“Economic operator” is the collective term EU product law uses for everyone in the supply chain who carries legal obligations. Decision No 768/2008/EC originally listed four roles: the manufacturer, the authorised representative, the importer and the distributor. Regulation (EU) 2019/1020 added the fulfilment service provider and an open clause covering any other natural or legal person subject to obligations in relation to the manufacture of products, making them available on the market or putting them into service under the relevant harmonisation legislation. The General Product Safety Regulation uses the same structure for consumer products.
Newer acts adjust the list to their subject. The Ecodesign for Sustainable Products Regulation includes the dealer, that is any distributor or other person offering products to end users, including through distance selling. The Packaging and Packaging Waste Regulation adds the supplier and the final distributor, and the 2024 Product Liability Directive counts the manufacturer of a component and the provider of a related service among the economic operators who may be liable.
The practical consequence is that a company must determine which role it plays for each product, because the obligations differ: the manufacturer designs, documents and declares conformity, the importer verifies and identifies itself, the distributor checks and acts with due care. Two duties reach every economic operator: to place or make available only safe products (General Product Safety Regulation, Article 5) and to cooperate with market surveillance authorities on actions that could eliminate or mitigate risks (Market Surveillance Regulation, Article 7, and General Product Safety Regulation, Article 15).