---
title: "Roles in EU product compliance"
description: "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."
type: "role"
url: "https://www.conphora.com/roles/"
markdown: "https://www.conphora.com/roles.md"
locale: "en"
language: "en"
updated: "2026-10-05"
author: "Conphora compliance team"
publisher: "Conphora"
tags: ["roles"]
license: "Free to quote with attribution and a link to the page"
---

# 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.

## The roles, one page each

- [Manufacturer](https://www.conphora.com/roles/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. Markdown: https://www.conphora.com/roles/manufacturer.md
- [Importer](https://www.conphora.com/roles/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. Markdown: https://www.conphora.com/roles/importer.md
- [Distributor](https://www.conphora.com/roles/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. Markdown: https://www.conphora.com/roles/distributor.md
- [Fulfilment service provider](https://www.conphora.com/roles/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. Markdown: https://www.conphora.com/roles/fulfilment-service-provider.md
- [Online marketplace](https://www.conphora.com/roles/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. Markdown: https://www.conphora.com/roles/online-marketplace.md
- [Online seller](https://www.conphora.com/roles/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. Markdown: https://www.conphora.com/roles/online-seller.md
- [Authorised representative](https://www.conphora.com/roles/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. Markdown: https://www.conphora.com/roles/authorised-representative.md

## 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.

1. **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).
2. **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.
3. **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.
4. **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.
5. **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.
6. **Do other traders sell to consumers on your online interface?** You are the provider of an 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.

## The hand-overs as a table

- **Manufacturer → Importer** — Gives: 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. Receives: Requests for documents, the markets the product is sold in, complaints and accident information.
- **Manufacturer → Distributor** — Gives: A marked product with instructions and safety information, and word of any safety issue you find. Receives: Complaints, accident information and non-conformities found in the shop.
- **Manufacturer → Authorised representative** — Gives: A written mandate that names the tasks, the declaration of conformity and access to the technical documentation. Receives: Requests from authorities, and word when the representative has reason to believe a product is dangerous.
- **Manufacturer → Market surveillance authorities** — Gives: The technical documentation and the declaration on request; notifications of dangerous products, corrective measures and accidents. Receives: Reasoned requests, orders for corrective action, withdrawal or recall.
- **Importer → Manufacturer** — Gives: Requests for documents, the markets you sell in, complaints and accident information. Receives: 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.
- **Importer → Distributor** — Gives: 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. Receives: Complaints, accident information and non-conformities found in the shop.
- **Importer → Online marketplace** — Gives: The information for each offer: the manufacturer, the responsible person, the product identification and the warnings. Receives: Notices when an offer is removed, and cooperation when a product is recalled.
- **Importer → Market surveillance authorities** — Gives: The technical documentation, the declaration and the names of your supplier and your business customers, on request. Receives: Reasoned requests, orders for corrective action, withdrawal or recall.
- **Distributor → Manufacturer** — Gives: Complaints, accident information and non-conformities found on the shelf. Receives: A marked product with instructions and safety information, and word of any safety issue.
- **Distributor → Importer** — Gives: Complaints, accident information and non-conformities found on the shelf. Receives: A product that carries the importer's name and address, with instructions in the market's language.
- **Distributor → Shop or consumer** — Gives: A product with its marking, instructions and safety information, and recall information when a product comes back. Receives: Complaints and reports of accidents.
- **Distributor → Market surveillance authorities** — Gives: Who supplied you and whom you supplied, and the information that shows conformity, on request. Receives: Reasoned requests, orders for corrective action, withdrawal or recall.
- **Fulfilment service provider → Seller outside the EU** — Gives: Requests from authorities, and word when you have reason to believe a product presents a risk. Receives: 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.
- **Fulfilment service provider → Shop or consumer** — Gives: The parcel, with the responsible operator's name and contact details on the product, its packaging, the parcel or an accompanying document. Receives: Returns and complaints, which go on to the seller.
- **Fulfilment service provider → Market surveillance authorities** — Gives: The declaration and the technical documentation on request, information on risks, and cooperation on corrective action. Receives: Reasoned requests and orders for corrective action.
- **Online marketplace → Online seller** — Gives: Notice when an offer is removed, a warning before a suspension, and recall information for the products concerned. Receives: For each listing: the manufacturer, the responsible person in the EU, the product identification and the warnings.
- **Online marketplace → Shop or consumer** — Gives: The mandatory information in the listing, and a direct notice when a product bought through the marketplace is recalled. Receives: Product safety questions and notices through the consumer contact point.
- **Online marketplace → Market surveillance authorities** — Gives: 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. Receives: Orders to remove an offer, disable access or display a warning.
- **Online seller → Manufacturer** — Gives: Complaints and accident information from your customers. Receives: The manufacturer's identity and addresses, the product identification, the warnings and the evidence that the product is safe.
- **Online seller → Online marketplace** — Gives: For each listing: the manufacturer, the responsible person in the EU, the product identification and the warnings. Receives: Notice when an offer is removed, a warning before a suspension, and recall information.
- **Online seller → Shop or consumer** — Gives: An offer with the mandatory information, and the product with its marking, instructions and safety information. Receives: Complaints and reports of accidents.
- **Online seller → Market surveillance authorities** — Gives: Who supplied you, and the information that shows the product's conformity, on request. Receives: Reasoned requests, orders for corrective action, and orders to remove an offer.
- **Authorised representative → Manufacturer** — Gives: Requests from authorities, and word when you have reason to believe a product is dangerous. Receives: The written mandate with the products and the tasks, the declaration of conformity and access to the technical documentation.
- **Authorised representative → Importer** — Gives: Your name and contact details where you are the responsible operator, for the label and the offers. Receives: Complaints and accident information that concern the products under your mandate.
- **Authorised representative → Market surveillance authorities** — Gives: A copy of the mandate, the declaration and the technical documentation on request, and cooperation on corrective action. Receives: Reasoned requests and orders for corrective action.