Distributor

A Distributor is a specific type of Economic Operator in the EU supply chain. Unlike an Importer, who brings goods into the EU for the first time, a distributor acquires machinery that has already been placed on the market and makes it available for further distribution or use. For North American manufacturers, your European dealers or resellers often fall into this category depending on the shipping terms agreed upon.

While they have fewer obligations than manufacturers, distributors are not exempt from responsibility. They must act with "due care," strictly verifying that the machinery bears the CE Mark, is accompanied by the correct documents—specifically the Declaration of Conformity (DoC) and manuals in the correct language—and that the manufacturer details are visible.

Crucially, if a distributor modifies the machinery—changing its safety functions or re-branding it under their own name—they legally become the manufacturer. This shifts the full burden of the Conformity Assessment and Technical File creation onto them, a critical detail to define in your partnership agreements.