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Can suppliers prepare the Technical file?

Yes, suppliers can prepare the Technical File, but you remain legally responsible for its accuracy.

The Supplier’s Role:

  • Provide Data: Suppliers usually generate the raw data, such as material test reports, component certificates, and user manuals.
  • Assemble the File: Many overseas suppliers (like factories in Asia) offer to compile these documents into a single package for you.

Your Legal Risk:

  • Ultimate Liability: In the US, Canada, and the EU, the importer or brand owner is legally responsible for compliance, not the foreign supplier.
  • Verification Required: If the supplier provides incomplete, fake, or outdated test reports, regulatory authorities will penalize your company, not the supplier.
  • Language & Updates: You must ensure the supplier-made file is in the correct language (e.g., English for the US/Canada) and updated whenever the product changes.
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