CroatiaAct on the Requirements for the Accessibility of Products and Services, distributors of products
NN 89/2025, čl. 12., 13. i 35. 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 make available on the market a product listed in Article 3(1) in the course of commercial activity, act with due care in accordance with the Act (Art. 12(1); implements Directive (EU) 2019/882, Art. 10).
- Before making the product available, check that it carries the CE marking, that the necessary documents and the instructions and safety information in Croatian and Latin script accompany it, and that the manufacturer and importer met their identification duties under Article 9(6) to (8) and Article 11(4) (Art. 12(2)).
- If you consider or have reason to believe that the product does not conform, do not make it available until it meets the accessibility requirements, and inform the manufacturer or importer and the inspector (Art. 12(3)).
- While the product is your responsibility, do not let storage or transport conditions jeopardize its conformity (Art. 12(4)).
- If you consider or have reason to believe that a product you made available does not conform, take without delay the measures needed to bring it into conformity or withdraw it, and notify the competent national authorities of the Member States where you made it available, with details of the non-conformity and the measures taken (Art. 12(5) and (6)).
- If you make a product available 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 35(1) fines a distributor that is a legal person EUR 1,990.00 to EUR 13,270.00 for making available a product contrary to the requirements, without the CE marking or documents, without Croatian instructions, without the identification data, or that it should have held back; for not protecting conformity in storage and transport, 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 35(2) fines the responsible person in the legal person EUR 1,320.00 to EUR 6,630.00 and Article 35(3) fines a distributor that is a craftsperson or other self-employed natural person EUR 1,320.00 to EUR 6,630.00. The Act published in Narodne novine 114/2026 added to Article 35(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
- 1,990
- Currency
- EUR
- Fixed cap
- 13,270
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
- a distributor, a natural or legal person in the supply chain other than the manufacturer or importer that makes a product available on the market, of a product listed in Article 3(1) of the Act (Article 5, point 19; point 15 until )
What this law does
Article 12 requires a distributor to act with due care when making a product available, and before doing so to check the CE marking, the documents, and the instructions and safety information in Croatian and Latin script, and that the manufacturer and importer met their identification duties.
Article 12(3) to (6) requires a distributor to hold back a product it considers or has reason to believe does not conform, to protect conformity in storage and transport, to take corrective measures or withdraw a non-conforming product, and to notify the manufacturer or importer, the inspector and the national authorities. Article 35(1) fines a distributor that is a legal person EUR 1,990.00 to EUR 13,270.00 for the listed offences.
Article 35(2) and (3) fine the responsible person in the legal person, and a distributor that is a craftsperson or other self-employed natural person, EUR 1,320.00 to EUR 6,630.00.
When LexLint raises it
When your app profile says your app distributes a software product.
Back to the example · Lint your app
Page updated .