Economic operator responsibilities - when the Importer is also Distributor - Article 13

#1
I hope that some of you might be willing to provide your insight into an issue I am trying to explain to our MDR team internally.

The issue surrounds Economic Operators in EU and the requirement to place the Importers information either on the product or a document accompanying the product. Since the requirement is an obligation of the Importer, my interpretation is that this takes place on the document accompanying the product originating from the importer and goes to the distributor (or a label the importer may apply). However, the issue arises when, in this case, the importer is also the distributor.
1. Would the requirement to provide the information to the distributor not be required In this situation since they are both Importer and Distributor?
If the requirement still exists, who is responsible for applying the information? Manufacturer?

2. I have interpreted the "document accompanying the product" to be a shipping document, due to information provided at a few webinars on EOs, however has anyone interpreted this as something different (i.e. an IFU)?
 
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