reg 36 Cases in which obligations of manufacturers apply to importers and distributors
An importer or distributor (“A”) is to be considered a manufacturer for the purposes of these Regulations, and is subject to the obligations of the manufacturer under this Part, where A— (a) places pressure equipment or an assembly on the market under A's own name or trademark; or (b) modifies pressure equipment or an assembly already placed on the market in such a way that it may affect whether the pressure equipment or assembly is in conformity with Part 2.