Under the EU AI Act, an Importer is defined as any natural or legal person located or established within the European Union who places on the market or puts into service an AI system that bears the name or trademark of a natural or legal person established outside the EU.

The Importer serves as the critical "compliance bridge" or "anchor" for non-EU AI Providers. Since the original developer (the Provider) is outside the EU's direct jurisdiction, the Importer assumes legal responsibility for ensuring that the AI system entering the European market meets all necessary safety and fundamental rights requirements.

For High-Risk AI Systems, Importers have specific verification obligations under Article 23 before placing a system on the market. They must ensure that:

• Conformity Assessment: The appropriate conformity assessment procedure has been carried out by the non-EU provider.
• Documentation: The provider has drawn up the technical documentation, and the system is accompanied by the required instructions for use.
• Authorized Representative: The provider has appointed an authorized representative in the EU.
• CE Marking: The system bears the CE marking of conformity.
• Storage Conditions: While the AI system is under their responsibility, storage or transport conditions do not jeopardize its compliance.

Strategic Distinction: The Importer is distinct from a Distributor. A Distributor simply moves the product through the supply chain (e.g., a retailer). An Importer is the specific entity that first brings a non-EU product into the EU. Because they are the entry point, Importers face higher liability than Distributors but less than Providers—unless they market the product under their own name, in which case they legally become the Provider.