Dear Andrew,
To me the Importer is the one who will ... pay for the product and
then will sell it to the European distributors or "licensed"
companies. In other words it is likely to be the European MAH
(depends on the real organization of flows). This might also be the
place where the QP who releases the batches works, if it not a contracted QP.
Anyway the ultimate responsibility lies with the one "putting the
batch on the market" (but no necessarily certification because
certification is a technical and regulatory operation, not a
commercial operation.
Hope this will help.
JDM
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