Importers/distributors are regarded as manufacturers if:
They market construction products under their own name or brand,
Or when they alter a construction product, which is already marketed in a manner which may affect the performance of the construction product.
This has important consequences for importers/distributors in respect of both product documentation and technical documentation.
Regarding the product documentation:
This means that importers/distributors must have product documentation (see link on the right) in their own name/under their own brand name.
As regards technical documentation
Importers/distributors then have to ensure that the manufacturer has carried out tasks required of him by the Construction products Ordinance, and which are described in more detail in the systems for assessment and verification of construction product performance.
In addition, importers must ensure that the third-party assessments from technical inspection bodies have been completed. In practice, this means:
For system 3 (test laboratory) construction products, importers must ensure that a technical inspection body has completed third-party assessment of the performance of the construction product
For system 2 + (certification of production inspection in the factory), importers/distributors must ensure that a technical inspection body has certified the manufacturer's production inspection in the factory.
For systems 1 and 1 + (product certification), importers must have a product certificate in their own name/under their own brand name