Importer and authorised representative obligations
Importers and authorised representatives carry their own ten-year documentation duty under Regulation (EU) 2023/1230, separate from the manufacturer, and it outlives the supplier relationship.
Most writing about Regulation (EU) 2023/1230 addresses manufacturers. If you import machinery into the EU, or act as an authorised representative for a manufacturer outside it, you carry duties of your own. They are not inherited from your supplier and they do not end when the machine is delivered.
Every machine must arrive with its instructions
“Importers shall ensure that the machinery or related product is accompanied by the instructions for use and the information referred to in Article 10(7).”
This is an obligation to check, not merely to forward. If a supplier in another country ships a machine whose plate carries no way to reach the instructions, or whose instructions are not in a language the destination country accepts, the gap is yours as much as theirs.
Ten years of documentation, on your side
“Importers shall, for at least 10 years after the machinery or related product has been placed on the market, keep a copy of the EU declaration of conformity at the disposal of the market surveillance authorities and ensure that the technical documentation set out in Annex IV, Part A, can be made available to those authorities upon request.”
Ten years is measured from placing on the market, per machine. A supplier relationship that ends in 2029 does not end the obligation for everything imported before then. Neither does a supplier going out of business, which is the scenario worth planning for, because that is exactly when the documents become hard to obtain.
Authorised representatives carry it too
“keep the technical documentation and the EU declaration of conformity of machinery and related products or the EU declaration of incorporation of partly completed machinery at the disposal of the national market surveillance authorities for at least 10 years after the product has been placed on the market;”
A manufacturer may appoint an authorised representative by written mandate and entrust this task to them. Note what cannot be delegated: the obligations in Article 10(1) and Article 11(1), and drawing up the technical documentation itself, stay with the manufacturer.
What this means in practice
An importer representing a dozen suppliers is running a documentation archive whether or not anyone has called it that. It has to survive staff changes, supplier changes and a decade of IT decisions, and it has to be produceable on request rather than merely existing somewhere.
The practical failure is rarely that the files were lost. It is that nobody can say, years later, which file was the one that shipped with a particular machine, in which languages, and from which address.
Everplate is where this documentation lives
Upload the manuals and declarations you already have and you get a QR code, plate artwork and a permanent address, in every language you sell into. Published revisions are never deleted, so what you served in 2027 is still provable in 2037.