ストレージ輸出のコンプライアンス文書：ターゲット市場別のファイル構成

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A storage export compliance documentation package is the set of market-specific files that lets a product be sold in a given country — and it is not one folder. At minimum, a B2B buyer should require five items for every SKU on the purchase order: a declaration of conformity, the EMC and safety test reports behind it, a RoHS declaration, a REACH statement, and the packaging and labelling declarations of the destination market. Because the package changes with the market and must match the exact model number, fix both the document list and the delivery milestones in the RFQ, before the quotation is finalised.

Shenzhen LingC Industrial Co., Ltd. (LingC) is a storage manufacturer based in Shenzhen, China, producing USB flash drives, TF memory cards, internal SSDs, portable SSDs, USB hubs and card readers from a 5,000 m² site. The framework below is what we would expect any professional buyer to apply — including to us.

What Actually Belongs in the Package

Buyers often ask for “the certificates” and receive a folder that mixes factory-level and product-level documents. Request each item by name.

The distinction matters: a management system certificate proves how the factory is run, while a product declaration proves something about one model for one market. One is not a substitute for the other.

Layering the Package by Target Market

Each market anchors on a different document. Confirm the exact scope of each item with your regulatory advisor before you quote — the notes below are orientation, not legal advice.

European Union

The declaration of conformity is the anchor. Under the EMC Directive 2014/30/EU the manufacturer self-declares and the test report is the evidence, so the DoC and the report travel together. RoHS and REACH statements, WEEE producer responsibility and EU packaging and packaging-waste requirements are separate obligations owned by the party placing the goods on the EU market. Confirm the current packaging reference at shipment.

United States

The anchor is FCC Part 15 Subpart B for an unintentional radiator, handled through the Supplier’s Declaration of Conformity route for a finished storage device. There is no single federal RoHS in the US, so a European RoHS declaration does not automatically answer a US request; state-level e-waste and labelling rules may apply, and California Proposition 65 labelling is a decision for the buyer and the importer of record. Other destinations, including Great Britain, follow their own marking and producer-registration steps.

Match Documents to the Model, Not the Brand

Product certification attaches to a model number and a destination market, so a “range approval” does not really exist. The common failure is a buyer approving a whole product line, then discovering late that only part of it carries the paperwork the market requires. Ask for the certificate list by model number and check it against your purchase order.

Within the LingC range, these models already carry CE / FCC / RoHS documentation:

For any model outside that list, the honest answer is the same: certification for this specific model can be arranged upon order confirmation. Before the quotation is signed off, review the full TF memory card range and confirm the document status of each model. Certificates and full test reports for documented models are available on request; the PS5005 portable SSD is an example of a documented mobile-storage SKU.

Fixing the Delivery Schedule and the Responsibility Boundary at RFQ Stage

The document set is useful only if it arrives in time, so tie each file to an RFQ milestone:

• At RFQ — a certificate list by model number, the management system certificate, and the datasheet for each quoted SKU.
• At sample approval — the approved sample signed and dated, plus the compliance documents for that exact sample configuration.
• Before mass production — written confirmation that the shipping housing, packaging and firmware match the documented build.
• With the shipping documents — a packed copy of the DoC and declarations, the packing list, and a reference HS code.

Then split ownership explicitly and write both columns into the RFQ so the gap does not appear at the port. The factory owns the product-level documents — the DoC, test reports, and RoHS and REACH statements for the models it manufactures. The buyer’s importer of record normally owns the market-side steps — producer registration, labelling decisions, and customs classification. Agreeing this boundary early prevents the late-stage dispute over who files what.

Frequently Asked Questions

Does one certificate cover an entire product line?

No. Product certification attaches to a specific model for a specific market, and a certificate listing one model does not extend to other models on the same line, even when they share a platform. Request the certificate list by model number and verify it against your purchase order.

Is RoHS a global requirement?

No. The EU RoHS Directive 2011/65/EU, as amended by (EU) 2015/863, is the reference most buyers cite, but the US has no single equivalent federal RoHS, so a European declaration does not automatically answer a US request. Confirm the required set per market.

Who is responsible for REACH and packaging documents on a private-label order?

The factory can supply the product-level REACH statement and the packaging declaration for the build it produces; registration and take-back duties that attach to the marketed product usually sit with the importer of record.

When should I request compliance documents in the sourcing process?

At RFQ stage, not after the order is placed. Requesting the certificate list and datasheet before the quotation is finalised lets you build the document schedule into the contract and exposes any model that still needs certification arranged.

Summary

Configure the compliance documentation package the way you configure the product: market by market, model by model. Confirm which documents lead in each market, keep factory-level and product-level files separate, verify every certificate against the exact model number, and write the delivery milestones and responsibility boundary into the RFQ.

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