Article 23: Importer Obligations
Article 23 requires importers to verify, before placing a high-risk system on the EU market, that the provider has carried out the required conformity assessment and that technical documentation, CE marking, and the EU declaration of conformity exist. Importers must also ensure storage and transport conditions do not jeopardise conformity and must indicate their own contact details on the system or its documentation.
- 02 Dec 2027 Coupled to the Annex III high-risk applicability date
- 02 Aug 2028 For Annex I embedded high-risk systems
- Verify the provider's conformity assessment, technical documentation, CE marking, and EU declaration of conformity exist before market placement.
- Verify the provider has appointed an authorised representative where required.
- Ensure storage or transport conditions under the importer's control do not jeopardise the system's conformity.
- Indicate the importer's name, registered trade name or trademark, and contact details on the system, packaging, or accompanying documentation.
- Cooperate with market surveillance authorities, and take corrective action if the importer has reason to believe the system is non-conformant.
- Verification checklist of provider documentation
- Records of storage/transport conditions
"Importer" is often assumed to mean a logistics or customs company; under the AI Act it is a legal role — whoever places a non-EU provider's system on the EU market — regardless of who physically handles the goods.
Unsettled: The obligation content itself was not independently re-verified against the primary EUR-Lex text as amended; it is treated as unchanged in substance by the Digital Omnibus based on secondary-source confirmation.
What regulators published on Art. 23
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- Regulation (EU) 2024/1689 on EUR-Lex
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- Deadline changes and the acts behind them
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Get free accessInformational content only. Not legal advice and not a substitute for qualified counsel. Dates reflect Regulation (EU) 2026/1744 as of 04 Aug 2026.