AI importer and distributor

An importer (Article 3(6)) is an EU-based party that places on the market an AI system bearing the name or trademark of a company established outside the EU. A distributor (Article 3(7)) is any other intermediary making it available on the market, such as a reseller or integrator.

For high-risk systems, both must check before selling that the provider has carried out the conformity assessment, that technical documentation exists, that it bears the CE marking and EU declaration of conformity, and that it comes with instructions for use. If in doubt, they must not market it, and they must cooperate with authorities (Articles 23 and 24).

Beware: an importer or distributor that puts its own brand on the system or substantially modifies it becomes a provider, with all the obligations that entails.