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EU AI Act Article 23: importer obligations for high-risk AI systems

Article 23 applies to importers — anyone established in the Union who places on the market a high-risk AI system bearing the name or trademark of a person established outside the Union.

What Article 23 requires

Before placing the system on the market, the importer must verify that the relevant conformity assessment procedure has been carried out by the provider, that the provider has drawn up the technical documentation, that the system bears the required CE marking and is accompanied by the EU declaration of conformity and instructions for use, and that a non-EU provider has appointed an authorised representative under Article 22. If the importer has reason to believe the system is non-conforming, presents a risk, or is falsified, it must not place it on the market until conformity is ensured, and must inform the provider, its authorised representative, and market surveillance authorities. The importer must also indicate its name and contact details on the system, its packaging, or accompanying documentation; ensure storage and transport conditions do not jeopardise conformity; and keep a copy of the certificate, instructions and EU declaration of conformity for ten years.

Who it applies to

Any EU-based entity bringing a high-risk system from outside the Union onto the EU market — including, in practice, resellers and platform operators who repackage a non-EU vendor's high-risk agent for EU customers.

What evidence this implies

The verification checks themselves need a record: what was checked, when, against which version of the documentation, and what was found. Ten years is a long time to keep that trail current and re-verifiable.

Gaps to state honestly

Article 23 is a gatekeeping duty performed before the system reaches the market — it does not extend to monitoring the system's ongoing behaviour, which sits with the provider under post-market monitoring and the deployer under Article 26.

How Vetro helps

An importer's ten-year record is only useful if it is still verifiable after ten years. Vetro's hash-chained, ed25519-signed ledger format is self-describing and checkable with a public key, independent of the original vendor's infrastructure. Vetro Attest verifies a ledger or OTLP GenAI trace for free, and issues a 49 USD counter-signed evidence report. Not legal advice.

See a sample ledger verified in one click, check your own logs free or get the countersigned EU AI Act report.