The import of electrical appliances involves vital issues of responsibility. In connection with import, attention must be paid to the fulfilment of special national requirements, i.e. the national installation requirements and especially the language of installation instructions and user manuals.
In terms of the responsibility aspect, there are two different actors: importers in the European Economic Area and those in Finland.
The market surveillance carried out by Tukes occasionally results in products being recalled to this stage, if the requisite changes can be implemented by the importer.
Importers in the European Economic Area are responsible for products imported from outside the European Economic Area and placed on the EEA market comply with European safety requirements. In addition, importers in the European Economic Area shall also assume liability for technical documentation and declaration of conformity being available to the authorities and for the products being duly furnished with CE markings.
Finnish importers are entitled to place only conforming products on the Finnish market. As no mention is made in the Low Voltage Directive of the language of instructions, responsibility for user manuals and installation instructions being available in Finnish and in Swedish in most cases also falls on Finnish importers.
Initiatives by importers to Tukes mostly come in the form of questions although suspicions of non-conforming products in the selections of other importers are also relatively common. To a certain extent, the initiatives may also contain suspicions as to the conformity of products in the enquirer’s own selection or those it plans to import. However, Tukes does not conduct market surveillance “on demand”, as ensuring the obligation of ensuring the conformity of products placed on the market lies with importers. Tukes advises importers on how to best ensure the conformity of products´ prior to placement on the Finnish market.
The majority of products are transferred to the end user in retail trade. A small number of products come to this stage several times during their lifecycle.
Sellers of products answer to their customers for the safety of the products. By law, sellers are equally responsible for product safety as importers, especially if the importer for one reason or the other fails to bear its responsibility. In addition to retailers of new products, product sellers include recycling centres, second-hand shops, sellers at swap meets and other private individuals who sell their old electrical appliances.
The Tukes market surveillance processes relate to the retail trade and, when necessary, recall unfit products back to an earlier stage of the lifecycle, in most cases all the way back to the stage of design and manufacture. Supervision often also results in complete removal of the product from the market.