If you're a Distributor — what's specific to your role
For: distributor
Tier: free+
Time: ~4 min
Why you'd do this
Distributor (Art. 3(7)) is the supply-chain role for any party making a high-risk AI system available on the EU market that is neither the Provider nor the Importer. 8 actionable obligations, all in Art. 24 + shared Art. 25 chain-responsibility. Lighter than Importer because you're not gatekeeping market entry — you're verifying the gatekeepers did their job.
Before you start
- Have visibility into Provider's CE marking + Importer's name + address on the system / its packaging — Distributor obligations are fundamentally about checking those exist
- Know the storage and transport conditions you maintain — Art. 24(2) makes you responsible for not degrading conformity through your handling
Step 1
Workflow 1 — Pre-distribution verification (Art. 24(1))
Before making a high-risk AI system available on the EU market, verify:
- The system bears the required CE marking
- It is accompanied by the EU declaration of conformity + instructions for use
- The Provider AND (where applicable) the Importer have complied with the obligations of Art. 16(b) (Provider name + trade name + address visible) and Art. 23(3) (Importer name + address visible)
Lighter than Importer's check — you confirm the markers exist, you don't audit the underlying conformity assessment.
Step 2
Workflow 2 — Storage + non-conformity escalation (Art. 24(2)-(4))
While the system is under your responsibility:
- Storage and transport conditions must not jeopardise the system's conformity (Art. 24(2))
- If you have reason to consider the system is not in conformity, you MUST NOT make it available until conformity is restored (Art. 24(3))
- Where the system presents a risk, immediately inform the Provider OR Importer AND the relevant national authorities, specifying the non-conformity + corrective measures taken (Art. 24(4))
On reasoned authority request, provide all information and documentation necessary to demonstrate conformity (Art. 24(5)).
Step 3
Workflow 3 — Recall participation
Per Art. 24(6), Distributors cooperate with authorities + Providers + Importers in any action taken to eliminate risks posed by systems they make available — including recalls and withdrawals.
Practical operational deliverables:
- A traceability log mapping which specific units of the system you distributed to which downstream customer (so a recall can reach them)
- A documented recall communication template + escalation list
- A pre-arranged channel with the Provider for receiving recall notifications
ComplianceLint's Art. 24 Human Gates questionnaire captures all three.
What can go wrong
- Provider goes out of business — who handles a recall? — Per Art. 25(1), if the Provider can no longer be reached, the obligation chain shifts: the Importer (if any) carries forward the corrective-action duty, then Distributors. Document the Provider's unreachability in writing before assuming the elevated obligation.
- You repackage the system or modify it before distributing — does that change your role? — Yes — per Art. 25(1)(b)/(c), substantial modification or rebranding can elevate you to Provider status with the full Provider obligation set. The dashboard's role multi-select lets you flag both; if in doubt, treat as Provider and run a full scan to surface the Provider-specific obligations you'd then owe.
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Last updated: 2026-04-30