The importer role in EU product compliance
The importer is the company established in the EU that places a product from a country outside the EU on the EU market. It does not make the product, but it must make sure the manufacturer did its part before the first unit is sold, add its own name and address to the product, and keep the documents for 10 years. If the product carries the importer's own brand, the importer is the manufacturer instead.
Free account · no card · opens in the Demo Company
Reviewed 5 October 2026 by the Conphora compliance team · Not legal advice
Am I the importer?
- Yes
Lamps bought from a maker in China and sold in the EU under the maker's brand
You are established in the EU and you are the first to make the product available here. The maker stays the manufacturer, and the importer's duties are yours. If the product was not designed or made for the EU market, you take on the manufacturer's role instead (Blue Guide, section 3.1).
- Yes
A webshop in the EU whose supplier outside the EU ships straight to the customer
Placing on the market means the first making available in the Union, not handling the parcel. A web shop established in the EU that buys from a supplier outside the EU and sells the product on the EU market places it on the market and is its importer, even though the goods never pass through its hands.
- No, you are the manufacturer
A toy you have made in China and sell under your own brand
Your name or trademark on the product makes you the manufacturer, whoever makes it (GPSR Article 13(1); Low Voltage Directive Article 10). You carry the manufacturer's duties, not the importer's.
See the manufacturer → - No, you are the distributor
Kitchenware bought from a wholesaler in another EU country
An importer places a product from a third country on the Union market. Buying inside the Union makes you a distributor, unless you use your own brand or substantially modify the product.
See the distributor →
What the law asks of you
The references name the General Product Safety Regulation (GPSR) and, as the example of a CE act, the Low Voltage Directive (LVD). For products under a product-specific harmonisation act, such as the Low Voltage or Toy Safety Directive, the GPSR's Chapter III, Section 1 (Articles 9 to 18) does not apply, and the act's own duties take its place (Article 2(1), third subparagraph, point (b)). The GPSR's safety requirement still covers risks the act does not (point (a)), and Articles 19 to 22, on online offers, accidents and online marketplaces, apply to all products, as do the recall rules in Articles 35 to 37. REACH restrictions and labelling rules do not take a product out of Articles 9 to 18. Whoever places on the EU market a product not designed for it, or a used product from outside the EU, takes on the manufacturer's role (Blue Guide, section 3.1); a used CE product resold inside the EU falls under the GPSR in full. The regulation guides list the article for each act.
Before the product is placed or sold
- Place only compliant products on the market. Before you do, make sure the manufacturer has carried out the risk analysis or conformity assessment, drawn up the technical documentation and marked the product; for a CE product, also that it bears the CE marking and comes with the required documents. GPSR Art. 11(1); LVD Art. 8(1) and 8(2)
- Do not place a product you have reason to believe is dangerous or non-conforming. Where it is dangerous, inform the manufacturer and make sure the market surveillance authorities are informed. GPSR Art. 11(2); LVD Art. 8(2)
On the product and in the offer
- Add your name, registered trade name or registered trade mark and your postal and electronic address (under the Low Voltage Directive, the postal address) to the product, or to the packaging or an accompanying document where that is not possible, without covering the manufacturer's information. GPSR Art. 11(3); LVD Art. 8(3)
- Make sure the product comes with instructions and safety information in the language determined by the Member State where it is made available. GPSR Art. 11(4); LVD Art. 8(4)
Records to keep
- Keep a copy of the technical documentation for 10 years after placing the product on the market. Under the Low Voltage Directive, keep a copy of the EU declaration of conformity for 10 years and make sure the technical documentation can be made available to the authorities on request. GPSR Art. 11(6); LVD Art. 8(8)
- Be able to say who supplied you and whom you supplied: for six years under the GPSR, for 10 years under the Low Voltage Directive. GPSR Art. 15; LVD Art. 11
While it is on the market
- While the product is under your responsibility, keep storage and transport from jeopardising its conformity. GPSR Art. 11(5); LVD Art. 8(5)
- Check that consumers can reach the manufacturer with complaints and provide a channel yourself if they cannot. Investigate complaints, keep the register and keep the manufacturer and the distributors informed. Under the Low Voltage Directive, sample-test marketed equipment where the risks warrant it. GPSR Art. 11(9) and 11(10); LVD Art. 8(6)
- Where the manufacturer is not established in the Union, you are the economic operator responsible for the product, for products under the GPSR and the CE acts listed in Article 4(5) of Regulation (EU) 2019/1020: under the GPSR, also check regularly that the product matches its technical documentation and carries the required identification, contact details and instructions. GPSR Art. 16(1) and 16(2); Regulation (EU) 2019/1020 Art. 4(2)(b), 4(3) and 4(5)
- When you offer the product online or at a distance, show in the offer the manufacturer, the responsible person where the manufacturer is outside the EU, the product identification with a picture, and the warnings. GPSR Art. 19
When something is wrong
- Under the GPSR, if a product you placed on the market is dangerous, at once inform the manufacturer, make sure corrective measures are taken, including withdrawal or recall, or take them yourself, make sure consumers are informed, and inform the market surveillance authorities through the Safety Business Gateway. GPSR Art. 11(8)
- Under the Low Voltage Directive, if equipment you placed on the market does not conform, at once take the corrective measures to bring it into conformity, withdraw or recall it; where it presents a risk, at once inform the national authorities where you made it available. LVD Art. 8(7)
- Tell the manufacturer without undue delay about an accident caused by a product you placed on the market. The manufacturer makes the notification through the Safety Business Gateway, or instructs you to make it. This duty applies to CE products too. GPSR Art. 20(3)
The importer is defined by what it does. Under the General Product Safety Regulation (EU) 2023/988, the importer is any natural or legal person established within the Union who places a product from a third country on the Union market (Article 3(10)); placing on the market is the first making available on the Union market (Article 3(7)). The Commission's Blue Guide describes the importer as more than a re-seller: it has a key role in guaranteeing that imported products comply, and its obligations build on the manufacturer's.[1][4]
For consumer products under the GPSR, Article 11 sets the list. Before placing a product on the market, the importer ensures that it meets the general safety requirement and that the manufacturer has drawn up the risk analysis and technical documentation and put the identifier and its contact details on the product. The importer adds its own name and addresses, ensures instructions and safety information in the required language, protects the product in storage and transport, keeps a copy of the technical documentation for 10 years, and investigates complaints and acts on dangerous products.[1]
For products covered by a CE act, Chapter III, Section 1 of the GPSR (Articles 9 to 18) does not apply (Article 2(1), third subparagraph, point (b)), and the act itself sets the importer's duties. Under the Low Voltage Directive 2014/35/EU, importers place only compliant equipment on the market; before doing so they ensure that the manufacturer carried out the conformity assessment, drew up the technical documentation and affixed the CE marking; they add their details, ensure the instructions, carry out sample testing where appropriate and keep the declaration for 10 years (Article 8). The GPSR's rules on online offers and accidents (Articles 19 and 20) and its recall rules (Articles 35 to 37) still apply to those products.[1][2]
Where the manufacturer is outside the Union, the importer is also the economic operator responsible for the product towards the authorities, for products under the GPSR and the CE acts listed in Article 4(5) of Regulation (EU) 2019/1020 (Article 4(2)(b); GPSR Article 16(1)). At the border, customs control products declared for release for free circulation and suspend the release where documentation, marking or the EU operator's details are missing (Regulation (EU) 2019/1020, Articles 25 and 26).[1][3]
What Conphora does for the importer
What the platform does today for a company in this role.
A supplier request to the manufacturer
One link asks the manufacturer for the declaration, the test reports and the technical documentation. What comes back is filed on the product with the sender's name.
The importer's steps, product by product
The product workspace sets the role for each product and lists the steps the importer carries under the regulations that apply to it.
One document when an authority asks
The documents filed on a product are assembled into one technical file, with the declaration of conformity, ready to send on a reasoned request.
Radar and recall
Compliance Radar reports changes in the rules and Safety Gate alerts for your product types, and the recall manager runs a recall from the first alert to closure.
Who you share with
-
Manufacturer
- You give
- Requests for documents, the markets you sell in, complaints and accident information.
- You receive
- The EU declaration of conformity; a copy of the technical documentation (GPSR) or, under a CE act, the assurance that it can be made available when an authority asks; test reports, instructions and safety information.
-
Distributor
- You give
- A product that carries the manufacturer's and your own name and address, with instructions in the market's language, and word of any safety issue.
- You receive
- Complaints, accident information and non-conformities found in the shop.
-
Online marketplace
- You give
- The information for each offer: the manufacturer, the responsible person, the product identification and the warnings.
- You receive
- Notices when an offer is removed, and cooperation when a product is recalled.
-
Market surveillance authorities
- You give
- The technical documentation, the declaration and the names of your supplier and your business customers, on request.
- You receive
- Reasoned requests, orders for corrective action, withdrawal or recall.
Regulations that bind the importer
Taken from the regulation guides: 48 acts name this role. The article numbers are those of the role's duties in each act.
- GPSR General Product Safety Regulation Art. 11, 15, 16, 19, 20
- BattR EU Batteries Regulation Art. 3, 41, 44, 46, 47, 48, 55, 56 …
- ELR Energy Labelling Framework Regulation Art. 1, 2, 3, 4, 6, 8, 9, 10 …
- FPR Fertilising Products Regulation Art. 8, 10, 11, 12
- IVDR In Vitro Diagnostic Medical Devices Regulation Art. 13, 16, 22, 27, 28
- MDR Medical Devices Regulation Art. 13, 16, 30, 31
- ErP Ecodesign Directive Art. 3, 4, 5
- PyroD Pyrotechnic Articles Directive Art. 7, 9, 12, 14, 15
- UAS UAS Regulation Art. 8, 10, 11
- RCD Recreational Craft Directive Art. 9, 11, 13
- RED Radio Equipment Directive Art. 12, 14, 15
- SPVD Simple Pressure Vessels Directive Art. 8, 10, 11
and 36 more in the regulation library · All regulation guides →
Problems people in this role ask about
Problem pages written for this role: 111 in all.
Questions about the role
Do we have to test every product we import?
No. The Blue Guide says the importer's checks do not imply a need to resort systematically to third-party testing, nor do they preclude it. Under the Low Voltage Directive, importers carry out sample testing of marketed products when deemed appropriate to the risks (Article 8(6)).
From when do the 10 years run?
From placing the product on the market (GPSR Article 11(6); Low Voltage Directive Article 8(8)). The Commission's Blue Guide reads this as the last item of the product model placed on the market, so the period keeps moving as long as you place new units of that model.
Do we need a mandate from the manufacturer?
No. The Blue Guide says the importer needs neither a mandate nor a preferential relationship with the manufacturer, but must make sure that contact with the manufacturer can be established. To carry out tasks on the manufacturer's behalf, the importer must be designated as authorised representative.
What is the difference between an importer and a distributor?
The distributor makes available a product that someone else already placed on the market and verifies the identifier, contact details, instructions and safety information (GPSR Article 12(1)). The importer places it first and must check the manufacturer's documentation itself (Article 11(1)).
Do importers have duties beyond product safety?
Often. An importer that places electrical and electronic equipment from a third country on a Member State's market on a professional basis is a producer under the WEEE Directive (Article 3(1)(f)(iii)). Importers of articles can also have REACH duties, such as passing on information on Candidate List substances above 0.1 % weight by weight (Article 33).
Is the importer liable for damage a product causes?
Liability for damage is a separate regime. Under the Product Liability Directive (EU) 2024/2853, which applies to products placed on the market or put into service from 9 December 2026, the importer is liable alongside a manufacturer established outside the Union, as national law transposing the directive provides (Articles 2(1) and 8(1)(c)(i)).
Sources
- Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026) EUR-Lex · accessed 5 October 2026
- Directive 2014/35/EU on electrical equipment (Low Voltage Directive), consolidated text of 30 May 2026 EUR-Lex · accessed 5 October 2026
- Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026) EUR-Lex · accessed 5 October 2026
- The 'Blue Guide' on the implementation of EU product rules 2022 (2022/C 247/01) European Commission, via EUR-Lex · accessed 5 October 2026
- Decision No 768/2008/EC on a common framework for the marketing of products EUR-Lex · accessed 5 October 2026
- Directive (EU) 2024/2853 on liability for defective products EUR-Lex · accessed 5 October 2026
About this page
- Reviewer
- Conphora compliance team
- Reviewed
- 5 October 2026
General information, not legal advice. Check the legal text or ask an adviser about your own product.
Conphora (2026). The importer role in EU product compliance. Retrieved 13 October 2026 from https://www.conphora.com/roles/importer/
Conphora (2026) The importer role in EU product compliance. Available at: https://www.conphora.com/roles/importer/ (Accessed 13 October 2026).
@misc{conphora2026theimporterroleineuprodu,
author = {Conphora},
title = {The importer role in EU product compliance},
year = {2026},
url = {https://www.conphora.com/roles/importer/},
note = {Retrieved 13 October 2026}
} The other roles
See it working before you add a product
The Demo Company is a complete, read-only example — products, documents, supplier requests and deadlines. Open it with a free account; no card, no trial clock.
Free account · no card · opens in the Demo Company