Who is responsible for an imported machine?
Identify the manufacturer responsible for the exact machine and check any representative’s written mandate. Own use does not remove the issue: if no qualifying manufacturer exists, whoever places the machine on the GB market or puts it into service becomes the manufacturer. Cambridge China Bridge can help gather supplier evidence in China.
Start with the machine and its intended use
This guide concerns Great Britain. OPSS guidance defines the manufacturer by reference to designing or manufacturing machinery for supply under their own name or trademark, or for their own use in the UK. It also provides a fallback where no such person exists. Buying a machine solely for your factory therefore does not settle who carries manufacturer responsibilities.
Before ordering, record the exact machine, configuration, intended use and destination factory. Ask the supplier to identify the responsible manufacturer in writing. Use our machinery sourcing guide for the wider specification and safety checks.
Trace the manufacturer behind the seller
Ask for the manufacturer’s full business name and address, the proposed declaration of conformity and a photograph of the machine’s identification plate. Compare these with the quotation and order specification. If the seller and manufacturer differ, ask each to explain their role and obtain confirmation directly from the named manufacturer.
A factory address or sales contact alone does not establish that the named business accepts responsibility for this machine. Ask who controls the design, approves safety changes and holds the supporting technical information. Record unresolved discrepancies rather than accepting a general assurance that the paperwork is available.
Check any authorised representative’s mandate
OPSS says manufacturers can appoint an authorised representative by written mandate to perform all or part of their obligations. For the GB market, that representative must be established in the UK. Ask for the mandate, the representative’s identity and address, and confirmation that it covers your machine and the tasks being claimed.
Treat a sourcing agent, adviser or document contact as a separate commercial role unless the manufacturer provides the relevant written appointment. Ask who will handle document requests and safety queries after delivery. See the machinery authorised representative guide for that appointment process.
Recognise when the responsibility reaches you
Where no manufacturer meeting the definition exists, OPSS says the person placing the machinery on the GB market or putting it into service becomes the manufacturer. Its guidance defines putting into service as the first use for its intended purpose in GB. A buyer importing directly for factory use can therefore fall within that responsibility.
That means addressing manufacturer compliance obligations, rather than merely finding a name to put on paperwork. The reference guide explains the technical file, safety requirements, conformity assessment, declaration, instructions and marking. If the supplier cannot substantiate the manufacturer’s identity and role, pause shipment and commissioning while a machinery compliance specialist assesses the position.
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Make responsibility a release condition
Keep a responsibility record with the order: the manufacturer’s identity, confirmation covering the exact machine, any representative’s mandate, document contacts and unresolved questions. Agree that substitutions affecting the machine or named manufacturer require your review before shipment. Give a named person in your business authority to stop release when the evidence does not match.
Use the technical compliance file checklist to organise supporting records. Cambridge China Bridge’s staff in China can help collect supplier confirmations and compare them with the actual machine. Keep that evidence-gathering work separate from any proposed appointment as an authorised representative.
Frequently asked questions
Does importing a machine for my own use avoid manufacturer duties?
No. Own use is covered by the OPSS manufacturer definition. If no qualifying manufacturer exists, the person putting the machine into service can become the manufacturer.
Is the company selling me the machine always its manufacturer?
Do not assume so. Ask the seller to identify the responsible manufacturer and obtain confirmation covering your exact machine. Compare the names on the proposed documents and machine plate.
Is my sourcing agent automatically an authorised representative?
No. OPSS describes an appointment by written mandate from the manufacturer. Ask for that mandate and check the tasks it covers.
What should I do if nobody accepts manufacturer responsibility?
Pause shipment and commissioning. Establish whether a qualifying manufacturer exists and obtain specialist advice on the responsibilities you may take on before using the machine.