Role under the Regulation
Importer
The gatekeeper role for products entering the EU market.
Importers are established in the Union and place on its market products bearing the name or trademark of a person established outside it, and the Regulation makes them the first checkpoint: they place only compliant products, and they verify that the manufacturer ran its conformity assessment, drew up the technical documentation, affixed the CE marking and can be identified F-012.
What the role really is
An importer is a verifier, not a bystander. The checks in Article 19 mean an importer who cannot show what it verified has a problem of its own, separate from the manufacturer's F-012. And the role can escalate: selling under your own name or trademark converts you into the manufacturer, with that role's full duty set F-106.
Boundary with distributors
A distributor makes products available in the supply chain without being their manufacturer or importer, and without affecting their properties; its checks are the lighter due-care set F-013. Which role you hold is a supply-chain fact, not a label you pick.
Verified facts this page relies on
- F-012 Importers place only compliant products on the market; verify conformity assessment, technical documentation, CE marking and manufacturer identification; indicate their own name and address; report known vulnerabilities to the manufacturer; keep the declaration of conformity; cooperate with authorities. Art. 19
- F-106 Marketing a product under your own name or trademark makes you the manufacturer even if someone else developed it. Art. 3(13), Art. 21
- F-013 Distributors act with due care; verify CE marking, declaration of conformity and manufacturer/importer obligations; do not make non-compliant products available; report vulnerabilities to the manufacturer; cooperate with authorities. Art. 20
Facts are maintained and human-verified in the CEMarque Facts Table (v2026.09.4, verified 2026-09-10).
Editorial review: Claude (AI reviewer, delegated by the editor), 2026-10-08. Methodology and correction process: how this site works.