Importer
A natural or legal person established in the European Union who places on the EU market a product with digital elements that bears the name or trademark of a natural or legal person established outside the Union.
Source citations
Regulation text
Article 3(16) of Regulation (EU) 2024/2847 defines an 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".
Key points
- Importers must be EU-established — a company outside the EU cannot be an importer; they would be the manufacturer or would need a separate EU importer
- The defining feature is that the product bears a non-EU manufacturer's name or trademark — the importer is not rebranding it
- If an importer does rebrand under their own name/trademark, they become the manufacturer (Art. 21)
- Importers have significant obligations under Art. 19, including verifying that conformity has been assessed, CE marking is present, and technical documentation exists before placing the product on the market
- Importers must keep a copy of the EU DoC for at least 10 years and ensure technical documentation can be provided to authorities on request