We sell software for cash register systems, but not cash register drawers and printers. Who has to submit a product declaration?

As a producer or importer of software, you must submit a product declaration. In such a case, the declaration will mean that the software makes it possible to fulfil the requirements linked to cash register drawers and printers after these devices have been connected. The Directorate of Taxes will issue more detailed guidelines for the way in which the declaration must be provided in cases where the producer or importer does not supply both hardware and software.

Section 2e of the Cash Register System Act defines a supplier of cash register systems as follows:

“manufacturer or importer which, either directly or through a distributor, offers cash register systems for sale, lease or loan to an enterprise with a bookkeeping obligation as referred to in Section 1, and distributors and others which modify cash register systems for an individual enterprise with a bookkeeping obligation”

In the first instance, it will therefore be manufacturers and importers who will provide product declarations, but “others who modify cash register systems for those who are required to keep accounts” may also be obliged to provide product declarations for the modifications that they have made.