Roles in EU product compliance
EU product law decides a company's duties by its role, product by product. The role follows from what you do with the product, not from your industry or what a contract calls you: whose name is on it, who brings it into the EU and who sells it on. A company can be the manufacturer of one product, the importer of the next and a distributor of a third.
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General information, not legal advice.
The roles, one page each
Each role has one page: the definition from the law, examples to test yourself against, the duties with their articles, and the regulations that name the role.
- Manufacturer Markets a product under its own name or trademark, whoever designed or made it. Draws up the technical documentation and answers for the product's conformity. Open the page →
- Importer Established in the EU and places a product from outside the EU on the market under the maker's brand. Checks the maker's work, adds its own name and address, keeps the documents for 10 years. Open the page →
- Distributor Sells on a product that a manufacturer or importer has already placed on the EU market. Verifies the marking, the instructions and the identification before selling. Open the page →
- Fulfilment service provider Stores, packs, addresses or dispatches products it does not own. Becomes the responsible person in the EU for the products it handles when nobody else in the EU is. Open the page →
- Online marketplace Runs an online interface where traders sell products to consumers. Carries the marketplace duties of GPSR Article 22, next to the Digital Services Act. Open the page →
- Online seller Sells to consumers online or at a distance. Is a manufacturer, importer or distributor for each product, and must show the mandatory information in every offer. Open the page →
- Authorised representative Established in the EU with a written mandate from a manufacturer. Keeps the documents available for the authorities and cooperates with them on the manufacturer's behalf. Open the page →
Which role am I?
Go through your range product by product. Questions 1 to 3 decide your place in the supply chain for that product: answer them in order, and the first yes decides. Questions 4 to 6 can apply on top of that, so answer all three. A company can hold different roles for different products, and a representative, a warehouse or a marketplace can also be a manufacturer, an importer or a distributor.
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Is the product sold under your name or trademark, did you substantially modify it, or do you bring onto the EU market a product not made for it or a used product from outside the EU?
You are the manufacturer, whoever designed or made it (for the modified part, or the whole product where safety is affected). Manufacturer →
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Are you established in the EU, and do you place a product from outside the EU on the EU market, as the first to make it available here?
You are the importer. Importer →
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Do you sell on a product that someone else has already placed on the EU market?
You are a distributor. Selling it online does not change the role. Distributor →
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Do you hold a written mandate from a manufacturer to act for it in the EU?
You are its authorised representative for the tasks the mandate names, alongside any role you hold yourself. Authorised representative →
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Do you offer at least two of storing, packing, addressing and dispatching goods you do not own (parcel and freight carriers excluded)?
You are a fulfilment service provider. Under the GPSR and the CE acts named in Regulation (EU) 2019/1020, you are the responsible person for the products you handle where no manufacturer, importer or authorised representative is established in the EU. Fulfilment service provider →
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Do other traders sell to consumers on your online interface?
You are the provider of an online marketplace. Online marketplace →
Selling online is not a role of its own. An online seller is a manufacturer, an importer or a distributor for each product, with extra duties for the offer. Online seller →
Who gives what to whom
A product moves down the chain with its papers. Questions, complaints and incidents move back up. Every role answers to the market surveillance authorities.
The hand-overs as a table
The same flow in text: what each role gives to, and receives from, the parties next to it.
| Role | With | Gives | Receives |
|---|---|---|---|
| Manufacturer | Importer | The EU declaration of conformity; a copy of the technical documentation (GPSR) or, under a CE act, access to it when an authority asks; test reports, the product identification, instructions and safety information. | Requests for documents, the markets the product is sold in, complaints and accident information. |
| Distributor | A marked product with instructions and safety information, and word of any safety issue you find. | Complaints, accident information and non-conformities found in the shop. | |
| Authorised representative | A written mandate that names the tasks, the declaration of conformity and access to the technical documentation. | Requests from authorities, and word when the representative has reason to believe a product is dangerous. | |
| Market surveillance authorities | The technical documentation and the declaration on request; notifications of dangerous products, corrective measures and accidents. | Reasoned requests, orders for corrective action, withdrawal or recall. | |
| Importer | Manufacturer | Requests for documents, the markets you sell in, complaints and accident information. | The EU declaration of conformity; a copy of the technical documentation (GPSR) or, under a CE act, the assurance that it can be made available when an authority asks; test reports, instructions and safety information. |
| Distributor | A product that carries the manufacturer's and your own name and address, with instructions in the market's language, and word of any safety issue. | Complaints, accident information and non-conformities found in the shop. | |
| Online marketplace | The information for each offer: the manufacturer, the responsible person, the product identification and the warnings. | Notices when an offer is removed, and cooperation when a product is recalled. | |
| Market surveillance authorities | The technical documentation, the declaration and the names of your supplier and your business customers, on request. | Reasoned requests, orders for corrective action, withdrawal or recall. | |
| Distributor | Manufacturer | Complaints, accident information and non-conformities found on the shelf. | A marked product with instructions and safety information, and word of any safety issue. |
| Importer | Complaints, accident information and non-conformities found on the shelf. | A product that carries the importer's name and address, with instructions in the market's language. | |
| Shop or consumer | A product with its marking, instructions and safety information, and recall information when a product comes back. | Complaints and reports of accidents. | |
| Market surveillance authorities | Who supplied you and whom you supplied, and the information that shows conformity, on request. | Reasoned requests, orders for corrective action, withdrawal or recall. | |
| Fulfilment service provider | Seller outside the EU | Requests from authorities, and word when you have reason to believe a product presents a risk. | The name and address of the responsible operator in the EU or, where there is none, the declaration of conformity and access to the technical documentation for an authority's request. |
| Shop or consumer | The parcel, with the responsible operator's name and contact details on the product, its packaging, the parcel or an accompanying document. | Returns and complaints, which go on to the seller. | |
| Market surveillance authorities | The declaration and the technical documentation on request, information on risks, and cooperation on corrective action. | Reasoned requests and orders for corrective action. | |
| Online marketplace | Online seller | Notice when an offer is removed, a warning before a suspension, and recall information for the products concerned. | For each listing: the manufacturer, the responsible person in the EU, the product identification and the warnings. |
| Shop or consumer | The mandatory information in the listing, and a direct notice when a product bought through the marketplace is recalled. | Product safety questions and notices through the consumer contact point. | |
| Market surveillance authorities | Action on orders and a report of the effect given to them, notifications through the Safety Business Gateway, and access to the interface for the authorities' online tools. | Orders to remove an offer, disable access or display a warning. | |
| Online seller | Manufacturer | Complaints and accident information from your customers. | The manufacturer's identity and addresses, the product identification, the warnings and the evidence that the product is safe. |
| Online marketplace | For each listing: the manufacturer, the responsible person in the EU, the product identification and the warnings. | Notice when an offer is removed, a warning before a suspension, and recall information. | |
| Shop or consumer | An offer with the mandatory information, and the product with its marking, instructions and safety information. | Complaints and reports of accidents. | |
| Market surveillance authorities | Who supplied you, and the information that shows the product's conformity, on request. | Reasoned requests, orders for corrective action, and orders to remove an offer. | |
| Authorised representative | Manufacturer | Requests from authorities, and word when you have reason to believe a product is dangerous. | The written mandate with the products and the tasks, the declaration of conformity and access to the technical documentation. |
| Importer | Your name and contact details where you are the responsible operator, for the label and the offers. | Complaints and accident information that concern the products under your mandate. | |
| Market surveillance authorities | A copy of the mandate, the declaration and the technical documentation on request, and cooperation on corrective action. | Reasoned requests and orders for corrective action. |
Read on
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