Who is responsible for an EU fertilising product?
Last reviewed 5 October 2026. Source: Regulation (EU) 2019/1009, consolidated text of 1 July 2026.
In simple words
The manufacturer is responsible. When the manufacturer writes the declaration of conformity, the manufacturer accepts responsibility that the product follows the rules (Article 16(4)). A consultant such as RecyFert can prepare and store documents. A consultant cannot take over this responsibility.
Words in this article
- Manufacturer
- The company that makes the product, or has it made, and sells it under its own name or brand.
- Economic operator
- A company in the supply chain. This means the manufacturer, the authorised representative, the importer or the distributor.
- Authorised representative
- A person or company in the EU that the manufacturer appoints in writing to do certain tasks for the manufacturer.
- Importer
- A person or company in the EU that brings a product from a country outside the EU onto the EU market.
- Distributor
- A company in the supply chain that makes the product available, but is not the manufacturer or the importer.
- EU declaration of conformity (DoC)
- A signed document in which the manufacturer states that the product follows the rules.
The manufacturer
The manufacturer must:
- design and make the product so that it follows the rules for the product and its materials;
- write the technical documentation;
- do the conformity assessment;
- write the declaration of conformity;
- put the CE marking on the product;
- keep the technical documentation and the declaration for 5 years after the product is first sold in the EU.
The authorised representative
A manufacturer can appoint a representative in the EU in writing. The representative can do some tasks, for example keep documents ready for authorities. The representative cannot take over the duty to make the product correctly or to write the technical documentation (Article 7).
The importer
An importer brings a product from outside the EU onto the EU market. Before the importer does this, the importer must check that the manufacturer has done the conformity assessment and has written the technical documentation. The product must also have the required documents, an identification number and the manufacturer's contact details. The importer adds their own name and address and keeps a copy of the declaration for 5 years (Article 8).
The distributor
A distributor must take due care. Before the distributor sells the product, the distributor checks that the required documents and label information are there (Article 9).
Where does RecyFert fit?
RecyFert prepares and stores the dossier. The economic operator stays responsible. RecyFert does not decide if a product is compliant. That decision belongs to the notified body or the authority.
Common questions
Can a consultant sign the declaration of conformity?
No. The declaration is made under the sole responsibility of the manufacturer (Annex V). A consultant can prepare it, but the manufacturer signs it.