We are a US orthopedic manufacturer using a third party logistics provider (3PL) in the EU to warehouse inventory, ship to our distributors and process loaner inventory. The 3PL would appear to meet the definition of importer per the MDR. The 3PL is placing devices from a third country on the Union market. They would thru their normal business processes add shipping labels and shipping documents to the shipments that would have fulfilled the requirements to identify the importer as required by the MDR. The 3PL is now telling me they can't be the importer and I must identify a 3rd party as the importer. They recommended an importer service provider https://www.luctormedical.com/eu-mdr-importer/. This seems like I am just setting up a 2nd EU authorized representative, so that the true importer doesn't have to register in Eudamed. Is this really what the authors of the MDR envisaged. It seems we are just creating a shell game to hide the identity of importers. What is the point of the importer if they can use a 3rd party to register. Their are no requirements in the MDR for the manufacturer to enforce this with the importer. Is the manufacturer responsible for ensuring the importer (who ever that really is???) acts appropriately per the MDR? This all seems like a shell game to me in order to hide the identity of importers. I now wonder if our EU authorized representative would agree to also serve as the importer, since they seem to do the same thing.