EU Market Surveillance Regulation deadlines and compliance calendar

These dates establish when the Regulation and its institutional duties applied. Except where a bullet says otherwise, they are not recurring deadlines for a manufacturer, importer, distributor, authorised representative, or fulfilment service provider.

The Regulation entered into force 20 days after its Official Journal publication and has applied generally since 16 July 2021. Articles 29 to 33 and Article 36, which concern the Union Product Compliance Network and related activities, applied earlier. Article 41 also set a one-time deadline for Member States to notify penalty provisions to the Commission.

Before first placement on the Union market, check whether the product is covered by one of the legal acts listed in Article 4(5). If it is, Article 4 requires an economic operator established in the Union to perform the Article 4(3) tasks. The operator may be an EU-established manufacturer, an importer where the manufacturer is outside the Union, a properly mandated authorised representative, or, only where none of those three is established in the Union, an EU-established fulfilment service provider handling the product.

Article 6 treats an online or other distance-sales offer as making the product available on the market when the offer targets end users in the Union. Targeting is assessed case by case. Dispatch destinations, offer or ordering languages, and payment methods can be relevant; mere website accessibility in a Member State is not enough on its own.

Record the date and time an authority request, suspension, decision, or order is received. Article 14 requires Member States to confer at least the listed investigation and enforcement powers, but national law determines whether an authority exercises a power directly, through another public authority, or by applying to a court.

Article 16 requires an authority that finds risk or non-compliance to specify a period for appropriate and proportionate corrective action. The Regulation does not set one standard number of days. Article 18 separately requires decisions and orders to state their grounds and identify available national remedies and time limits.

The following reviews are internal controls, not deadlines imposed by Regulation (EU) 2019/1020. Schedule them when a change could affect Article 4 coverage, product conformity, targeting of Union end users, documentation retrieval, or an open authority measure.

For each entry, record the trigger, product and market scope, responsible team, legal or internal basis, documents checked, decision, completion evidence, authority deadline if any, and the next product, listing, batch, or shipment affected.