
Medical devices and in vitro diagnostics
Cosmetics and personal care products
Electrical and electronic equipment
Responsibilities Relating to Supply Chain Due Diligence
While specific obligations depend on the product category and role in the supply chain, due diligence responsibilities commonly include:
- Verifying that manufacturers have completed applicable conformity assessment procedures and hold the required documentation
- Confirming that products bear the required conformity markings and labelling before placing or making them available on the market
- Requesting and reviewing technical documentation, test reports, and declarations of conformity from suppliers
- Confirming that an EU Authorised Representative or Responsible Person has been appointed where required
- Maintaining records of supply chain parties and compliance checks carried out
- Acting promptly where a compliance concern or safety risk is identified, including notifying competent authorities where required
- Conducting periodic reviews of supplier compliance, particularly where product formulations, designs, or manufacturing processes change
Supply Chain Due Diligence and Technical Documentation
Technical documentation is a key output of effective supply chain due diligence. Importers and distributors should request and retain copies of or access to relevant compliance documentation from their suppliers, including test reports, risk assessments, and declarations of conformity. This documentation forms the evidence base that demonstrates due diligence was carried out and supports the business’s own compliance obligations.
Need compliance support for the EU and UK?
Euverify provides EU Authorised Representative, Responsible Person, and GDPR Article 27 Representative services for businesses placing products on the EU and UK markets. Our team supports regulatory communication, documentation, and ongoing compliance management across multiple frameworks.
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