An importer is defined in Regulation (EU) 2019/1020 and in the General Product Safety Regulation as any natural or legal person established within the Union who places a product from a third country on the Union market. “Placing on the market” means the first making available of a product in the EU, so the importer is the first link in the EU supply chain for goods manufactured outside it. A Danish retailer buying directly from a manufacturer in China is an importer in this sense, even for a single consignment.
The obligations follow the model in Article R4 of Decision No 768/2008/EC: an importer may place only compliant products on the market, must verify that the manufacturer has carried out the conformity assessment, drawn up the technical documentation and the declaration of conformity, affixed the CE marking and identified itself on the product, must put its own name and contact address on the product or its packaging, must ensure that instructions and safety information are in the required language, must keep a copy of the declaration and be able to produce the technical documentation, and must act, inform the authorities and cooperate where a product presents a risk. Article 11 of the General Product Safety Regulation contains the equivalent list for consumer products.
Where the manufacturer is not established in the EU, the importer is normally also the economic operator responsible for the product under Article 4 of Regulation (EU) 2019/1020 and Article 16 of the General Product Safety Regulation. Under the 2024 Product Liability Directive the importer of a defective product from a non-EU manufacturer is liable for the damage it causes.