Guide

Responsible person vs importer vs distributor

The three roles are not interchangeable. Here is who carries which obligation, and how to choose the right arrangement.

Updated 2026-10-22

The roles, in plain terms

The manufacturer makes the product. The importer places a third-country product on the EU market. The distributor makes an already-placed product available further down the chain. The responsible person is the EU-established party accountable for compliance and contact with authorities.

One company can hold more than one role, but the obligations do not disappear because the names overlap.

Who carries the liability

The responsible person must be able to show the technical file, act on safety issues, and respond to authorities. The importer must verify that the product meets the rules before placing it on the market.

A distributor has lighter duties but still must not make a product available if it knows it is non-compliant.

Common mistakes

Using a mailbox address with no ability to act, naming a party that is not established in the EU, or signing a mandate that does not cover the actual products.

Another mistake is assuming the marketplace is the responsible person. Platforms may collect the information, but they do not take over the manufacturer's obligations.

How to choose

Decide based on who can actually hold documents, respond to authorities, and make decisions about recalls. Then put the mandate in writing and make sure the label and listing match it.

If you sell through several channels, use one responsible person per legal entity and market, not a different name for every listing.

FAQ

Related requirements