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ActorIn forcev1.0.0

Importer

You are an importer as soon as you, from within the EU, first place an AI system on the Union market that bears the name or trade mark of a party established outside the EU. What counts is not your purchasing role but whose brand is on the system and who first brings it to market.

The official source remains authoritative. This is general information about obligations and not legal advice. See this object on the map

Address and citation

This object has an address of its own that is never renamed or reused. Store the identifier in your own file, not the title or the link.

Identifier
praxikon:eu:ai-act:actor:importer
Payload hash (sha256)
152e324e4109e7ad2b10c910c623deef18e05cca1f165166aa94f4f3b3a58f89

Citation line

Praxikon, "Importer", praxikon:eu:ai-act:actor:importer@1.0.0, dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.2.0 (schema 1.5.0), effective_at 2026-08-08T00:00:00.000Z, known_at 2026-09-06T00:00:00.000Z, sha256 152e324e4109e7ad2b10c910c623deef18e05cca1f165166aa94f4f3b3a58f89
Version
1.0.0
Legal time (effective_at)
8 August 2026
Knowledge time (known_at)
8 August 2026
Closed on
Not closed
Topics
value-chain

Review status: Editorially reviewed (8 August 2026). Next check due by 4 February 2027. The check date is the knowledge date of this version; no later recheck has been recorded.

What this object links to

Every relation appears below as a path: from the source with its locator, through the conditions and exceptions of the object carrying the relation, to the consequence. A locator belongs to a statement in the data and not to a relation, so the source is the source anchor of the carrying object.

On this time pin this object has no relations that resolve.

What points at this object

Duties resting on this role

1 of 1 shown

The duty rests on this role. A supervisory authority addresses this role when it is not met.

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 23(1)-(7)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    • Condition | allApplies to importers of high-risk AI systems. For the standalone Annex III route (Article 6(2)) the date is 2 December 2027; for the embedded Annex I route (Article 6(1)) the date is 2 August 2028.
    • ExceptionIf you put your own name or trade mark on the system, substantially modify it, or change the intended purpose so that it becomes high-risk, Article 25(1) treats you as a provider and the duties of Article 16 apply instead of those of Article 23.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Relation recorded on: Article 23: obligations of importers

    Consequence

What affects this role without the duty resting on it

3 of 3 shown

This role is practically affected without being the addressee: it receives the information, has to cooperate, or absorbs the consequences in its own process.

  1. Source

    Official fact on this object, with its locator.

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 111(2)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source
    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source
    • Digital Omnibus on AI 2026/1744

      Locator: New Article 111(4)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source
    • Digital Omnibus on AI 2026/1744

      Locator: Recital 39 of Regulation (EU) 2026/1744

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allThe transitional rule is without prejudice to the application of Article 5, as referred to in Article 113, third paragraph, point (a). A prohibited practice remains prohibited, regardless of when the system was placed on the market or put into service and regardless of whether the design has changed.
    • Condition | allThe transitional rule concerns the high-risk requirements of Chapter III and is not an exemption from the whole Regulation. Article 4 has applied since 2 February 2025 irrespective of when a system reached the market, and Article 50 has applied to all systems in scope since 2 August 2026. The paragraph 4 added by the Digital Omnibus confirms this: it gives legacy generative systems a short extra period for Article 50(2), which would make no sense if Article 50 did not reach them.
    • Condition | allApplies to operators of high-risk AI systems placed on the market or put into service before the date of application of Chapter III referred to in Article 113, other than the systems referred to in paragraph 1 that are components of the large-scale IT systems listed in Annex X. That date is 2 December 2027 for systems that are high-risk under Article 6(2) and Annex III, and 2 August 2028 for systems that are high-risk under Article 6(1) and Annex I. For that group the high-risk requirements bite only once the systems are subject to significant changes in their designs as from that date.
    • Condition | allThe grace period runs per type and model, not per unit. If at least one individual unit of the type and model was lawfully placed on the market or put into service before the cut off date, other units of the same type and model are covered too and may be offered without additional obligations, requirements or additional certification, as long as the design remains unchanged. The decisive date is the one on which the first unit of that type and model was placed on the market or put into service in the Union.
    • Condition | allApplies independently to providers and deployers of high-risk AI systems intended to be used by public authorities. They must in any case take the necessary steps to comply with the requirements and obligations of the Regulation by 2 August 2030, even where the design remains unchanged.
    • ExceptionSystems that are components of the large-scale IT systems established by the legal acts listed in Annex X fall not under paragraph 2 but under paragraph 1. Paragraph 1 was not amended by the Digital Omnibus and keeps its own cut off: placed on the market or put into service before 2 August 2027, with compliance by 31 December 2030.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Relation recorded on: Article 111(2): legacy high-risk systems and the 2 August 2030 date

    Consequence

  2. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 20(1)-(2)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source
    • Digital Omnibus on AI 2026/1744

      Locator: Article 1, point (40)(b), of Regulation (EU) 2026/1744, replacing Article 113, third paragraph, point (c), of Regulation (EU) 2024/1689

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allApplies to providers of high-risk AI systems as soon as they consider, or have reason to consider, that a system they have placed on the market or put into service is not in conformity with this Regulation. For the standalone Annex III route (Article 6(2)) the date is 2 December 2027. For systems embedded as a safety component in products covered by the Annex I harmonisation legislation (Article 6(1)) the date is 2 August 2028.
    • Condition | any ofThe second layer in paragraph 2 is added only where the system presents a risk within the meaning of Article 79(1) and the provider becomes aware of that risk. The investigation of causes and the duty to inform the market surveillance authorities and, where applicable, the notified body that issued a certificate under Article 44, then come on top of the corrective actions under paragraph 1.
    • Condition | any ofThe distributor, the importer and the deployer appear here as affected parties, but that is not their only possible position. Anyone who puts their name or trade mark on a high-risk system already placed on the market, who substantially modifies such a system, or who changes the intended purpose of a system not classified as high-risk so that it becomes high-risk, is considered a provider under Article 25(1) and is subject to the obligations of Article 16. Point (j) of that Article routes straight to Article 20, so this provision then becomes a duty of their own rather than a notification arriving from someone else. In the trade mark case this applies without prejudice to contractual arrangements allocating the obligations otherwise.
    • ExceptionArticle 20 is by definition about systems already placed on the market or put into service, and that is exactly the group covered by the transitional rule of Article 111(2). That provision was replaced by Article 1, point (39)(a), of Regulation (EU) 2026/1744 and now reads: without prejudice to the application of Article 5 as referred to in Article 113, third paragraph, point (a), this Regulation applies to operators of high-risk AI systems, other than the systems referred to in paragraph 1 of that Article, that have been placed on the market or put into service before the date of application of Chapter III referred to in Article 113, only if, as from that date, those systems are subject to significant changes in their designs. The cut-off is therefore no longer a fixed date in paragraph 2: the date of 2 August 2026 that stood there until that amendment has been removed, and the amended paragraph names no date of its own. The carve-out in paragraph 1 covers systems that are components of the large-scale IT systems listed in Annex X; paragraph 1 was not amended and keeps a cut-off of its own. For systems intended to be used by public authorities the reprieve in paragraph 2 does not hold: there, compliance with the requirements and obligations is due by 2 August 2030 in any event. Which date of application of Chapter III is the cut-off is an open point: the object on Article 111 reads it as route dependent, so 2 December 2027 for the Annex III route and 2 August 2028 for the Annex I route, and marks that reading expressly as preliminary. That question is carried there, not here.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Relation recorded on: Article 20: corrective actions and duty of information

    Consequence

  3. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 99(1)-(11)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source
    • Digital Omnibus on AI 2026/1744

      Locator: Regulation (EU) 2026/1744, Article 1, point (38)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source
    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 113, third paragraph, point (b)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source
    • Digital Omnibus on AI 2026/1744

      Locator: Regulation (EU) 2026/1744, Article 1, point (40)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source
    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 101(1)-(6)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source
    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 100(1)-(3)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source
    • Digital Omnibus on AI 2026/1744

      Locator: Regulation (EU) 2026/1744, Article 1, point (32)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allRelevant as soon as you are an operator within the meaning of the Regulation, that is a provider, product manufacturer, deployer, authorised representative, importer or distributor, and one of the provisions named in Article 99(3), (4) or (5) is engaged. The Article 101 regime is additionally relevant where you are a provider of a general-purpose AI model, because there the Commission fines you itself. If you fall within the competence of the AI Office under Article 75(1), Article 75c is added on top.
    • ExceptionParagraph 6 reverses the calculation for SMEs, including start-ups: for them the lower of the percentage and the amount applies, where for other undertakings it is the higher of the two, and it does so for every fine referred to in Article 99. The inserted paragraph 6a does the same for small mid-cap enterprises, but expressly only for paragraphs 4 and 5, so the Article 5 band is not reversed for them. Paragraph 8 leaves it to each Member State to determine to what extent administrative fines may be imposed on public authorities and bodies established in that Member State, so the ceiling for a public organisation does not follow from the Regulation. Paragraph 9 allows the fine to be imposed by the competent national courts or by other bodies rather than by the authority in some Member States.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Relation recorded on: Article 99, 100 and 101: the penalty structure per obligation

    Consequence

Evidence this role owns

1 of 1 shown

This duty holder creates, maintains and can produce the evidence.

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 23(1)-(7)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    • Condition | allApplies to importers of high-risk AI systems. For the standalone Annex III route (Article 6(2)) the date is 2 December 2027; for the embedded Annex I route (Article 6(1)) the date is 2 August 2028.
    • ExceptionIf you put your own name or trade mark on the system, substantially modify it, or change the intended purpose so that it becomes high-risk, Article 25(1) treats you as a provider and the duties of Article 16 apply instead of those of Article 23.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Relation recorded on: Article 23: obligations of importers

    Consequence

Objects that are about this role

12 of 15 shown

The object is about this role. Undifferentiated: it does not follow that the duty rests on this role.

  1. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 99(1)-(11)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source
    • Digital Omnibus on AI 2026/1744

      Locator: Regulation (EU) 2026/1744, Article 1, point (38)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source
    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 113, third paragraph, point (b)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source
    • Digital Omnibus on AI 2026/1744

      Locator: Regulation (EU) 2026/1744, Article 1, point (40)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source
    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 101(1)-(6)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source
    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 100(1)-(3)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source
    • Digital Omnibus on AI 2026/1744

      Locator: Regulation (EU) 2026/1744, Article 1, point (32)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allTo be done as soon as your obligations register exists, and to be revisited on every amendment of the Regulation and on every change to the national penalty regime of a Member State in which you operate. No deadline attaches to it: this is an editorial recommendation.

    Relation recorded on: Assign to each obligation the penalty ceiling that belongs to it

    Consequence

  2. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 23(1)-(7)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    • Condition | allTo be carried out before every first placing on the market of a high-risk AI system from a third-country provider.

    Relation recorded on: Run the four verifications of Article 23(1) before importing

    Consequence

  3. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 99(1)-(11)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source
    • Digital Omnibus on AI 2026/1744

      Locator: Regulation (EU) 2026/1744, Article 1, point (38)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source
    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 113, third paragraph, point (b)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source
    • Digital Omnibus on AI 2026/1744

      Locator: Regulation (EU) 2026/1744, Article 1, point (40)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source
    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 101(1)-(6)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source
    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 100(1)-(3)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source
    • Digital Omnibus on AI 2026/1744

      Locator: Regulation (EU) 2026/1744, Article 1, point (32)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Recording of the factors in Article 99(7)

    Consequence

  4. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 23(1)-(7)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    • Condition | allTriggered at the threshold of sufficient reason to consider, meaning on a well-founded signal and not only upon certainty or third-party confirmation.

    Relation recorded on: Stop rule and notification route on doubts about conformity

    Consequence

  5. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 3(24)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: CE marking

    Consequence

    • DefinitionCE marking

      praxikon:eu:ai-act:definition:definitie-ce-markering

  6. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 3(7)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    • Condition | allApplies only to a party in the supply chain that is neither the provider nor the importer.

    Relation recorded on: Distributor

    Consequence

    • DefinitionDistributor

      praxikon:eu:ai-act:definition:definitie-distributeur

  7. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 3(6)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Importer

    Consequence

    • DefinitionImporter

      praxikon:eu:ai-act:definition:definitie-importeur

  8. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 3(9)-(10)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Placing on the market

    Consequence

  9. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 3(8)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Operator

    Consequence

    • DefinitionOperator

      praxikon:eu:ai-act:definition:definitie-operator

  10. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 3(17)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Withdrawal of an AI system

    Consequence

  11. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 99(1)-(11)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source
    • Digital Omnibus on AI 2026/1744

      Locator: Regulation (EU) 2026/1744, Article 1, point (38)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source
    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 113, third paragraph, point (b)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source
    • Digital Omnibus on AI 2026/1744

      Locator: Regulation (EU) 2026/1744, Article 1, point (40)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source
    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 101(1)-(6)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source
    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 100(1)-(3)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source
    • Digital Omnibus on AI 2026/1744

      Locator: Regulation (EU) 2026/1744, Article 1, point (32)

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Register of penalty ceilings per obligation

    Consequence

  12. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 23(1)-(7)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    • Condition | allThe ten-year term runs from placing on the market or putting into service, and therefore per system and per version, not per supplier relationship.

    Relation recorded on: Importer dossier with ten-year retention

    Consequence

Open the full list in the explorer

The list there can be slightly wider than this group: the filter also counts the object itself, and for a role the broader role above it.

When this applies

  1. 1Applies where you are located or established in the Union and are the first to place an AI system from a third-country provider on the Union market under that provider's name or trade mark.

When this does not apply

  • You are not an importer but a provider as soon as you put your own name or trade mark on the system, make a substantial modification, or change the intended purpose so that the system becomes high-risk (Article 25(1)(a), (b) and (c)). Point (a) expressly applies without prejudice to contractual arrangements stipulating that the obligations are otherwise allocated. The role switch can be determined today; the twelve duties of Article 16 start to apply on 2 December 2027 for the standalone Annex III route and on 2 August 2028 for the embedded Annex I route.

Referring to this object

Citation block

Copy this reference into your advice, article or file. The identifier, the version and the hash keep the statement findable later, even once the dataset has moved on.

Reference

Praxikon, "Importer",
praxikon:eu:ai-act:actor:importer@1.0.0,
dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.2.0 (schema 1.5.0),
effective_at 2026-08-08T00:00:00.000Z, known_at 2026-08-08T00:00:00.000Z,
sha256 152e324e4109e7ad2b10c910c623deef18e05cca1f165166aa94f4f3b3a58f89,
https://www.praxikon.com/en/verkenner/actor/importer
(https://www.praxikon.com/api/v1/entities?id=praxikon%3Aeu%3Aai-act%3Aactor%3Aimporter&effective_at=2026-08-08&known_at=2026-08-08&lang=en, accessed 2026-09-15)

Short form

praxikon:eu:ai-act:actor:importer@1.0.0 (sha256 152e324e)

BibTeX

@misc{praxikon-eu-ai-act-actor-importer-1-0-0,
  author       = {{Praxikon}},
  title        = {Importer},
  year         = {2026},
  version      = {1.0.0},
  number       = {praxikon:eu:ai-act:actor:importer},
  howpublished = {AI Act Change \& Evidence Graph, dataset 2.2.0, schema 1.5.0},
  note         = {effective_at 2026-08-08T00:00:00.000Z; known_at 2026-08-08T00:00:00.000Z; sha256 152e324e4109e7ad2b10c910c623deef18e05cca1f165166aa94f4f3b3a58f89},
  url          = {https://www.praxikon.com/en/verkenner/actor/importer},
  urldate      = {2026-09-15},
  language     = {en}
}

CSL JSON

[
  {
    "id": "praxikon:eu:ai-act:actor:importer@1.0.0",
    "type": "dataset",
    "title": "Importer",
    "container-title": "AI Act Change & Evidence Graph",
    "publisher": "Praxikon",
    "version": "1.0.0",
    "number": "praxikon:eu:ai-act:actor:importer",
    "URL": "https://www.praxikon.com/en/verkenner/actor/importer",
    "language": "en",
    "issued": {
      "date-parts": [
        [
          2026,
          8,
          8
        ]
      ]
    },
    "accessed": {
      "date-parts": [
        [
          2026,
          9,
          15
        ]
      ]
    },
    "note": "dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.2.0; schema 1.5.0; effective_at 2026-08-08T00:00:00.000Z; known_at 2026-08-08T00:00:00.000Z; sha256 152e324e4109e7ad2b10c910c623deef18e05cca1f165166aa94f4f3b3a58f89; retrieved_from https://www.praxikon.com/api/v1/entities?id=praxikon%3Aeu%3Aai-act%3Aactor%3Aimporter&effective_at=2026-08-08&known_at=2026-08-08&lang=en; licence https://www.praxikon.com/nl/legal/terms"
  }
]

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This page and the machine output come from the same object and the same two time axes.