A document is suspended: what the seller and the manufacturer should do

Mass checks of the evidence behind documents mean that a suspension is no longer a rare event. Most often an honest business suffers: it received the document through an intermediary and did not check what the document is based on.

What it looks like

First actions

• Open the register entry and record the reason and the date
• Stop shipping the goods covered by the document
• Remove or hide the listings until the status is restored
• Notify the corporate buyers who received batches
• Ask the body or the laboratory to explain the grounds
• Decide whether the cause can be fixed, and choose a path: restoration or a new document

What happens to goods that are already sold

Products put into circulation while the document was valid remain legal, unless there is a separate decision to withdraw them. But if the document is declared invalid from the moment of registration, the situation is different: it is considered that no conformity assessment was done at all, and a product recall may be required.

How to reduce the risk in advance

If you are a buyer of such products

Check the document status not only at the first deal but also before large purchases. It is worth adding a clause to the contract: the supplier must notify you of any change in the document status and compensate your losses if the goods turn out to have no valid proof of conformity.

How the register works and what the other statuses mean — in the article about electronic documents. What sanctions are possible if sales continued — in the review of liability.

What happens, day by day

Suspension, termination, invalidity

These are three different statuses. In conversation they are often mixed up, but their consequences are very different.

The difference between a suspension and invalidity is the key point. In a suspension, products released earlier remain legally released. When a document is declared invalid, all products released under this document are considered released without proof of conformity, and questions arise for the whole chain — including those to whom you shipped.

Why documents are suspended

The causes fall into two groups, and the amount of work depends on which group you are in.

• Procedural. An incomplete set of evidence, errors in the data, a test report outside the laboratory's scope of accreditation, an expired accreditation of the body. These are fixed by replacing or completing the documents.
• Substantive. The products do not meet the requirements found during the check. These require changes to the products themselves and repeat tests, and sometimes the withdrawal of a batch.

A separate cause is the termination of the accreditation of a body or a laboratory that took part in issuing the document. Formally you did not violate anything, but the document is in question, and you have to deal with it. We explained how to check counterparties in the register in a separate article.

What to tell counterparties

Silence works worst: the partner will see the status anyway and will assume the worst. Here is an order of actions that protects the relationship.

• Tell them first, before the counterparty sees it themselves
• State the reason directly: procedural or substantive — they are perceived differently
• Give a deadline for the correction and keep to it
• Say separately what to do with goods that are already shipped
• After restoration, send a confirmation with a link to the register entry

For marketplaces the scenario is harder: the listing is blocked automatically by the document status, and correspondence will not help — a valid document is needed. So when a document is suspended, you should also assess at once, in parallel with fixing the causes, whether it is faster to issue a new one.

How to restore the validity

1. Get and read the grounds — the specific items, not a general wording.
2. Divide the remarks into procedural and substantive: the first are closed with documents, the second with the products.
3. Collect what is missing: test reports, data, justifications.
4. Send the confirmation of the correction within the set period.
5. Wait for the status to change in the register and record it with a dated screenshot.
6. Send the confirmation to counterparties and marketplaces.

If the correction period is missed, the document is terminated, and only one way remains — to issue a new one. This takes longer than restoration, so it is better to react in the first days, not in the last.