Who becomes the importer when a robot comes from outside the EU

A purchase order does not usually feel like a legal role, and importing a machine from outside the European Union assigns one anyway, to whoever places it on the market.

Regulation (EU) 2019/1020 names the importer as whoever brings the product from outside the Union onto the EU market, and that is a role, not a label chosen by either side of the transaction.

Buy directly from a manufacturer or reseller outside the EU and the importer is whoever completes that first placement, which in almost every practical case is the buyer. Buy from a supplier who has already placed the machine on the Union market, and the obligation never reaches the buyer at all, because someone earlier in the chain already carries it.

What the importer role actually carries is three specific things: the conformity file, the technical documentation, and the correspondence with market-surveillance authorities.

None of these is paperwork that can be assembled after the fact if a question arrives; the file has to exist and be current from the point the machine is placed on the market, and the importer is the party a market-surveillance authority contacts first.

Article 36 of Regulation (EU) 2023/1230 adds a specific date to this: the Machinery Regulation becomes mandatory on 20 January 2027.

There is no harmonised European standard yet for a free-walking general-purpose humanoid, which makes the importer's own documentation the thing standing in for a standard that does not exist, rather than a formality layered on top of one that does.

None of this is a reason to avoid importing directly; it is a reason to know, before a purchase order is signed, which side of that placement decision the buyer is actually on. A supplier that has already placed the machine on the Union market takes the role with it. A direct import from outside the EU assigns the role to whoever signs, whether or not that was the plan.