If you're an Importer — what's specific to your role
For: importer
Tier: free+
Time: ~4 min
Why you'd do this
Importer (Art. 3(6)) is a verification role: you check that the non-EU Provider's AI system is properly conformity-assessed and documented BEFORE you place it on the EU market under the Provider's trademark. 8 actionable obligations, all in Art. 23 + the shared Art. 25 chain-responsibility provisions.
Before you start
- Have the Provider's technical documentation, EU declaration of conformity, and CE marking visible — Importer obligations all depend on you having seen these BEFORE placing the system on the EU market
- Confirm whether the Provider has appointed an Authorised Representative (Art. 22) — Importer can be the same legal entity as the AR, but this needs to be explicit
Step 1
Workflow 1 — Pre-market verification (Art. 23(1))
Before placing a high-risk AI system on the EU market, the Importer must verify ALL of the following:
- The Provider has carried out the appropriate conformity assessment procedure (per Art. 43)
- The Provider has drawn up the technical documentation in accordance with Annex IV
- The system bears the required CE marking and is accompanied by the EU declaration of conformity + instructions for use
- The Provider has appointed an Authorised Representative (if non-EU)
If any check fails, you MUST NOT place the system on the market until the non-conformity is rectified. ComplianceLint's Art. 23 Human Gates questionnaire collects evidence of each check.
Step 2
Workflow 2 — Documentation retention (Art. 23(4))
Once you've placed the system on the market, you must:
- Keep a copy of the EU declaration of conformity for 10 years and make it available to authorities on request
- Indicate your name + registered trade name + address on the AI system, its packaging, or accompanying documentation
- Ensure storage and transport conditions don't jeopardise continued conformity
Same 10-year horizon as the Authorised Representative — your document store needs equivalent durability.
Step 3
Workflow 3 — Authority cooperation (Art. 23(7))
On reasoned request from a national competent authority, you provide all information and documentation necessary to demonstrate the system's conformity. You also cooperate with authorities on any action taken to eliminate risks posed by systems you've placed on the market.
If you have reason to consider a system is not in conformity with the AI Act, you must immediately inform the Provider, the Authorised Representative, and the relevant authorities — and where the system presents a risk, the relevant national authorities.
What can go wrong
- Provider's CE marking is on the system but no EU declaration of conformity reached you — Do NOT place the system on the market until the declaration is produced. Per Art. 23(2), the absence is sufficient grounds to withhold market placement. Request from Provider in writing; if non-response within reasonable time, refer to Art. 23(7) authority-cooperation duty.
- You're both Importer AND Distributor of the same system — which obligations apply? — Both. Per Art. 25, Importer obligations attach at first placement on the EU market; Distributor obligations attach on subsequent making-available in the supply chain. The ComplianceLint role multi-select lets you mark both — your dashboard view will union the two obligation sets.
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Last updated: 2026-04-30