Frequently Asked Questions about Hold Tech Files Services
What do we sell
- We sell EU based Secure Data Storage to non-EU machinery, vehicle and product manufacturers.
- We allow non-EU machinery manufacturers to use our details on their Declarations of Conformity as the person to 'compile' Technical Files in the EU. This will need to be an Authorised Representative from July 2021.
- We can act as Authorised Representative in the EU.
- We can verify that information in Technical Files or Documentation is adequate and sufficient.
Hold Tech Files Ltd is a company based in the Republic of Ireland that holds Technical Documentation on behalf of non-EU based manufacturing companies, within the EU.
For companies that need to sell to the UK as well, we can hold the files at our UK based subsidiary.
Costs
Maintain a Technical File for Ten Years, to allow the use of the Hold Tech Files name on a Certificate as a person to compile a Technical File = € 600.00 (Until July 16th 2021, then an AR is required).
To verify sufficient information there is a Technical File = € 500.00
Acting as Authorised Representative = both of the above plus € 300 per annum for ten years, or as long as the contract lasts, or for a one off fee of € 2,500.00 for a ten year period.
See terms and conditions and mandate.
Who do we sell to
The service is designed for all worldwide manufacturing companies who supply machinery and products into the European Economic Area, who need to store Technical Files or Documentation in the EU, so it can be made available to a reasoned request from authorities.
We can provide the name of a European National or Legal Person on the Declaration of Conformity as the person ‘compiling’[1] the Technical File, or act as an Authorised Representative in Europe[2].
I'm a UK Manufacturer, do I need to hold the file in the EU
If you're suppling machinery or other products into the EEA, you need an EEA based organisation to act as the person compiling the Technical File, who will make the file available to any Authorities that request it. The name and address need to be provided on the Declaration. Following Brexit, the UK will not be part of the EU and UK Manufacturers will require to have the files available in the EU.
Regulation EU 2019/1020 from July 2021 requires an importer, fulfilment centre or Authorised Representative.
Why do I need this service
Manufacturers of machinery are required to identify on their Declarations of Conformity or Incorporation, the name and address of a person within Europe to act on their behalf to ‘compile’ the Technical File for their machine, and provide the Technical File, on official request from a European enforcement agency.
If a manufacturer already has an Authorised Representative or office based in the EU, they will be able to fulfill this requirement, but manufacturers who do not have a relationship with a company based in one of the twenty-seven EU countries, can store their Technical Documentation with Hold Tech Files Ltd.
If the manufacturer does have an authorised representative in the EU, the manufacturer does not have to use them as a means of providing the Technical File to the European enforcement agencies. On occasion, Authorised Representatives represent more than one company or organisation, and may provide similar equipment, and so the manufacturer may not be comfortable in their Authorised Representative having access to the Technical File.
Can I display my Declaration on the website
Once the file is uploaded, you can allow your Declaration to be displayed on our site, this allows your potential customers to see that the Declaration is genuine. There is a tick box on the contract to allow you to do this.
Can I use your details on all my products Declarations
You need to pay a fee for each file provided to us. If you have three products that you want to use our details on, you would pay for three licenses. We hold the Technical File for each product and provide it to EU Authorities when required. We provide a unique identifier for files that we hold.
How do you verify a Technical File
To verify a file we check it to ensure that all information is provided in a suitable format. We provide a report to explain what complies and what does not, giving you the opportuity to update the file with more information if required. There is an additional fee for this service.
What happens if I don't provide the Technical File
Without a copy of the Technical File, we cannot provide it to the relevant Authorities. We would expect you to upload as much of the information you have at the time of agreeing the contract, and if incomplete, uploading the rest later. It is the manufacturers responsibility to ensure the information is available, not Hold Tech Files Ltd.
The Directive states that the Technical File does not have to be ‘readily available in material form’, what happens if we don’t have a complete file
It is correct that the Directive does allow manufacturers time to compile the Technical File, however, if we don’t have a copy, and you can’t provide it, then you cannot meet your requirements and your product may constitute sufficient grounds for doubting the conformity of the machinery with the essential health and safety requirements applied.
Use of this service is based on the manufacturer providing a Technical File to be uploaded at the time of buying the service.
What if I want to make changes
You can update the Technical File at any time, however there may be a small charge for this. All changes are logged to enable an Authority to see the process.
How long does the contract last
The contract to act as the person to compile the Technical File is for a ten-year period. At the end of this period, if it was for a one-off machine, the contract lapses. If it was for a series machine or if the machine has been updated significantly, the contract can be extended if required. Once the contract lapses, the file will not be available to Authorities.
What if I need an Authorised Representative
Hold Tech Files can act as Authorised Representative for your company. If we do this, we work with any Authorities to ensure that information is provided and is suitable. We do not have any responsibility for Sales, Service, Warranty or anything relating to the product. There is an annual fee for this service, and we must verify the file before acting as Authorised Representative.
To act as Authorised Representative, it is the manufacturers responsibility to ensure that the annual fee is paid, and the contract is still in place. Allowing the contract to lapse may result in products not beig allowed to be imported into the EU.
How does the process work
When you click the ‘Buy’ button you will be asked to enter basic information. This will produce a contract which will need to be accepted, and payment made. Preferred method is by credit card or PayPal, however if your company uses Purchase Orders, that is acceptable. You may not use our company details until payment has been cleared. You will receive an e-mail when you can use our details on your Declaration, we need a copy of all Declarations that you use our details on.
There is the opportunity to have your Declaration available to view on our website, to show that your product complies.
How long does the process take
Once you have paid the fee and uploaded the file, you can use our details on the Declaration. It can take a few minutes. It helps if the file is a single file in PDF format.
What about other Directives
Other Directives don't have a requirement for a person in the EU to compile the technical files, generally the manufacturer has to prepare and hold a Declaration, and make it available on request for the Authorities. We can hold the files and Declarations as required.
From July 2021 Regulation EU 2019/1020 requires an Authorised Representative, importer or fulfilment centre to undertake these tasks.
Begin the application HERE
[1] Compiling in this sense means making available to relevant authorities that may request it. There is no responsibility for the contents of the file by Hold Tech Files Ltd. This service will be overridden by the requirement for an Authorised Person from July 16th 2021, due to EU Regulation 2019/1020.
[2] Where Hold Tech Files acts an Authorised Representative, it is only to provide the Technical File or Documentation to the Authorities and work with them to explain the contents. When we carry out this service we will always verify the Technical File or Documentation to ensure the file is adequate.