Do I have to register complaints about my products?

Complaint register is a manufacturer obligation, not a seller obligation for everyone

Yes, anyone who qualifies as a manufacturer keeps a register of complaints about products and instances where a product was found not to meet safety requirements. That register does not stand alone: it is part of the same administrative system as the risk analysis and technical documentation for each product. Manufacturer is a broader concept here than most entrepreneurs expect. It is not only about who physically manufactures the product, but also about who places a product on the market under their own name or brand. A webshop that adds its own logo to a purchased product falls under that description, and the same applies to anyone who substantially modifies a product before it reaches the consumer. Those who consider themselves a distributor because there is no in-house factory involved may still bear the manufacturer obligations — including the complaint register.

A distributor who resells a product unchanged and under another party's brand does not need to keep this register itself. Different obligations apply to that role, such as verifying that the manufacturer and importer are compliant on their end, and passing on complaints received by the distributor to the manufacturer. For the manufacturer themselves, a registered complaint or a non-conformity signal is input to assess whether a problem is incidental or structural. What that assessment yields and whether it leads to a corrective action is up to the manufacturer and, where applicable, the competent authority.

Where this obligation stems from: Article 9 of the regulation

Article 9 of Regulation (EU) 2023/988 requires the manufacturer to keep a register of complaints about products and instances of non-conformity, and to keep distributors informed about them. This obligation applies directly and identically in all Member States, including the Netherlands, Belgium and Germany, where respectively the NVWA, the FOD Economie and the competent authorities of the Länder with the BAuA as coordination point supervise compliance.