Who keeps compliance files when we change agents?
Agree a buyer-controlled archive, a named evidence custodian and continuing access before changing agents. Match every document to the product revision it supports, record gaps and test retrieval before signing off. Retention follows the applicable product rules. Discuss this handover with Cambridge China Bridge.
Name the responsible business and the file custodian
Separate the business responsible for product compliance from the person administering its files. Importer obligations include checking that documentation exists and keeping records available, as explained in our certification guide. Record the manufacturer, importer and market for each product before allocating custody.
Agree a named evidence owner within the responsible business, a deputy and an archive administrator. State who supplies originals, approves updates and answers evidence requests. Prefer an archive controlled by that business, with agreed access for the outgoing agent, incoming agent and factory. Do not treat a folder transfer as evidence that responsibilities have transferred.
Agree a file index adapted to the product
Use the technical-file checklist as a starting point. Tailor the index to the product and intended market rather than demanding the same certificate bundle for every purchase. For each entry, record its purpose, document title, issuer, date, revision, covered configuration, custodian, storage location and verification status.
Consider design drawings, material and component specifications, risk assessments, complete test reports, declarations, labels, instructions and production-change records. Include product-specific evidence where relevant. Mark an item not applicable only with a written reason and named reviewer; distinguish this from a missing document.
Map evidence to models and revisions
Build a coverage register with a row for each saleable model and revision. Record factory identity, materials, critical components, power supply, software where relevant, intended use and batch references. Link these to the exact supporting documents. Use the approved product specification to identify configuration differences.
Record why a report supports a variant and who checked that conclusion. Keep superseded configurations linked to historical shipments. A report for a similar-looking product should remain an unresolved coverage question until reviewed. Do not overwrite old evidence when a factory changes a component.
Record gaps and agree continuing access
Maintain a missing-item register showing the affected model, missing or disputed evidence, practical consequence, person responsible, agreed completion date and closure evidence. Separate unavailable originals, incomplete reports, unverified documents and uncertain model coverage. Agree which unresolved gaps block handover acceptance or further orders.
Put access terms in writing using the original-records access guide. Specify named users, viewing and download permissions, laboratory verification permissions, update notifications and support after termination. Agree export formats, backup custody, retrieval response times, charges and arrangements if an agent stops trading. If confidential material stays elsewhere, name its holder and test the authorised retrieval route.
Set retention by the applicable product rules
For electrical equipment within the GB electrical safety regime, official guidance says importers must keep a copy of the declaration of conformity and technical documentation for 10 years after the equipment is placed on the GB market. Official RoHS guidance instead describes holding the declaration and ensuring technical documentation is available for inspection for 10 years after the last product in the product line is first placed on the market.
Create a retention schedule for each applicable regime: record the official guidance used, documents covered, responsible business, triggering event and supporting market-placement records. Agree how later shipments update the schedule, how historical files remain accessible and who approves deletion. Do not calculate retention from the date the agent relationship ends.
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Test the handover before accepting it
Agree the acceptance checklist before transfer. Have the incoming custodian use their own authorised account to retrieve evidence for a current model, a superseded revision and a changed component. Open the complete reports, check signatures and attachments, trace documents to shipment records and test the route for confidential files.
Export the index, coverage register, missing-item register and underlying files; restore the backup and check permissions. Record the tester, date, documents retrieved, failures and corrective action. Accept only the scope that passed, attach unresolved gaps to the sign-off and retest failed steps before closing them. Arrange a future retrieval check after the outgoing agent's access changes.
Frequently asked questions
Can my old sourcing agent keep the compliance files?
Agree custody and access explicitly. Prefer a business-controlled archive; where originals remain elsewhere, record their holder, permitted uses and a tested retrieval route.
Does changing agents transfer importer responsibility?
Do not assume it does. Identify the manufacturer and importer for each product and market separately from the agent administering the evidence.
How long should we keep product compliance evidence?
Use the applicable product guidance and its retention trigger. Electrical safety and RoHS guidance use 10 years but describe different triggers. Do not start the clock when the agent contract ends.
What proves a compliance-file handover is complete?
A recorded retrieval test against the agreed index and model coverage, readable complete files, a restored backup and signed acceptance that identifies every unresolved gap.