Martin Krüger is a product compliance attorney (advocaat product compliance) and managing partner at MAAK Advocaten in Amsterdam, the Netherlands.

He leads the firm’s Product Law team and serves as Product Law Officer of the International Bar Association (IBA). With more than 15 years of experience in European product regulation, Martin advises and litigates for manufacturers, importers, distributors and online platforms at the intersection of product regulation and compliance, product liability and enforcement proceedings before the Netherlands Food and Consumer Product Safety Authority (NVWA), the Netherlands Inspectorate for Digital Infrastructure (RDI), the Human Environment and Transport Inspectorate (ILT), the Labour Authority (Arbeidsinspectie), and other Dutch regulators. Clients describe him as analytical, sharp, tactical and approachable.

What makes Martin Krüger a unique product compliance specialist in the Netherlands?

Martin Krüger masters Product Law like few others in the Netherlands. His background combines strong knowledge of European directives, regulations and harmonised standards with tailored, practical advice. In addition, he draws on years of litigation experience before the Dutch courts and in administrative-law proceedings. Therefore, he is particularly effective: he translates complex technical regulation into concrete legal steps and then appears before the court or regulator himself when needed.

As Product Law Officer at the IBA, Martin has a worldwide network of specialised legal partners. Consequently, he handles cross-border questions on CE marking, PPWR, REACH or product liability across several markets at once. He also works closely with specialists in Dutch contract law and commercial litigation within MAAK Advocaten. As a result, his clients benefit from an integrated approach in which compliance, contracts and proceedings are managed consistently.

Martin advises in Dutch, German and English. Namely, he handles matters with a German or international character himself, without extra links in the chain.

Would you like to speak with him directly? Call +31 (0)20 210 31 38 or email martin.kruger@maakadvocaten.nl.

What is product regulation and compliance, and why is it indispensable for your organisation?

Product regulation and compliance (productregelgeving) is the legal duty to meet all applicable European and Dutch rules across a product’s entire life cycle: from design and production to market entry and end-of-life. Obligations include conformity assessment, technical documentation, CE marking, labelling requirements and post-market surveillance.

Enforcement pressure keeps rising structurally. More than 60% of non-conformity findings during market surveillance by the NVWA (Netherlands Food and Consumer Product Safety Authority) and the RDI trace back to incomplete technical documentation or a wrongly applied conformity-assessment procedure. Moreover, new European frameworks on digital products, cybersecurity, sustainability and chemicals keep arriving. Martin Krüger monitors those developments actively for his clients and helps them prepare in good time, so they do not lose market position.

Martin guides organisations in the automotive, mechanical engineering, life sciences, construction products, electronics and consumer-goods sectors. In particular, he acts for manufacturers, importers, distributors, online platforms and public authorities.

How does Martin guide the CE marking procedure step by step under EU and Dutch law?

CE marking is a legally required declaration of conformity by which manufacturers and importers demonstrate that a product meets all applicable European directives and regulations. It is not a quality label, but a legal statement by the responsible economic operator. Incorrect use or incomplete technical documentation leads to enforcement actions, sales bans and penalty payments by the NVWA or RDI.

Martin Krüger guides the CE marking procedure in six steps:

1. Determine the applicable directives: which European directive(s) and regulation(s) apply to your product, and in which markets?
2. Carry out the conformity assessment: also for products that require an independent Notified Body, such as machinery, medical devices and pressure equipment
3. Draw up the technical documentation: risk analyses, test results and construction files that withstand an NVWA inspection
4. Sign the EU Declaration of Conformity (DoC): legally correct and complete, so the declaration holds up during an enforcement action
5. Affix the CE marking: including labelling, digital marking requirements and QR obligations under new regulation
6. Implement post-market surveillance: proactive monitoring, reporting duties and support with corrective measures

The lead time is usually four to sixteen weeks, depending on product category and risk profile. Martin also advises on CE marking for innovative products and for products that fall under several regimes at once, such as the Machinery Regulation, the AI Regulation and the Battery Regulation.

When is a product recall mandatory, and how does Martin lead you through a crisis?

A product recall is mandatory as soon as a product poses a serious safety risk and corrective measures are insufficient to remove that risk. Under the General Product Safety Regulation (GPSR, EU 2023/988), a reporting duty applies to the competent authorities within four working days of identifying a serious risk. The NVWA or RDI can also impose a recall when the manufacturer or importer fails to act in time.

The financial impact is considerable. The figures below show why speed matters in the Netherlands and across the EU.

Timely, strategic legal guidance, however, limits financial loss, liability and reputational damage substantially in many cases. Therefore, Martin Krüger is directly available in a recall crisis and coordinates the entire process. His approach includes:

• Strategic planning and risk analysis in the first hours after the problem surfaces
• Direct notifications to the NVWA, RDI and competent authorities in every country involved
• Full legal crisis management, including communication alongside crisis-communication experts
• Legal support with reverse logistics, consumer-protection rules and sustainability requirements
• Management of liability claims arising from the recall
• Follow-up on RAPEX/Safety Gate notifications and EU market-surveillance coordination
• Damage limitation and reputation management before, during and after the recall

Are you facing a product recall? Every day counts. Call Martin Krüger straight away on +31 (0)20 210 31 38.

How does Martin protect your organisation against product liability under Dutch law?

Product liability (productaansprakelijkheid) is the statutory liability of a producer, importer or distributor for damage caused by a defective product. Under the revised Product Liability Directive (EU 2024/2853), damage caused by defective software, AI systems and integrated digital services now falls within this regime too. Every link in the chain can be held liable, even for damage that arises long after market entry.

Martin Krüger applies a preventive strategy. First, he identifies liability risks as early as the design phase. Next, he covers them contractually through supplier contracts, general terms and conditions and limitations of liability. Finally, he advises on the allocation of liability between manufacturer, importer and distributor. When a claim arises nonetheless, he coordinates the international defence strategy, manages technical and court-appointed experts, and litigates where necessary.

From the outset, his advice also factors in liability insurance and criminal-law risks. That integration prevents your organisation from being caught out after an incident.

Practical example: MAAK Advocaten acted successfully for a client in a REACH matter, where a competitor argued that the client wrongly refused to share registration costs and had infringed a registration dossier. Martin’s team argued that a valid opt-out registration with its own dossier applied and that no protected data had been used. The court dismissed all claims (ECLI:NL:RBAMS:2025:4436). In the proceedings on the merits (bodemprocedure), the court followed this defence in full and ordered the competitor to pay the legal costs (ECLI:NL:RBAMS:2025:6489).

Which REACH, RoHS and PFAS obligations does Martin handle for your organisation?

The REACH Regulation (EC 1907/2006), the RoHS Directive (2011/65/EU) and the fast-expanding PFAS restrictions from ECHA together form the heaviest chemical product-regulation framework in Europe. REACH requires manufacturers and importers that produce or import chemical substances of one tonne or more per year to register them with ECHA. In addition, communication duties apply to SVHC substances in articles. Many chain parties underestimate that obligation in practice.

RoHS restricts the use of ten specific hazardous substances in electrical and electronic equipment. PFAS regulation, moreover, is undergoing the most far-reaching shift in years: ECHA has proposed a universal restriction on more than 10,000 PFAS compounds. As a result, organisations in the textile, coating and medical-device sectors must fundamentally adjust their formulations and supply chains. Martin Krüger guides you on:

• Analysis of registration, communication and authorisation duties per substance and per chain role
• Assessment of RoHS conformity and support with technical documentation and test results
• PFAS exposure analysis and advice on transition strategies and substitution duties
• Contractual anchoring of REACH and RoHS obligations in your supply chain
• Assistance with enforcement actions by the NVWA, the ILT, the Netherlands Labour Authority or ECHA on chemical substances

How does Martin defend your organisation against enforcement actions by the NVWA, RDI or ILT?

In enforcement actions by Dutch regulators, a great deal is at stake — financially, but also for your reputation and market position. Martin Krüger represents companies in enforcement by the NVWA, the Dutch Authority for Digital Infrastructure (RDI), Customs, the Netherlands Labour Authority (NLA) and the Human Environment and Transport Inspectorate (ILT).

Dutch regulators have a broad arsenal of enforcement instruments. The table below sets out how Martin responds to each.

Above all, the message in every enforcement action is the same: have your position assessed as quickly as possible and limit reputational damage. The earlier Martin is involved, the more legal room there is to control the harm. Consequently, he determines the most effective approach with you, from constructive dialogue with the regulator to a decisive administrative-law procedure.

Regulators can, however, also be a strategic instrument. When a competitor structurally ignores product regulation and gains an unfair advantage, Martin guides your organisation in engaging the NVWA, RDI or ILT to restore a level playing field.

Are you facing an enforcement action by the NVWA, RDI or ILT? Contact Martin Krüger straight away on +31 (0)20 210 31 38 or at martin.kruger@maakadvocaten.nl. He is available at short notice and responds within one working day.

How does Martin help with breach of contract in the Dutch production chain?

Breach of contract (wanprestatie) in the production chain has different dimensions than in a standard trading relationship. A non-conforming product, a supplier that fails to deliver CE documentation, or a customer that files non-conformity claims: each situation touches contract law and product regulation at the same time. Martin Krüger masters both domains and therefore gives you complete advice in one pair of hands.

When a breach occurs, he analyses straight away which route is most effective: demanding performance, rescinding the agreement (ontbinding) or claiming damages. Where the interest is urgent, he starts summary proceedings (kort geding). For a final decision, he litigates in proceedings on the merits or in international arbitration at the NAI or the ICC.

How does Martin draft an agreement that strengthens your compliance position?

Drafting an agreement in the manufacturing industry requires knowledge of both contract law and the product regulation that applies to your products and supply chain. Martin Krüger combines that knowledge. He drafts contracts that are not only commercially watertight, but that also allocate compliance responsibilities across the chain clearly and limit your liability exposure.

Specifically, he drafts or reviews: supplier contracts with compliance obligations, distribution agreements with product-liability provisions, general terms and conditions with legally sound exoneration clauses, OEM contracts with IP protection and quality requirements, and ESG supply-chain contracts with due-diligence duties under CSRD and CSDDD. In addition, he advises on the termination of continuing agreements (duurovereenkomsten) in the production chain and the legal consequences for your compliance position.

What does legal advice on product compliance in the Netherlands cost?

The cost of product-compliance advice and proceedings depends on the complexity of the matter and the scope of the work. As a rule, Martin Krüger works on an hourly rate. In addition, MAAK offers the LAAP approach (Law As A Product): a fixed price per defined legal product, such as a CE marking review, a contract audit or a compliance scan of your supply chain. That way, your organisation knows the cost in advance.

Martin always discusses the cost transparently at the start. He weighs what proactive compliance guidance saves against the cost of an enforcement action, a product recall or a liability procedure. An introductory consultation is always free of charge. Call +31 (0)20 210 31 38 or email martin.kruger@maakadvocaten.nl.

Why do organisations choose Martin Krüger as their product compliance attorney in Amsterdam?

Martin Krüger is one of the most specialised product compliance attorneys in the Netherlands. His combination of more than 15 years of European product-regulation expertise, deep litigation knowledge, an international IBA network and multilingual service in Dutch, German and English makes him distinctive in his field. Namely, he advises not only on what the law requires, but also on what is strategically wise for your market position, your liability exposure and your business continuity.

Clients choose Martin because he is analytical, tactical and directly reachable. He explains complex product regulation in clear language, gives concrete advice and moves fast when a crisis or enforcement action demands it. Whether it concerns CE marking for a new product, a defence against an NVWA enforcement action, guidance on a product-liability claim, a REACH compliance question, or crisis management during a product recall — MAAK Advocaten in Amsterdam is ready to help.

Do you have a question about product compliance, product regulation or product liability in the Netherlands? Contact Martin Krüger for a no-obligation consultation. He responds within one working day and gives you clear advice straight away on your position and the approach that best fits your situation.