For CE and UKCA marking, the legislation states that the supplier/importer must supply the product "accompanied by the DoC and must keep a copy of it for 10 years after the product has been placed on the market"

I've looked for information relating to when a supplier is asked to supply a copy of the DoC for a product that is less than 10 years old, but can't find the answers I'm looking for. I'm trying to establish :-

i) If requested, the supplier has to provide a copy of the DoC free of charge or whether they can make a reasonable charge to supply a copy ?

ii) Does it matter if the equipment is still owned by the original purchaser or has been sold on to a new owner ?

The ten years relates to the period after the last sale of the product to a market.

They are meant to free issue the DoC ideally with the goods (normally these are contained as a page in the instruction manual as opposed to for example a Declaration of Performance associated with construction products) or with the sales paperwork (invoice/delivery note).

They may, if they so choose, make them available as a download from their company web site - in this case remember it could be in the specific operating manual for the model rather than a separate document.

Particularly with machinery if you are the new owner of something second hand it must be rememembered that the term "manufacturer" and the responsibilities thereof applies to the person conducting the market transaction and not necessarily the original fabricator/assembler.

Originally Posted by: Roundtuit

They are meant to free issue the DoC ideally with the goods (normally these are contained as a page in the instruction manual as opposed to for example a Declaration of Performance associated with construction products) or with the sales paperwork (invoice/delivery note).

The DoC was supplied with the equipment when it was first placed on the market.

These are customers who have since lost it and want a copy for their records several years down the line.

The purpose being - to tick some auditors check list?

A DoC is like an MOT applicable at the time and referencing the standards considered during its creation.

There is nothing to stop the clients approaching the original manufacturer and requesting a DoC applicable to the item although if it is more bespoke in nature than say a commercially available hand drill the more information you can provide - model / serial number / build year - the more able they may be to assist.

One thing the conformity assessment regulations does not do is provide a legal strick to beat manufacturers when the end user has been negligent with their filing.

Originally Posted by: Roundtuit

There is nothing to stop the clients approaching the original manufacturer and requesting a DoC applicable to the item although if it is more bespoke in nature than say a commercially available hand drill the more information you can provide - model / serial number / build year - the more able they may be to assist.

The equipment is more bespoke in nature and we've always supplied a copy when asked, as we have them on file. We've always done this to maintain the goodwill and good working relationship with customers.

However, it's gone from being a request that came in once or twice a year from customers, to a couple of requests every week, creating additional workload for someone, especially as the customers usually don't initially provide enough information to identify the equipment they have.

Summarising you are the equipmment manufacturer, you supplied the DoC with the equipment, you don't post these on-line as the equipment is bespoke in nature and whilst you can access the required document like all customer requests it is an unbudgeted cost that is begining to spiral out of control.

In your circumstances I would devise a form to capture all the information you need to easily locate the appropriate record in your systems - any requestors are sent the form to be completed and returned.

You can then include statement that in the absence of all necessary information to readily access the requested document and to cover retrival costs an invoice of £xx will be levied before the document can be released.

As this is not an access request by an individual the GDPR rule Free of Charge does not apply.