Distributor
A natural or legal person in the supply chain, other than the manufacturer or importer, who makes a product with digital elements available on the EU market without affecting its properties. Distributors have lighter obligations than manufacturers or importers, but still must verify CE marking and basic compliance before supplying products.
Source citations
Regulation text
Article 3(17) of Regulation (EU) 2024/2847 defines a distributor as:
"a natural or legal person in the supply chain, other than the manufacturer or the importer, that makes a product with digital elements available on the Union market without affecting its properties".
Key points
- The critical qualifier is "without affecting its properties" — as soon as a distributor modifies the product, they risk stepping out of this definition
- Distributors do not need to independently verify technical documentation or run conformity assessments — their core check (Art. 20(2)) is to verify CE marking is present and that the manufacturer/importer has complied with identification, instructions, and support period display obligations
- Distributors who rebrand or substantially modify a product become the manufacturer (Art. 21)
- Distributors must act with due care and not supply a product they have reason to believe is non-compliant
- Upon learning of a vulnerability in a product they have supplied, distributors must inform the manufacturer without delay