The Cyber Resilience Act does not only concern manufacturers. Distributors and importers also have legal obligations. Ignoring these responsibilities can lead to financial penalties and marketing bans.

1. Importer Obligations

An importer is any person or entity established in the EU who places a product from a third country on the European market. Their obligations include:

  • Pre-verification: Ensure the manufacturer has carried out the conformity assessment procedure and prepared the technical documentation
  • CE marking: Verify the product bears CE marking and is accompanied by the EU Declaration of Conformity
  • Contact information: Indicate the importer's name and address on the product or packaging
  • Complaint register: Maintain a register of non-compliant products and recalls
  • Authority cooperation: Inform authorities in case of serious risk

2. Distributor Obligations

A distributor is any supply chain actor (other than manufacturer or importer) who makes a product available on the market. Their obligations:

  • Conformity check: Ensure the product bears CE marking and is accompanied by required documents
  • Storage conditions: Maintain product security conditions during storage and transport
  • Non-compliance: Do not market a product suspected of non-compliance
  • Traceability: Be able to identify suppliers and customers

3. Joint Liability

In some cases, importers and distributors may be held jointly liable with the manufacturer. If the manufacturer is not established in the EU or cannot be identified, the importer assumes full responsibility for product compliance.

4. How to Protect Yourself

  1. Audit your suppliers' CRA compliance before marketing their products
  2. Request EU Declaration of Conformity and technical documentation
  3. Use verification platforms like Expert CRA to check distributed product compliance
  4. Train your purchasing and sales teams on CRA requirements
Distributors and importers are not mere intermediaries. The CRA requires active verification. Protect your business by auditing your suppliers now.