Distributor
A distributor is any actor in the supply chain, other than the provider or importer, that makes an AI system available on the Union market without affecting its properties. Distributors carry a narrower, but not negligible, verification duty before and during distribution.
The concept is defined in Article 3(7), the obligations in Article 24. A distributor — typically a reseller, IT systems integrator or platform — must, before making a system available, verify that it bears the CE marking, that the required documentation and instructions for use accompany it, and that the provider and, where applicable, the importer have complied with their respective obligations. If the distributor has reason to believe the system is non-compliant, it may not make it available until conformity is ensured. A distributor's obligations are narrower than an importer's, since it is not the first to place the system on the Union market, but they persist during distribution: if it becomes aware that a system already on the market is non-compliant, it must take corrective action or arrange a recall. Among Hungarian SMEs this role typically arises for software resellers and systems integrators.
SME systems integrators and software resellers should consciously assess whether they act as distributors in a given transaction — this imposes a baseline verification duty before handing the AI product to the client.
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Start freeRelated terms
- ImporterAn importer is a person established in the Union that places on the market an AI system that bears the name or trademark of a third-country provider. Before placing it on the market, the importer must verify that the provider has carried out the conformity assessment and prepared the required documentation.
- ProviderA provider is a natural or legal person that develops an AI system or a general-purpose AI model, or has one developed, and places it on the market or puts it into service under its own name or trademark, whether for payment or free of charge. Providers bear the Regulation's most extensive package of obligations: risk management, data governance, documentation, conformity assessment, CE marking.
- Authorised representativeAn authorised representative is a person established in the Union and mandated in writing by a third-country provider to act on the provider's behalf towards Union authorities. A non-EU provider typically must appoint such a representative — as a condition of entering the Union market — before placing its system on the market.