Role mapping is where many PSTI programs become inaccurate.
The regime imposes related but distinct duties on manufacturers, importers, and distributors, especially after a compliance failure appears.
Structured answer sets in this page tree.
Cited legal and guidance references.
The Act defines relevant persons to include manufacturers, importers, and distributors. Each role has its own entry duties, statement or deemed-compliance handling expectations, and post-market compliance-failure duties. Those duties should be reflected in contracts, playbooks, and incident response paths.
Manufacturers must comply with the relevant security requirements where the Act says the duty is engaged. They also control the statement-of-compliance position or, where applicable, the newer Schedule 2A deemed-compliance position for the UK market.
That means the manufacturer needs the strongest engineering and evidence link to the product itself.
Importers and distributors are not passive logistics roles under PSTI. For most products they must not make products available in the UK unless the statement or summary conditions are met, but sections 15(5) and 22(3) switch the check to satisfaction of the specified deemed-compliance conditions where a section 9(7) route applies. They also have action duties when compliance failures surface.
These checks should sit in onboarding, sourcing, and release-to-channel controls.
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