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The distributor role in EU product compliance

The distributor is any company in the supply chain, other than the manufacturer or the importer, that makes a product available on the market: wholesalers, retailers and online shops that resell products already placed on the EU market. A distributor does not test or document the product, but it must verify the marking and the information before selling, must not sell a product it has reason to doubt, and must act when a product it sold turns out to be dangerous.

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Reviewed 5 October 2026 by the Conphora compliance team · Not legal advice

Am I the distributor?

What the law asks of you

The references name the General Product Safety Regulation (GPSR) and, as the example of a CE act, the Low Voltage Directive (LVD). For products under a product-specific harmonisation act, such as the Low Voltage or Toy Safety Directive, the GPSR's Chapter III, Section 1 (Articles 9 to 18) does not apply, and the act's own duties take its place (Article 2(1), third subparagraph, point (b)). The GPSR's safety requirement still covers risks the act does not (point (a)), and Articles 19 to 22, on online offers, accidents and online marketplaces, apply to all products, as do the recall rules in Articles 35 to 37. REACH restrictions and labelling rules do not take a product out of Articles 9 to 18. Whoever places on the EU market a product not designed for it, or a used product from outside the EU, takes on the manufacturer's role (Blue Guide, section 3.1); a used CE product resold inside the EU falls under the GPSR in full. The regulation guides list the article for each act.

Before the product is placed or sold

  • Before making a product available, verify that the manufacturer and, where applicable, the importer have put the identification and their names and addresses on the product and supplied instructions and safety information. For a CE product, act with due care and verify that it bears the CE marking and comes with the required documents. GPSR Art. 12(1); LVD Art. 9(1) and 9(2)
  • Do not make a product available where you consider or have reason to believe that it is not in conformity, until it has been brought into conformity. GPSR Art. 12(3); LVD Art. 9(2)

On the product and in the offer

  • You add nothing to the product. If you sell it under your own name or trademark, or modify it substantially (GPSR) or in a way that may affect its compliance (Low Voltage Directive), you take on the manufacturer's obligations. GPSR Art. 13; LVD Art. 10

Records to keep

  • Be able to say who supplied you and whom you supplied: for six years under the GPSR, for 10 years under the Low Voltage Directive. GPSR Art. 15; LVD Art. 11

While it is on the market

  • While the product is under your responsibility, keep storage and transport from jeopardising its conformity. GPSR Art. 12(2); LVD Art. 9(3)
  • When you sell online or at a distance, show in the offer the manufacturer, the responsible person where the manufacturer is outside the EU, the product identification with a picture, and the warnings. GPSR Art. 19

When something is wrong

  • Under the GPSR, if a product you made available is dangerous or lacks the required identification and information, inform the manufacturer or the importer at once, make sure corrective measures are taken, including withdrawal or recall, and make sure the authorities are informed through the Safety Business Gateway. GPSR Art. 12(4)
  • Under the Low Voltage Directive, if equipment you made available does not conform, make sure the corrective measures are taken, including withdrawal or recall; where it presents a risk, at once inform the national authorities yourself. LVD Art. 9(4)
  • Tell the manufacturer without undue delay about an accident caused by a product you made available. The manufacturer makes the notification, or instructs you to make it. This duty applies to CE products too. GPSR Art. 20(3)
  • Cooperate with the authorities on measures to eliminate the risks. On request, give them the information they need: under the GPSR, the risk, related complaints, known accidents and corrective measures; under the Low Voltage Directive, on a reasoned request, the information and documentation that show conformity. GPSR Art. 15(1) and 15(2); LVD Art. 9(5)

Article 12 of the General Product Safety Regulation (EU) 2023/988 sets out the distributor's obligations. Before making a product available on the market, distributors verify that the manufacturer and, where applicable, the importer have complied with the rules on identification of the product, name and addresses, and instructions and safety information (Article 12(1), referring to Article 9(5), (6) and (7) and Article 11(3) and (4)).[1]

The duty continues while the product is in the distributor's hands: storage or transport conditions must not jeopardise its conformity (Article 12(2)). Where the distributor has reason to believe that a product is not in conformity, it does not make it available (Article 12(3)), and where a product it has made available is dangerous or lacks the identification and information, it informs the manufacturer or the importer, ensures that corrective measures are taken and ensures that the authorities are informed (Article 12(4)).[1]

For products covered by a CE act, Chapter III, Section 1 of the GPSR (Articles 9 to 18) does not apply (Article 2(1), third subparagraph, point (b)); the act's own distributor article applies instead. Under the Low Voltage Directive 2014/35/EU, distributors act with due care, verify the CE marking, the documents and the instructions before making equipment available, and cooperate with the authorities on request (Article 9). The GPSR's rules on online offers and accidents (Articles 19 and 20) and its recall rules (Articles 35 to 37) still apply to those products.[1][2]

Market surveillance authorities can turn to any economic operator in the chain and require corrective action (Regulation (EU) 2019/1020, Article 16, applied to products under the GPSR by its Article 23(1)), which is why retailers pass the same questions on to their suppliers.[3]

What Conphora does for the distributor

What the platform does today for a company in this role.

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Who you share with

  • Manufacturer

    You give
    Complaints, accident information and non-conformities found on the shelf.
    You receive
    A marked product with instructions and safety information, and word of any safety issue.

  • Importer

    You give
    Complaints, accident information and non-conformities found on the shelf.
    You receive
    A product that carries the importer's name and address, with instructions in the market's language.

  • Shop or consumer

    You give
    A product with its marking, instructions and safety information, and recall information when a product comes back.
    You receive
    Complaints and reports of accidents.

  • Market surveillance authorities

    You give
    Who supplied you and whom you supplied, and the information that shows conformity, on request.
    You receive
    Reasoned requests, orders for corrective action, withdrawal or recall.

See the whole flow →

Regulations that bind the distributor

Taken from the regulation guides: 47 acts name this role. The article numbers are those of the role's duties in each act.

and 35 more in the regulation library · All regulation guides →

Problems people in this role ask about

Problem pages written for this role: 25 in all.

We only resell and do not know what we must checkRoles and responsibilitiesA new regulation applies and nobody knows what changesPlacing a product on the marketA product needs to be recalledIncidents, recalls and authoritiesMarketing wants to say the product is sustainableSustainability and green claimsOur supplier recalled a product we sellIncidents, recalls and authoritiesA retailer wants to sell our product under its own brandMarketplace and retailer demandsWe sell refurbished products and are asked for safety proofMarketplace and retailer demandsAre we the manufacturer, the importer or the distributor?Roles and responsibilities

All problems for this role →

Questions about the role

Do we have to ask for test reports?

The regulation asks distributors to verify the marking and the information, and to act on what they know. Asking for documents is a sensible way to know more, and many retailers require it by contract.

We buy from a wholesaler in another EU country. Are we an importer?

No. An importer places a product from a third country on the Union market. Buying inside the Union makes you a distributor, unless you use your own brand or substantially modify the product.

Does this apply to online shops?

Yes. An online shop that resells products bought inside the Union is a distributor, and its offers must also show the information listed for distance sales in Article 19 of the GPSR.

What if the manufacturer does not answer?

You still make sure the authorities are informed when a product you made available is dangerous, and you do not keep selling it.

Can a distributor become the manufacturer?

Yes. The GPSR applies the rule to any person placing a product on the market under its own name or trademark (Article 13(1)), and the Low Voltage Directive names importers and distributors expressly (Article 10).

Sources

  1. Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026) EUR-Lex · accessed 5 October 2026
  2. Directive 2014/35/EU on electrical equipment (Low Voltage Directive), consolidated text of 30 May 2026 EUR-Lex · accessed 5 October 2026
  3. Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026) EUR-Lex · accessed 5 October 2026
  4. Decision No 768/2008/EC on a common framework for the marketing of products EUR-Lex · accessed 5 October 2026

About this page

Reviewer
Conphora compliance team
Reviewed
5 October 2026

General information, not legal advice. Check the legal text or ask an adviser about your own product.

Cite this page 
Conphora (2026). The distributor role in EU product compliance. Retrieved 13 October 2026 from https://www.conphora.com/roles/distributor/
Reviewed

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