Medical-device importer or distributor: compare the MDR handoff
MDR Articles 13 and 14 describe different checks and follow-up duties for importers and distributors. Build the project around the actual supply-chain role, declarations, labels, UDI where applicable, storage controls and complaint escalation. A freight or customs contract does not by itself establish the MDR role.
Evidence retrieved 2026-10-06. Source versions and topic-specific limits are listed below.
Sourced criteria · EU
What changes the service scope?
Decision or task
What the source describes
What to prepare
What is checked before supplying?
Article 13(2) lists importer checks including CE/declaration, identified manufacturer/representative, labels/instructions and applicable UDI. Article 14(2) lists distributor checks and permits representative sampling for specified items. [1][2]
Create separate importer and distributor checklists; document which sampling provisions actually apply.
Whose contact goes with the device?
Article 13(3) specifies importer name and contact information, without obscuring manufacturer information; Article 14(2)(c) asks distributors to check this for imported devices. [1][2]
Compare packaging and accompanying-document examples with the importer-identification requirement.
Who controls storage and transport?
Articles 13(5) and 14(3) address conditions while devices are under the respective operator’s responsibility. [1][2]
Allocate storage, transport, deviations and evidence access by actual custody stage.
How do incidents and nonconformities move?
Both articles describe notification/cooperation and complaint or recall/withdrawal records, with role-specific details. [1][2]
Agree who logs, forwards, investigates and supplies authority information; retain each operator’s responsibilities.
The definition of the buyer’s actual actor role and the applicable device regime remain unresolved. This comparison is MDR-specific and does not establish customs importer-of-record obligations.
A scoped evidence and handoff plan
Use this checklist to gather your business or product details before speaking with a specialist. The items below explain what to record and suggest useful supporting documents. You can add your own answers in the editable project brief.
What is checked before supplying?
Create separate importer and distributor checklists; document which sampling provisions actually apply.
Useful evidence: Supply-chain map, declarations, representative details, labels/IFU and UDI records.
Whose contact goes with the device?
Compare packaging and accompanying-document examples with the importer-identification requirement.
Useful evidence: Label artwork, importer identity/address and change control.
Who controls storage and transport?
Allocate storage, transport, deviations and evidence access by actual custody stage.
Useful evidence: Manufacturer conditions, transport/storage records and deviation escalation.
How do incidents and nonconformities move?
Agree who logs, forwards, investigates and supplies authority information; retain each operator’s responsibilities.
Useful evidence: Complaint/recall registers and a manufacturer–representative–importer–distributor escalation matrix.
Work packages and dependencies
Conditional: Supply-chain role and evidence-handoff assessment — For this work package, agree the supported criteria, evidence access, covered entities/products and unresolved facts in the table above. Additional services require their own justified scope.
Questions for providers
Which exact actor, product or processing facts support the quoted scope, and what is still unresolved?
How will the listed records reach the responsible people, and who owns each change or authority request?
Which tasks and entities are excluded from the agreement, and which additional services need a separate assessment?
Sources and data dates
Read the official document in context. The audit details identify the precise locators and preserved versions used for this page.