3. What about distributors of substances and mixtures?

If you use a distributor located in the EEA who purchases a substance from outside the EEA, the person responsible for the import may be that distributor or you. Only a case-by-case analysis can provide a definitive answer. Key factors include:

• the importer;

• the legal entity listed on the invoice;

• the ability to source supplies from outside the EEA;

• the address for the first delivery within the EEA.

For example:

• If you are unaware that your distributor sources the substance from outside the EEA, the importer may be the distributor as a natural person;

• If you have asked the distributor to purchase a substance that is not available...