--- title: "EU Market Surveillance Regulation (EU) 2019/1020" canonical_url: "https://www.sorena.io/artifacts/eu/market-surveillance-regulation" source_url: "https://www.sorena.io/artifacts/eu/market-surveillance-regulation" author: "Sorena AI" description: "A practical EU Market Surveillance Regulation artifact grounded in Regulation (EU) 2019/1020 and current Commission materials." published_at: "2026-02-21" updated_at: "2026-02-21" keywords: - "EU Market Surveillance Regulation" - "Regulation (EU) 2019/1020" - "Article 4 economic operator" - "Article 6 distance sales" - "Article 14 online enforcement powers" - "Article 25 customs controls" - "Article 26 suspension of release" - "Article 34 ICSMS" - "Union Product Compliance Network" - "MSR compliance" - "Market surveillance" - "MSR" - "Enforcement" - "Compliance" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # EU Market Surveillance Regulation (EU) 2019/1020 A practical EU Market Surveillance Regulation artifact grounded in Regulation (EU) 2019/1020 and current Commission materials. ![EU Market Surveillance Regulation artifact preview](https://cdn.sorena.io/cdn-cgi/image/format=auto/cheatsheets/prod/sorena-ai-eu-msr-timeline-small.jpg?v=cheatsheets%2Fprod) *MSR* *Free Resource* ## EU Market Surveillance Regulation (EU) 2019/1020 A practical enforcement guide for EU product compliance: how market surveillance works, what authorities can ask for, how customs and online enforcement interact, and how to stay inspection-ready across online and offline channels. Grounded in Regulation (EU) 2019/1020, the 2021 Article 4 guidance notice, the 2025 Article 4 implementation report, and Commission market-surveillance materials. [Get MSR readiness review](/contact.md) ## What you can decide faster - **Whether MSR triggers**: Distance sales targeting, operator setup, and channel exposure. - **Who must act**: Manufacturer vs importer vs authorised representative vs fulfilment service provider. - **What to show**: DoC/technical documentation retrieval, logs, tests, and corrective actions. Early apply 1 Jan 2021 | Applies 16 Jul 2021 | Updated Mar 2026 ### Quick scan *MSR* - **Economic operator duties**: Article 4 tasks and what to label on product/parcel. - **Online sales targeting**: When an offer is "made available" in the EU (Article 6). - **Investigations + corrective action**: Evidence requests, withdrawals/recalls, and serious risk handling. Use the decision flow to connect Article 4 setup, online targeting, customs controls, and evidence retrieval into one enforcement-ready operating model. | Value | Metric | | --- | --- | | 1 Jan 2021 | Early apply | | 16 Jul 2021 | Applies | | Art. 4 | Operator | | Art. 25 | Customs | **Key highlights:** Article 4 duties | Online sales | Inspection-ready evidence ## Topic Guides - [Authority request response playbook | EU Market Surveillance Regulation (EU) 2019/1020 | Evidence requests, corrective action](/artifacts/eu/market-surveillance-regulation/authority-request-response-playbook.md): An operational playbook for responding to authority requests under Regulation (EU) 2019/1020: first-24-hour triage, Article 4 evidence packs. - [Enforcement powers and penalties | EU MSR (Regulation (EU) 2019/1020) | Checks, serious risk, penalties](/artifacts/eu/market-surveillance-regulation/enforcement-powers-and-penalties.md): A practical enforcement guide for Regulation (EU) 2019/1020 covering Article 11 risk-based checks, Article 14 authority powers. - [EU Market Surveillance Regulation applicability test | Regulation (EU) 2019/1020 scope, Article 6 distance sales](/artifacts/eu/market-surveillance-regulation/applicability-test.md): A practical applicability test for the EU Market Surveillance Regulation (Regulation (EU) 2019/1020). - [EU Market Surveillance Regulation requirements | Regulation (EU) 2019/1020 (MSR) obligations](/artifacts/eu/market-surveillance-regulation/requirements.md): A practical requirements breakdown for Regulation (EU) 2019/1020 covering Article 4 EU economic-operator tasks, Article 6 distance-sales targeting. - [EU MSR Article 4 economic operator duties and responsible-person setup | Regulation (EU) 2019/1020](/artifacts/eu/market-surveillance-regulation/responsible-person-and-economic-operator-duties.md): A practical guide to Article 4 of Regulation (EU) 2019/1020: when an EU economic operator is required, who can act, what Article 4(3) tasks they perform. - [EU MSR checklist | Regulation (EU) 2019/1020 compliance checklist for inspections](/artifacts/eu/market-surveillance-regulation/checklist.md): An audit-ready checklist for the EU Market Surveillance Regulation (Regulation (EU) 2019/1020): online targeting and distance sales (Article 6). - [EU MSR compliance program | Regulation (EU) 2019/1020 implementation guide](/artifacts/eu/market-surveillance-regulation/compliance.md): A practical implementation guide for the EU Market Surveillance Regulation (Regulation (EU) 2019/1020). - [EU MSR deadlines and compliance calendar | Regulation (EU) 2019/1020 key dates (Article 44, Article 41)](/artifacts/eu/market-surveillance-regulation/deadlines-and-compliance-calendar.md): Key dates for Regulation (EU) 2019/1020 covering early application from 1 January 2021 for Articles 29 to 33 and 36, general application from 16 July 2021. - [EU MSR FAQ | Regulation (EU) 2019/1020 questions (Article 4, Article 6, investigations)](/artifacts/eu/market-surveillance-regulation/faq.md): Answers to common questions about the EU Market Surveillance Regulation (Regulation (EU) 2019/1020): online targeting (Article 6). - [EU MSR penalties and fines | Article 41 penalties (Regulation (EU) 2019/1020) | Reduce exposure](/artifacts/eu/market-surveillance-regulation/penalties-and-fines.md): Penalty exposure under Regulation (EU) 2019/1020: what Article 41 requires, why penalties differ by Member State. - [Investigations and evidence requests | EU Market Surveillance Regulation (EU) 2019/1020 | What authorities check](/artifacts/eu/market-surveillance-regulation/investigations-and-evidence-requests.md): A practical guide to MSR investigations under Regulation (EU) 2019/1020 covering Article 11 risk-based checks. - [Market surveillance for online marketplaces | EU MSR (Regulation (EU) 2019/1020) | Operator controls](/artifacts/eu/market-surveillance-regulation/market-surveillance-for-online-marketplaces.md): A practical guide for online marketplaces under Regulation (EU) 2019/1020: Article 6 distance-sales targeting, Article 7(2) cooperation. - [MSR vs GPSR | Market Surveillance Regulation (EU) 2019/1020 vs General Product Safety Regulation (EU) 2023/988](/artifacts/eu/market-surveillance-regulation/market-surveillance-regulation-vs-gpsr.md): A grounded comparison of Regulation (EU) 2019/1020 and Regulation (EU) 2023/988: MSR as the enforcement and coordination framework. - [Online sales under the EU Market Surveillance Regulation | Article 6 distance sales + ecommerce controls](/artifacts/eu/market-surveillance-regulation/online-sales-and-marketplaces.md): A practical guide for ecommerce sellers under Regulation (EU) 2019/1020: Article 6 distance-sales targeting, Article 4 operator identification. - [What changes with EU market surveillance | Regulation (EU) 2019/1020 (MSR) practical impact](/artifacts/eu/market-surveillance-regulation/what-market-surveillance-changes.md): A practical 'what changed' guide for Regulation (EU) 2019/1020: stronger EU-wide coordination, explicit online/distance sales targeting logic (Article 6). ## Key dates for enforcement planning *MSR Timeline* Track entry into application, staged application for some chapters, and review milestones that affect market surveillance activity and compliance strategy. ## How does the MSR affect your operations *MSR Decision Flow* Use the decision flow to identify applicable obligations and evidence expectations, then translate outcomes into readiness actions and response playbooks. *Next step* ## Turn EU Market Surveillance Regulation (EU) 2019/1020 into an operational assessment workflow EU Market Surveillance Regulation (EU) 2019/1020 should be the shared entry point for your team. Route execution into Assessment Autopilot for live work and into SSOT when the artifact needs deeper research, evidence governance, or supporting analysis. - Start from EU Market Surveillance Regulation (EU) 2019/1020 and route the work by entity, product, team, or control owner. - Use Assessment Autopilot to turn the guidance into owned tasks, evidence requests, and review checkpoints. - Use SSOT to keep documents, evidence, and control records in one governed system. - Move from artifact reading to accountable execution without rebuilding the guidance in separate files. - [Open Assessment Autopilot](/solutions/assessment.md): Turn the guidance into owned tasks, evidence requests, and review checkpoints for EU Market Surveillance Regulation (EU) 2019/1020. - [Open SSOT](/solutions/ssot.md): Keep documents, evidence, and control records in one governed system from the same artifact. - **Download decision flow**: Share operational logic internally. - **Download timeline**: Align milestones across your team. - [Talk through EU Market Surveillance Regulation (EU) 2019/1020](/contact.md): Review your current process, evidence model, and next steps for EU Market Surveillance Regulation (EU) 2019/1020. ## Decision Steps ### STEP 1: Is your product subject to Union harmonisation legislation listed in Annex I of Regulation (EU) 2019/1020? *Reference: Art. 2(1)* - MSR applies to products subject to Union harmonisation legislation listed in Annex I, unless specific provisions in that legislation regulate market surveillance more specifically. - Union harmonisation legislation includes Directives and Regulations covering machinery, PPE, construction products, toys, radio equipment, measuring instruments, ATEX, EMC, pressure equipment, and more. - **NO** Out of MSR Scope - **YES** Which type of economic operator are you? ### STEP 2: Which type of economic operator are you? *Reference: Art. 3(8)-(11), Art. 4* - Economic operator means manufacturer, authorised representative, importer, distributor, fulfilment service provider, or any other natural or legal person subject to obligations under Union harmonisation legislation. - Article 4 applies only to products subject to specific legislation listed in Article 4(5) (including Regulations (EU) No 305/2011, (EU) 2016/425, (EU) 2016/426, (EU) 2023/1542, (EU) 2024/1252 and Directives 2000/14/EC, 2006/42/EC, 2009/48/EC, 2009/125/EC, 2011/65/EU, 2013/29/EU, 2013/53/EU, 2014/29-35/EU, 2014/53/EU, 2014/68/EU). - -> Is your product subject to the legislation listed in Article 4(5)? ### STEP 3: Is your product subject to the legislation listed in Article 4(5)? *Reference: Art. 4(5)* - Article 4 requires an EU-based economic operator only for products subject to the Union harmonisation legislation listed in Article 4(5). - If your product is subject to other Union harmonisation legislation in Annex I but not listed in Article 4(5), Article 4 does not apply (but other MSR obligations may apply). - Article 4(5) legislation includes construction products, PPE, gas appliances, batteries, critical raw materials, outdoor noise, machinery, toys, ecodesign, RoHS, pyrotechnics, recreational craft, simple pressure vessels, EMC, measuring instruments, ATEX, low voltage, radio equipment, and pressure equipment. - **NO** Article 4 Does Not Apply - **YES** Is the manufacturer established in the EU? ### STEP 4: Is the manufacturer established in the EU? - Manufacturer established in the Union: the manufacturer is the economic operator referred to in Article 4 (unless it has appointed an authorised representative for Article 4(3) tasks). - Manufacturer not established in the Union: the importer (if established in the Union) is the economic operator referred to in Article 4, unless the manufacturer has appointed an authorised representative or a fulfilment service provider handles the product. - **YES** EU Manufacturer - **NO** Has the manufacturer appointed an authorised representative in the Union? ### STEP 5: Has the manufacturer appointed an authorised representative in the Union? *Reference: Art. 4(2)(c), Art. 5* - An authorised representative must be established in the Union and hold a written mandate from the manufacturer to perform the tasks in Article 4(3). - The authorised representative must provide a copy of the mandate to market surveillance authorities upon request (Art. 5(2)). - Authorised representatives must have appropriate means to fulfil their tasks (Art. 5(3)). - **YES** Authorised Representative is the Economic Operator - **NO** Is there an importer established in the Union? ### STEP 6: Is there an importer established in the Union? *Reference: Art. 4(2)(b)* - Importer means any natural or legal person established within the Union who places a product from a third country on the Union market (Art. 3(9)). - If the manufacturer is not established in the Union and has not appointed an authorised representative, the importer becomes the economic operator referred to in Article 4. - **YES** Importer is the Economic Operator - **NO** Is there a fulfilment service provider established in the Union handling the products? ### STEP 7: Is there a fulfilment service provider established in the Union handling the products? *Reference: Art. 4(2)(d), Art. 3(11)* - Fulfilment service provider means any person offering, in the course of commercial activity, at least two of the following: warehousing, packaging, addressing, dispatching (excluding postal and parcel delivery services) (Art. 3(11)). - Where no manufacturer, importer, or authorised representative is established in the Union, the fulfilment service provider is the economic operator referred to in Article 4. - **YES** Fulfilment Service Provider is the Economic Operator - **NO** Non-Compliant with Article 4 ## Reference Information ### MSR Scope (Overview) - Regulation (EU) 2019/1020 applies to products subject to Union harmonisation legislation listed in Annex I (machinery, PPE, construction products, toys, radio equipment, low voltage, measuring instruments, ATEX, EMC, recreational craft, pressure equipment, ecodesign, energy labelling, etc.). - MSR covers both online and offline distribution channels (distance sales deemed to be making available if targeted at EU end users). - Market surveillance authorities (MSAs) designated by Member States ensure products comply with Union harmonisation legislation and protect public interests (health, safety, environment, public security). - MSR establishes Article 4 obligations for economic operators: EU-based responsible person required for products subject to specified legislation (listed in Article 4(5)). - Border controls and customs cooperation framework under Chapter VII ensure non-compliant products are stopped at the Union border. ### Article 4 Tasks (EU-Based Economic Operator) - Verify that EU declaration of conformity or declaration of performance and technical documentation have been drawn up; keep declaration at disposal of market surveillance authorities; ensure technical documentation can be made available upon request (Art. 4(3)(a)). - Following a reasoned request from a market surveillance authority, provide all information and documentation necessary to demonstrate product conformity in a language easily understood by the authority (Art. 4(3)(b)). - When having reason to believe a product presents a risk, inform market surveillance authorities (Art. 4(3)(c)). - Cooperate with market surveillance authorities; following a reasoned request, take immediate necessary corrective action to remedy non-compliance or mitigate risks when required by authorities or on own initiative (Art. 4(3)(d)). - Indicate name, registered trade name or trade mark, and contact details including postal address on the product or packaging/parcel/accompanying document (Art. 4(4)). ### Distance Sales (Online and Offline) - Products offered for sale online or through other distance sales are deemed to be made available on the market if the offer is targeted at end users in the Union (Art. 6). - An offer is considered targeted at end users in the Union if the economic operator directs its activities to a Member State by any means (Art. 6). - Information society service providers must cooperate with market surveillance authorities to facilitate action against products presenting risks offered for sale online (Art. 7(2)). ### Market Surveillance Authority Powers - Member States designate market surveillance authorities and confer powers to enforce Union harmonisation legislation (Art. 10, Art. 14). - MSA powers include: requiring documents/data/information (including access to embedded software); requiring supply chain and distribution network information; carrying out unannounced on-site inspections and physical checks; entering premises; starting investigations on own initiative; requiring economic operators to take corrective action; prohibiting/restricting making available, ordering withdrawal or recall; imposing penalties; acquiring samples (including under cover identity); reverse-engineering; requiring removal of online content or restricting access to online interfaces (Art. 14(4)). - MSAs exercise powers efficiently, effectively, and in accordance with the principle of proportionality (Art. 14(2)). - MSAs may reclaim costs of their activities from the relevant economic operator in instances of non-compliance (Art. 15). ### Market Surveillance Measures - MSAs take appropriate measures if a product is liable to compromise health or safety or does not conform to Union harmonisation legislation (Art. 16(1)). - MSAs require the relevant economic operator to take appropriate and proportionate corrective action within a specified period (Art. 16(2)). - Corrective action may include: bringing the product into compliance; preventing the product from being made available; withdrawing or recalling the product; warning end users; destroying the product (Art. 16(3)). - If the economic operator fails to take corrective action or the non-compliance or risk persists, market surveillance authorities ensure the product is withdrawn or recalled, or that making available is prohibited or restricted (Art. 16(5)). ### Products Presenting a Risk - Product presenting a risk means a product that could adversely affect health, safety, environment, public security, or other public interests to a degree beyond what is reasonable and acceptable (Art. 3(19)). - Product presenting a serious risk requires rapid intervention by MSAs (may include cases where effects are not immediate) (Art. 3(20)). - Where a market surveillance authority takes or intends to take a measure pursuant to Article 19 and considers that the reasons or effects go beyond its Member State, it notifies the Commission immediately (Art. 20(1)). - MSAs must take measures to prohibit or restrict making available of products presenting a serious risk, and where applicable order withdrawal or recall (Art. 19). - Economic operators must cooperate to eliminate or mitigate risks presented by products they made available (Art. 7). ### RAPEX (Rapid Information Exchange System) - When a market surveillance authority takes or intends to take a measure pursuant to Article 19 and considers that the reasons or effects go beyond its Member State, it notifies the Commission (Art. 20(1)). - If a product presenting a serious risk has been made available on the market, market surveillance authorities notify the Commission of any voluntary measures taken and communicated by an economic operator (Art. 20(2)). - Notifications include available details needed for identification of the product, origin and supply chain, risk, and the nature and duration of national measures (Art. 20(3)). - For Article 20 notifications, the Rapid Information Exchange System (RAPEX) provided for in Article 12 of Directive 2001/95/EC is used (Art. 20(4)). - The Commission maintains a data interface between RAPEX and the information and communication system referred to in Article 34 to avoid double data entry (Art. 20(5)). ### Union Safeguard Clause Procedure - The MSR is without prejudice to Union safeguard procedures under the applicable Union harmonisation legislation (Art. 11(9), Art. 16(6)). - National measures communicated under Article 16(5) are communicated through the information and communication system referred to in Article 34, and that communication is deemed to fulfil notification requirements for applicable safeguard procedures (Art. 16(6)). - Products deemed non-compliant by a decision of a market surveillance authority in one Member State are presumed non-compliant by authorities in other Member States unless a relevant authority concludes the contrary on the basis of its own investigation (Art. 11(9)). - Market surveillance authorities enter relevant safeguard-related information in the information and communication system, including objections raised by a Member State and subsequent follow-up (Art. 34(4)(e)). ### Customs Controls and Border Checks - Member States designate authorities to perform controls on products entering the Union market (Art. 25). - Designated authorities perform risk-based checks on products intended for release for free circulation, prioritising products presenting a serious risk or significant levels of non-compliance (Art. 25(3)). - Where designated authorities identify non-compliance or a serious risk, they immediately inform the market surveillance authority and suspend release for free circulation (Art. 26). - Where release for free circulation has been suspended, the product is released where the other requirements are fulfilled and either the suspension is not maintained within four working days, or approval is given by market surveillance authorities (Art. 27). - Where placing on the market is prohibited, MSA requires designated authorities not to release the product and to include notice on commercial invoice and in customs data-processing system (Art. 28). - Cooperation between customs and market surveillance authorities is critical to prevent non-compliant products from entering the Union market. ### Union Product Compliance Network (EUPCN) - The Union Product Compliance Network (Network) coordinates market surveillance activities and ensures consistent enforcement across Member States (Art. 29). - Network consists of representatives of market surveillance authorities, the single liaison offices, and the Commission (Art. 30(1)). - Network tasks include: developing best practices; facilitating cooperation and exchange of information; coordinating joint activities; developing work programmes; providing opinions; contributing to consistent application of MSR (Art. 31). - Administrative Cooperation Groups (ADCOs) established for sectors support the Network and coordinate market surveillance in specific sectors (Art. 30(2)). - Network decisions are legally non-binding recommendations (Art. 31(3)). ### Mutual Assistance and Information Sharing - Market surveillance authorities cooperate and exchange information across Member States (Art. 22(1)). - On a reasoned request for information under Article 22, the requested authority supplies relevant information without delay and in any event within 30 days (Art. 22(2)). - Where bringing non-compliance to an end requires measures within another Member State, an applicant authority may submit a reasoned request for enforcement measures, and the requested authority takes appropriate enforcement measures using Article 14 powers (Art. 23). - Requests and related communication use electronic standard forms via the information and communication system referred to in Article 34 (Art. 24(3)). - Evidence used by a market surveillance authority in one Member State may be used by authorities in another Member State without further formal requirements (Art. 11(6)). - Products deemed non-compliant by a decision in one Member State are presumed non-compliant in other Member States unless a relevant authority concludes the contrary on the basis of its own investigation (Art. 11(9)). ### Union Testing Facilities - Union testing facilities aim to enhance laboratory capacity and ensure reliable and consistent testing for market surveillance (Art. 21(1)). - The Commission may designate a public testing facility of a Member State or one of its own testing facilities as a Union testing facility for specific categories of products or specific risks (Art. 21(2)). - Union testing facilities are accredited in accordance with Regulation (EC) No 765/2008 (Art. 21(3)). - Designated Union testing facilities provide services solely to market surveillance authorities, the Network, the Commission and other government or intergovernmental entities (Art. 21(5)). - Union testing facilities can carry out testing at the request of market surveillance authorities, the Network or the Commission, provide independent technical or scientific advice to the Network, and develop new techniques and methods of analysis (Art. 21(6)). ### National Market Surveillance Strategies - Each Member State draws up an overarching national market surveillance strategy at least every four years (Art. 13(1)). - First strategy was due by 16 July 2022; first evaluation by 16 July 2024 (Art. 13(1)). - National strategy includes: information on occurrence of non-compliant products; priority enforcement areas; planned enforcement activities; assessment of cooperation with other Member States (Art. 13(2)). - Member States communicate their strategy to the Commission and other Member States via the information and communication system and publish a summary (Art. 13(3)). ### Penalties and Enforcement - Member States lay down penalties for infringements of the MSR and of the Union harmonisation legislation listed in Annex II that impose obligations on economic operators (Art. 41(1)). - Penalties must be effective, proportionate, and dissuasive (Art. 41(2)). - Member States notify the Commission of penalty provisions by 16 October 2021 and notify subsequent amendments without delay (Art. 41(3)). - Market surveillance authorities have the power to impose penalties in accordance with Article 41 (Art. 14(4)(i)). ### Joint Activities to Promote Compliance - MSAs may agree with other authorities or organisations representing economic operators or end users on joint activities to promote compliance, identify non-compliance, raise awareness, and provide guidance (Art. 9(1)). - Joint activities must not lead to unfair competition and must preserve objectivity, independence, and impartiality (Art. 9(2)). - MSAs may use information from joint activities in investigations (Art. 9(3)). - Agreements on joint activities must be made publicly available and entered in the information and communication system (Art. 9(4)). ### Information to Economic Operators - The Commission ensures the Your Europe portal provides easy online access to information on product requirements, rights, obligations, and rules under Union harmonisation legislation (Art. 8(1)). - Member States put in place procedures to provide economic operators, at their request and free of charge, with information on national transposition and implementation of Union harmonisation legislation (Art. 8(2)). ### Peer Reviews - Peer reviews are organised for market surveillance authorities to strengthen consistency in market surveillance activities (Art. 12). - The Network develops methodology and a rolling plan for peer reviews (Art. 12(2)). - Peer reviews cover best practices and relevant aspects related to effectiveness of market surveillance (Art. 12(3)). - Outcome of peer reviews is reported to the Network (Art. 12(4)). ## Possible Outcomes ### [RESULT] EU Manufacturer Art. 4(2)(a) - You are the economic operator referred to in Article 4 unless you have appointed an authorised representative to perform the tasks set out in Article 4(3) on your behalf. - Your contact details (name, registered trade name or trade mark, postal address) must be indicated on the product or packaging/parcel/accompanying document (Art. 4(4)). - You must perform the tasks in Article 4(3): verify EU declaration of conformity and technical documentation; provide information to market surveillance authorities; inform authorities if the product presents a risk; cooperate on corrective action. ### [RESULT] Authorised Representative is the Economic Operator Art. 4(2)(c) - The authorised representative is the economic operator referred to in Article 4. - The authorised representative must perform the tasks specified in the written mandate from the manufacturer, including Article 4(3) tasks. - The authorised representative's contact details must be indicated on the product or packaging/parcel/accompanying document (Art. 4(4)). ### [RESULT] Importer is the Economic Operator Art. 4(2)(b) - The importer is the economic operator referred to in Article 4. - The importer must perform the tasks in Article 4(3): verify EU declaration of conformity and technical documentation; provide information to market surveillance authorities; inform authorities if the product presents a risk; cooperate on corrective action. - The importer's contact details must be indicated on the product or packaging/parcel/accompanying document (Art. 4(4)). ### [RESULT] Fulfilment Service Provider is the Economic Operator Art. 4(2)(d) - The fulfilment service provider is the economic operator referred to in Article 4 with respect to the products it handles. - This applies only where no manufacturer, importer, or authorised representative is established in the Union. - The fulfilment service provider must perform the tasks in Article 4(3) and indicate contact details on the product or packaging/parcel/accompanying document (Art. 4(4)). ### [RESULT] Non-Compliant with Article 4 Product may not be placed on the market - Article 4(1) prohibits placing products on the market unless there is an economic operator established in the Union responsible for the tasks in Article 4(3). - Market surveillance authorities may prohibit the placing of the product on the market and require border authorities not to release it for free circulation. - Economic operators must cooperate with market surveillance authorities (Art. 7). ### [RESULT] Article 4 Does Not Apply Other MSR obligations may apply - Article 4 applies only to products subject to the legislation listed in Article 4(5). - Even if Article 4 does not apply, economic operators must cooperate with market surveillance authorities (Art. 7). - Distributors and other economic operators remain subject to obligations under Union harmonisation legislation applicable to the product and under general MSR provisions. ### [RESULT] Out of MSR Scope Product not subject to Union harmonisation legislation in Annex I - MSR applies only to products subject to Union harmonisation legislation listed in Annex I. - If your product is not subject to that legislation, MSR does not apply. - The MSR does not prevent market surveillance authorities from taking more specific measures as provided for in Directive 2001/95/EC (Art. 2(3)). ## MSR Timeline | Date | Event | Reference | | --- | --- | --- | | 2019-06-20 | Regulation (EU) 2019/1020 adopted by European Parliament and Council | Reg. (EU) 2019/1020 | | 2019-06-25 | MSR published in Official Journal (OJ L 169) | OJ L 169, 25.6.2019, p. 1 | | 2019-07-15 | MSR enters into force (20 days after publication) | Art. 44 | | 2021-01-01 | Articles 29-33 and 36 apply (Union Product Compliance Network and financing) | Art. 44 | | 2021-07-16 | MSR applies in full (including Article 4 on economic operator obligations) | Art. 44 | | 2022-07-16 | First national market surveillance strategy due | Art. 13(1) | | 2023-07-16 | Commission evaluation report on Article 4 implementation due | Art. 42 | | 2024-07-16 | First evaluation of national market surveillance strategies | Art. 13 | | 2026-12-31 | Commission evaluation of MSR and report to Parliament and Council (every 5 years thereafter) | Art. 42 | ## Compliance Timeline | Date | Event | Category | Reference | | --- | --- | --- | --- | | 2019-06-14 | Council Decision on Final Text | Legislative History | | | 2019-06-20 | Regulation Adopted | Legislative History | | | 2019-06-25 | Official Journal Publication | Official Publication | | | 2021-01-01 | Early Application of Certain Articles | Application Dates | | | 2021-02-25 | EUPCN Rules of Procedure Adopted | Network & Cooperation | | | 2021-03-05 | Article 4 Guidelines Externalized (Docsroom) | Commission Guidance | | | 2021-03-23 | Article 4 Guidelines Published in Official Journal | Commission Guidance | | | 2021-07-16 | Regulation Applies | Application Dates | | | 2021-10-16 | Member State Notification Deadline | Implementation Milestones | | | 2022-07-16 | First National Market Surveillance Strategy Due | Implementation Milestones | | | 2022-07-20 | Union Testing Facility Designation Procedures Adopted | Implementing Measures | | | 2022-07-21 | Union Testing Facility Procedures Published | Official Publication | | | 2023-07-16 | Article 4 Evaluation Report Due | Evaluation & Review | | | 2023-07-28 | Amendment (EU) 2023/1542 Published | Amendments | | | 2023-12-05 | Implementing Regulation (EU) 2023/2712 Signed | Implementing Measures | | | 2024-05-03 | Amendment (EU) 2024/1252 Published | Amendments | | | 2024-05-27 | Union Testing Facility Designated | Implementing Measures | | | 2024-05-29 | Union Testing Facility Decision Published | Official Publication | | | 2024-06-18 | Union Testing Facility Decision Enters into Force | Implementing Measures | | | 2024-07-16 | First Evaluation of National Strategies | Evaluation & Review | | | 2024-08-06 | Implementing Regulation (EU) 2023/2712 Applies | Implementing Measures | | | 2024-10-01 | Corrigendum to (EU) 2024/1252 Published | Amendments | | | 2026-12-31 | Commission Evaluation Due | Evaluation & Review | | | 2029-06-18 | Union Testing Facility Designation Review | Evaluation & Review | | **Event details:** - **2019-06-14 - Council Decision on Final Text**: Legislative procedure milestone noted in EUR-Lex timeline: decision of the Council of 14 June 2019 (and European Parliament position of 17 April 2019, not yet published in the Official Journal). - **2019-06-20 - Regulation Adopted**: European Parliament and Council adopt Regulation (EU) 2019/1020 on market surveillance and compliance of products. - **2019-06-25 - Official Journal Publication**: Regulation (EU) 2019/1020 published in Official Journal L 169 (25 June 2019). - **2021-01-01 - Early Application of Certain Articles**: Certain provisions of Regulation (EU) 2019/1020 (Articles 29, 30, 31, 32, 33 and 36) apply from 1 January 2021. - **2021-02-25 - EUPCN Rules of Procedure Adopted**: Rules of Procedure of the Union Product Compliance Network (EUPCN) adopted (document referenced with date 25 February 2021). - **2021-03-05 - Article 4 Guidelines Externalized (Docsroom)**: C(2021) 1461 guidance on practical implementation of Article 4 is externalized/published in the Commission Docsroom record metadata on 5 March 2021. - **2021-03-23 - Article 4 Guidelines Published in Official Journal**: Commission Notice 2021/C 100/01 on Article 4 implementation published (Document 52021XC0323(01)). - **2021-07-16 - Regulation Applies**: Regulation (EU) 2019/1020 applies from 16 July 2021. - **2021-10-16 - Member State Notification Deadline**: Member States must notify penalty provisions to the Commission by 16 October 2021 and promptly notify subsequent amendments affecting them. - **2022-07-16 - First National Market Surveillance Strategy Due**: Each Member State must draw up the first national market surveillance strategy by 16 July 2022. - **2022-07-20 - Union Testing Facility Designation Procedures Adopted**: Commission Implementing Regulation (EU) 2022/1267 adopted, specifying procedures for designating Union testing facilities under Regulation (EU) 2019/1020. - **2022-07-21 - Union Testing Facility Procedures Published**: Implementing Regulation (EU) 2022/1267 published in the Official Journal (OJ L 192, 21.7.2022, p. 21). - **2023-07-16 - Article 4 Evaluation Report Due**: By 16 July 2023, the Commission must prepare an evaluation report on the implementation of Article 4 (scope, effects, costs and benefits), accompanied where appropriate by a legislative proposal. - **2023-07-28 - Amendment (EU) 2023/1542 Published**: Regulation (EU) 2023/1542 was published in the Official Journal on 28 July 2023 (OJ L 191, 28.7.2023) and amends Regulation (EU) 2019/1020. - **2023-12-05 - Implementing Regulation (EU) 2023/2712 Signed**: Commission Implementing Regulation (EU) 2023/2712 signed on 5 December 2023 on transmitting information from national customs systems to the market surveillance information system. - **2024-05-03 - Amendment (EU) 2024/1252 Published**: Regulation (EU) 2024/1252 was published in the Official Journal on 3 May 2024 (OJ L, 2024/1252, 3.5.2024) and amends Regulation (EU) 2019/1020. - **2024-05-27 - Union Testing Facility Designated**: Commission Implementing Decision (EU) 2024/1456 adopted, designating a Union testing facility for eco-design and energy labelling under Regulation (EU) 2019/1020. - **2024-05-29 - Union Testing Facility Decision Published**: Implementing Decision (EU) 2024/1456 published in the Official Journal (OJ L, 2024/1456, 29.5.2024). - **2024-06-18 - Union Testing Facility Decision Enters into Force**: Implementing Decision (EU) 2024/1456 enters into force on 18 June 2024 (twentieth day after its publication in the Official Journal, as captured in the EUR-Lex timeline extraction). - **2024-07-16 - First Evaluation of National Strategies**: First evaluation of national market surveillance strategies should take place by 16 July 2024. - **2024-08-06 - Implementing Regulation (EU) 2023/2712 Applies**: Implementing Regulation (EU) 2023/2712 applies from 6 August 2024. - **2024-10-01 - Corrigendum to (EU) 2024/1252 Published**: Corrigendum to Regulation (EU) 2024/1252 published (OJ L 90589, 1.10.2024, p. 1), as recorded in the consolidated MSR regulation timeline. - **2026-12-31 - Commission Evaluation Due**: By 31 December 2026, the Commission must carry out an evaluation of Regulation (EU) 2019/1020 and present a report to the European Parliament, the Council and the European Economic and Social Committee. - **2029-06-18 - Union Testing Facility Designation Review**: The designation of the Union testing facility under Implementing Decision (EU) 2024/1456 must be reviewed by 18 June 2029 (and every 5 years thereafter). --- [Privacy Policy](https://www.sorena.io/privacy) | [Terms of Use](https://www.sorena.io/terms-of-use) | [DMCA](https://www.sorena.io/dmca) | [About Us](https://www.sorena.io/about-us) (c) 2026 Sorena AB (559573-7338). 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