A marketplace suspended a listing because the certificate supplied with the product named a company the brand had never heard of. Nothing was wrong with the product and nothing was wrong with the report: the file belonged to a configuration held by someone else. Three arrangements are possible for holding that file, and the difference between them is decided long before the artwork is printed.
Charger certification: three ways the file can be held
The file can sit with the factory, with the brand as the responsible party, or with the brand as the applicant for its own configuration.
The three models differ in who is accountable, how quickly a product can be launched, how much the file costs and what the brand receives at the end. They are commercial arrangements around the same technical evidence, not different levels of quality.
Choosing between them is a decision about the channel rather than about engineering. A brand selling through its own web store has different obligations from one selling into a marketplace or a retail chain that audits documentation, and the model should be selected for the strictest channel in the plan.
Model 1: the factory holds the reports and the brand resells
The fastest and cheapest model, with the least protection for the brand.
The product is built on a platform whose reports are held by the manufacturer, the brand appears on the packaging, and the technical file stays with the factory. Launch is quick because nothing has to be re-tested, and the cost is limited to documentation. The exposure is that the brand cannot produce the file in its own name when a marketplace, a distributor or an authority asks for it, and the arrangement depends on the factory continuing to hold the reports and to answer for them.
Model 2: the brand becomes the responsible party
The usual middle arrangement for a branding programme.
The technical file is updated so that the brand is named as the responsible party on the finished product, using the existing test evidence for the configuration. The brand now holds the declaration, the reports and the label artwork, and can produce them on request. What does not change is the tested configuration: a new enclosure, a different coil or a changed component list is assessed against the evidence rather than covered by it.
Model 3: a submission in the brand’s own name
The most defensible model and the slowest one to reach the market.
The product is tested for the brand’s configuration, and the reports are issued to the brand. This suits a programme with its own enclosure, a specification that departs from the platform, or a channel that will not accept a file held by a third party. It carries the full test cost and the whole schedule, and it is the only model that removes the dependency on another company’s paperwork.
| Model | Who is accountable | What the brand receives | Speed | Cost | Fits |
|---|---|---|---|---|---|
| 1 Factory holds | The manufacturer | Documentation confirming the platform is covered | Fastest | Lowest | A first test of the market |
| 2 Brand responsible | The brand, on the tested configuration | Declarations, reports, label artwork | Moderate | Documentation and any review | Most branding programmes |
| 3 Brand submission | The brand, on its own configuration | Reports issued to the brand | Slowest | Full test programme | Audited channels and custom designs |
What changes when the brand name appears on the product
Responsibility follows the name on the marking, not the name on the purchase order.
Once the brand is the responsible party, the obligations that come with that role move to the brand: holding the technical documentation, keeping it consistent with the shipped revision, ensuring the marking is present and legible, and being able to answer questions about the product’s conformity. Those are documentation obligations rather than testing obligations, and they are what an audit will ask about.
Documents that transfer, and documents that do not
Some items move with the programme and some stay with the platform.
Test reports for the configuration, the declaration of conformity on the brand’s letterhead where applicable, and the label artwork with its revision transfer. The platform’s internal design files, its component qualification records and its other customers’ artwork do not, and asking for them is a different negotiation. Where the brand needs the design files, that belongs to a development agreement rather than to the certification pack.
How to price the three models against each other
Compare the total of documentation, test, schedule and risk rather than the invoice alone.
Model one looks cheapest until a channel asks for a file the brand cannot produce, at which point the cost of the alternative has to be paid at the worst possible moment. Model three looks expensive until it is compared with the cost of a delayed launch in an audited channel. Model two is usually the balance point, and the way to price it is to ask which review or update the existing evidence needs for the brand’s configuration, because that answer is what the documentation cost actually is.
FAQ
Is the factory’s certificate enough for our marketplace listing?
It depends on what the channel requires. Many marketplaces and distributors ask for documentation that names the responsible party for the product being sold, which is not the same as a certificate held by a manufacturer for its own platform. Many marketplaces and distributors ask for documentation that names the responsible party for the product being sold, which a manufacturer’s certificate does not do.
Does the brand need to repeat the tests to be the responsible party?
Where the tested configuration is unchanged, the existing evidence supports the product and the change is documentary. Where the enclosure, the coil or the component list differs, the difference is assessed, and the assessment may require testing. Where the tested configuration is unchanged the existing evidence supports the product, and where the enclosure or the component list differs the difference is assessed.
Can the model be changed later?
It can, and the cost of changing it later is higher than choosing it correctly at the start, because the brand inherits a configuration it did not test and has to evaluate the differences retrospectively, often against a deadline. The cost of changing the model later is higher than choosing it correctly at the start, because the brand inherits a configuration it did not test.
Who owns the reports when the brand pays for them?
Where the brand commissions the submission, the reports are issued to the brand and it holds them. Where the factory commissions them for the brand, the ownership and the right to use them should be stated in the purchase agreement rather than assumed. Where the brand commissions the submission the reports are issued to the brand, and where the factory commissions them the ownership is stated in the agreement.
Next step
Send the product configuration, the channels you sell through and the markets to Wecent Group through the contact page. The reply states which model fits the channel, what the documentation would contain and what would have to be re-tested for the brand’s own version. Related reading: charger quality control, charger manufacturing services and the factory floor. External references: EU CE marking rules, UK UKCA marking guidance, UK Office for Product Safety and Standards, US FCC Part 15 rules, UL standards and certification and TUV testing services.
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