The distributor checks, and the check is specific

Distributors read Article 15, see that it is three paragraphs long where the manufacturer gets ten, and conclude the regulation is not really about them. The length is misleading. The duties are few but they are checkable, dated and specific, and two of them are about documentation that somebody else produced.

The verification happens before the machine moves

Article 15(2) lists what has to be verified before making a machine available on the market, which is to say before you sell it on, not after a problem surfaces. Two of the four items are documents.

Point (c) is the one with teeth. It is not enough that instructions exist somewhere. They have to accompany the machine, they have to be the Article 10(7) ones, and they have to be in a language users can easily understand as determined by the member state the machine is being made available in. A distributor selling the same model into three countries is verifying three different language positions, and the manufacturer three borders away may not have thought about any of them.

The other two items are the CE marking, and that the manufacturer and importer have put their identification and contact details on the machine as Article 10(5), 10(6) and 13(3) require. All four are things you can look at. None of them require you to assess conformity, which is not a distributor duty and never becomes one.

A digital address is now part of what you are checking

When instructions are delivered digitally, "accompanied by the instructions" means the machine is marked with how to reach them and that what they reach is right. A QR code that resolves to a support portal for a product family, a login wall, or a page in the wrong language is a machine you have a reason to believe does not conform. The check is cheap to perform on arrival and expensive to perform in retrospect, because by then you have made it available.

Storage and transport

Article 15(4) adds that while the machine is under your responsibility, storage and transport conditions must not jeopardise conformity with the essential health and safety requirements. For documentation this matters in a dull but real way: paper that travels with a machine can be lost in your warehouse, and a digital address cannot.

When a distributor stops being a distributor

Article 17 sets out the cases where the obligations of manufacturers apply to importers and distributors instead. Put your own name or trade mark on a machine, or modify one already placed on the market in a way that affects its conformity, and you are treated as its manufacturer, with the whole of Article 10 attached. Private labelling is the common route into this, and it is usually a commercial decision taken without anyone reading Article 17.

What this guide does not cover

Article 15 also carries the corrective action, withdrawal and recall duties, the obligation to inform authorities about a machine presenting a risk, and the duty to cooperate on reasoned request. Article 16 is the parallel list for partly completed machinery. Those are outside this page, which is about the documentation you are expected to look at before the machine leaves you.