§4.2 Importers

An importer is a natural or legal person established in the EU that places a product from a third country on the EU market (Article 3 of the Regulation). If there is an importer in the EU, it is in principle the economic operator referred to in Article 4, unless the manufacturer has appointed an authorised representative for the specific tasks under Article 4. Sector-specific legislation in general imposes on the importer obligations that overlap with and go beyond the obligations laid down in Article 4(3) (38). Again, an exception is that – unlike Article 4 – EU legislation on outdoor noise, machinery and ecodesign does not explicitly require importers to inform the market surveillance authorities where they have reason to believe that a product covered by such legislation presents a risk. Importers of products falling under that legislation and who are the economic operator referred to in Article 4 will however have to do this for the products covered by these legislative acts. The sector-specific provisions on indicating the importer’s name and contact details on or with the product are largely the same as for the manufacturer (see above). Therefore, only in exceptional cases does Article 4 require the importer who is the economic operator referred to in Article 4 to take the additional action of indicating its name and contact details. Where multiple importers handle the same type of product, each is the economic operator referred to in Article 4 for the units it has placed on the EU market and will have to ensure that its name appears on or with those units, as required. This is already the case under sector-specific legislation where there are multiple importers for the same type of product. An individual product should thus in principle only bear the name of the relevant importer.

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Source: EUR-Lex (Cellar) · retrieved 2026-09-07