No. An importer as defined by the regulation must be established within the EU. A branch office without independent legal personality, or having only VAT registration, does not constitute an importer.
Therefore: • Taiwan exporters/trading companies are on the "manufacturer" side, or are only suppliers in the supply chain • The legal importer is the buyer on the EU side • The EU buyer's obligation is to confirm that the manufacturer has prepared the Declaration of Conformity and to submit it when requested by market surveillance authorities
If a user says "I am an importer" or "I am an exporter so I am the importer's counterpart," gently correct this concept.