Importer
The importer brings a product from a third country into the EU and checks whether the manufacturer has met its obligations. It is not liable for the product in the way a manufacturer is, but it must look closely before it sells.
An importer is anyone established in the EU who places on the market a product with digital elements bearing the name or trademark of a manufacturer outside the EU.
Definition in the Regulation
Article 3, point (16), of Regulation (EU) 2024/2847 defines the importer as "a natural or legal person established in the Union who places on the market a product with digital elements that bears the name or trademark of a natural or legal person established outside the Union". Its obligations are set out in Article 19. Paragraph 2 requires it to ensure three things before placing the product on the market: the conformity assessment under Article 32 has been carried out and the technical documentation drawn up. The CE marking, the EU declaration of conformity and the user information under Annex II accompany the product. And the manufacturer has provided its identification details, contact information and the end date of the support period. Paragraph 4 requires the importer's own contact details on the product or its documents. Paragraph 5 requires it to inform the manufacturer without undue delay when it becomes aware of a vulnerability and, where there is a significant risk, the market surveillance authorities as well.
What it means for manufacturers
For a manufacturer outside the EU, the importer is the first line of control: if the importer has reason to believe that the product does not conform, Article 19(3) prohibits it from placing it on the market. For a German wholesaler that sells industrial routers from Asia, for example, this means it must be able to see the certificates and documentation. If it sells the product under its own brand or substantially modifies it, it becomes the manufacturer itself under Article 21. The obligations of importers apply from 11 December 2027; under Article 64(3), infringements can be fined up to EUR 10 million or 2 per cent of total worldwide annual turnover.
Free templatesCRA Reporting KitReporting playbook, awareness record, notification templates for the ENISA platform, call chain and deadline calculator. Six Word templates, two Excel workbooks and a handbook, free by e-mail.Request the kit