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MachineryComplianceTHE WORKSHOP MANUAL

PLATE 06 OF 20

Economic operators.

Who carries which obligations in the supply chain, and when a role changes.

PILLAR Manufacturer, importer and distributor: who does what?GUIDES 10REVIEWED 27 October 2026

Pillar guide

Manufacturer, importer and distributor: who does what?: Map the legal role to the supply chain. Product branding, own use and modifications can change who carries manufacturer obligations.

Supporting guides

GuideWhat it covers
Manufacturer duties under Article 10Design, documentation, assessment, declaration, marking, identification, instructions, series conformity, and corrective action.
Importer duties under Article 13Checks on manufacturer conformity work and documents for products from a third country.
Distributor duties under Articles 15 and 16Due care and relevant checks for distributors, distinct for complete and partly completed products.
The authorised representative and its mandateA written mandate for specified tasks, and the obligations a mandate cannot transfer.
When branding changes the roleMarketing under your own name or trademark can make an importer or distributor carry manufacturer obligations.
When modification changes the roleModifying a product already placed on the market in a way that may affect compliance can change who is manufacturer.
Mapping roles across a supply chainA role map that names manufacturer, importer, distributor, and representative for each product, not each company in general.
Own use and operator rolesManufacturing for own use, and how operator duties apply when the manufacturer is also the user.
Corrective action across operatorsHow manufacturers, importers, and distributors each act when a product presents a risk, and who coordinates.

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