The European Federation of Associations of Locks & Builders Hardware Manufacturers

A retailer sells a product, which is not manufactured by himself/herself, using the retailer's own name. May the retailer use the declaration of performance (DoP) drawn up by the real manufacturer? If not, does the DoP drawn up by the retailer need to be based on certification granted by a notified body?

Retailers (the Construction Products Regulation (CPR) calls them distributors) making construction products available on the market on their own (trade) names are indeed considered manufacturers (see Article 15 of the CPR). Therefore, they need to draw up their own DoPs, technical documentation, instructions of use, safety instructions (cf. Article 11 of the CPR), information on dangerous substances (see Article 6(5) of the CPR) and affix the CE marking (see Articles 8 and 9 of the CPR) to these products.


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