CroatiaAct on the Requirements for the Accessibility of Products and Services, importers of products
NN 89/2025, čl. 11., 13. i 34. Zakona o zahtjevima za pristupačnost proizvoda i usluga
In force since .
An accessibility requirements rule binding public and private bodies.
What it requires
- If you import into the European Union a product listed in Article 3(1) from a third country, place on the market only a product that meets the accessibility requirements of Annex I (Art. 11(1); implements Directive (EU) 2019/882, Art. 9).
- Before placing the product on the market, check that the manufacturer carried out the conformity assessment of Annex IV, drew up the technical documentation, affixed the CE marking, supplied the necessary documents, and gave its identification and contact information as Article 9(6) to (8) requires (Art. 11(2)).
- If you consider or have reason to believe that the product does not conform, do not place it on the market until it meets the accessibility requirements, and inform the manufacturer and the inspector (Art. 11(3)).
- Show your name, registered trade name or registered trade mark and a contact address, with the contact details in Croatian and Latin script, on the product, or where that is not possible on the packaging or an accompanying document, and attach instructions and safety information in Croatian and Latin script (Art. 11(4) and (5)).
- While the product is your responsibility, do not let storage or transport conditions jeopardize its conformity (Art. 11(6)).
- Keep a copy of the EU declaration of conformity for five years for the inspector and make sure the technical documentation can be made available to the inspector on request (Art. 11(7)).
- If you find, or have reason to believe, that a product you placed on the market does not conform, take without delay the measures needed to bring it into conformity or withdraw it; if it does not meet the accessibility requirements, tell the competent national authorities of the Member States where you made it available, with details, and keep a record of non-conforming products and related complaints (Art. 11(8) and (9)).
- If you place a product on the market under your own name or trade mark, or modify a product already on the market so that conformity may be affected, you are treated as the manufacturer and carry the manufacturer's duties under Article 9 (Art. 13).
- The accessibility requirements apply only so far as compliance needs no fundamental alteration of the product and imposes no disproportionate burden, assessed against Annex VI, documented, and notified to the market surveillance authority where you rely on the limit (Art. 17(1) to (5) and (8)).
These lines are LexLint's reading of the law's text.
If you get it wrong
Penalty structure
Article 34(1) fines an importer that is a legal person EUR 3,310.00 to EUR 66,360.00 for placing on the market a product that does not meet the requirements, that has had no conformity assessment or technical documentation, that lacks the CE marking, documents or identification data, or that the importer should have held back; for not showing its name and address, not attaching Croatian instructions, not protecting conformity in storage and transport, not keeping the EU declaration for five years, not correcting, withdrawing or notifying, not cooperating with the inspector, not documenting or keeping the Article 17 assessment, and not complying with an enforceable decision of the inspector under Article 23. Article 34(2) fines the responsible person in the legal person EUR 1,990.00 to EUR 6,630.00 and Article 34(3) fines an importer that is a craftsperson or other self-employed natural person EUR 1,990.00 to EUR 6,630.00. The Act published in Narodne novine 114/2026 added to Article 34(1) the offences of not giving the inspector the supply-chain information of Article 14(1), not keeping it for five years, not giving a copy of the Article 17 assessment or its facts on request, relying on the disproportionate-burden limit while funded to improve accessibility, and not notifying the market surveillance authority of reliance on Article 17. The offences are misdemeanours (prekršaj). Under Article 28(3) the inspector, no later than 15 days after the inspection ends or the deadline set in a written order expires, files an indictment proposal to start misdemeanour proceedings or issues a misdemeanour payment order (prekršajni nalog). Under Article 28(1) the inspector does neither, except where the same offence is found again, if the operator removes the irregularities during the inspection, complies with the decision made, or undertakes by a statement on the record to remove irregularities for which no administrative measure is prescribed within a set time.
- Rule
- Fixed only
- As of
- Minimum
- 3,310
- Currency
- EUR
- Fixed cap
- 66,360
Who enforces it
Enforcement body
Electronic communications inspectors of the Croatian Regulatory Authority for Network Industries (HAKOM) for products that are radio equipment, and market inspectors of the State Inspectorate (Državni inspektorat) for all other products covered (Art. 22(2) and (3))
What it reaches
Instrument type
an act of a legislature
Applicability criteria
- As of
- Combinator
- Any of
- Criteria
- an importer, a natural or legal person established in the European Union that places on the market a product from a third country, of a product listed in Article 3(1) of the Act (Article 5, point 18; point 14 until )
What this law does
Article 11 requires an importer to place on the market only a product that meets the accessibility requirements, and before doing so to check that the manufacturer carried out the conformity assessment, drew up the technical documentation, affixed the CE marking and supplied the documents and the identification information.
Article 11 requires an importer that considers or has reason to believe a product does not conform to hold it back until it conforms and to inform the manufacturer and the inspector.
Article 11(4) to (9) requires an importer to put its own name and address on the product, to attach instructions and safety information in Croatian and Latin script, to protect conformity in storage and transport, to keep a copy of the EU declaration for five years and the technical documentation available, to take corrective measures or withdraw a non-conforming product, and to notify the authorities and keep a record of non-conforming products and complaints.
Article 13 treats an importer or distributor as a manufacturer, with the manufacturer's duties of Article 9, when it places a product on the market under its own name or trade mark or modifies a product already on the market so that conformity may be affected. Article 34(1) fines an importer that is a legal person EUR 3,310.00 to EUR 66,360.00 for the listed offences.
Article 34(2) and (3) fine the responsible person in the legal person, and an importer that is a craftsperson or other self-employed natural person, EUR 1,990.00 to EUR 6,630.00.
When LexLint raises it
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