---
title: "The manufacturer role in EU product compliance"
description: "The manufacturer is the company that markets a product under its own name or trademark, whether it made the product itself or had it designed or made by someone else. EU product law gives the manufacturer the full set of duties: the risk analysis or conformity assessment, the technical documentation, the marking and the instructions, and action when a product turns out to be dangerous. A brand owner is the manufacturer even when a factory elsewhere builds the product."
type: "role"
url: "https://www.conphora.com/roles/manufacturer/"
markdown: "https://www.conphora.com/roles/manufacturer.md"
locale: "en"
language: "en"
updated: "2026-10-05"
author: "Conphora compliance team"
publisher: "Conphora"
source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529"
tags: ["roles", "Manufacturer"]
license: "Free to quote with attribution and a link to the page"
---

# The manufacturer role in EU product compliance

The manufacturer is the company that markets a product under its own name or trademark, whether it made the product itself or had it designed or made by someone else. EU product law gives the manufacturer the full set of duties: the risk analysis or conformity assessment, the technical documentation, the marking and the instructions, and action when a product turns out to be dangerous. A brand owner is the manufacturer even when a factory elsewhere builds the product.

## The definition in the law

> Any natural or legal person who manufactures a product or has a product designed or manufactured, and markets that product under that person's name or trademark.

[Regulation (EU) 2023/988 on general product safety (GPSR), Article 3(8)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529)

The CE acts define the manufacturer in the same terms, for example the Low Voltage Directive (Article 2, point (3)). The definition goes back to the reference provisions in Decision No 768/2008/EC (Annex I, Article R1, point 3) and appears in the same terms in Regulation (EU) 2019/1020 (Article 3, point (8)).

## Am I the manufacturer?

- **Yes: A lamp you design and have built by a factory in Asia, sold under your brand.** You have the product designed or manufactured and you market it under your own name. The factory is your subcontractor, and the manufacturer's duties are yours (GPSR Article 3(8)).
- **Yes: A ready-made product that only carries your logo.** A person who places a product on the market under its own name or trademark is deemed to be the manufacturer, also when only the label or the packaging was changed (GPSR Article 13(1); Low Voltage Directive Article 10).
- **Yes: A product from another maker that you substantially modify.** A person other than the manufacturer who substantially modifies a product is deemed to be a manufacturer for the part affected by the modification, or for the whole product if the modification affects its safety (GPSR Article 13(2)).
- **No, you are the importer: A branded product from a maker outside the EU, sold under the maker's brand.** The maker stays the manufacturer. You are established in the EU and place its product on the EU market, which makes you the importer. If the product was not designed or made for the EU market, the Commission's Blue Guide says you take on the manufacturer's role (section 3.1). (https://www.conphora.com/roles/importer/)
- **No, you are the distributor: A product bought from a supplier in the EU and sold on unchanged.** Someone else already placed the product on the EU market. You make it available, which makes you a distributor, as long as it does not carry your own brand. (https://www.conphora.com/roles/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

- Design and manufacture the product so that it is safe: under the GPSR in accordance with the general safety requirement, under a CE act such as the Low Voltage Directive in accordance with its safety objectives. [GPSR Art. 5 and 9(1); LVD Art. 6(1)]
- Carry out the risk analysis and draw up the technical documentation. Under a CE act, also carry out the conformity assessment, draw up the EU declaration of conformity and affix the CE marking. [GPSR Art. 9(2); LVD Art. 6(2), 15, 16 and 17]
- If you are established outside the EU, make sure that an economic operator established in the Union is responsible for the product before it is placed on the market. [GPSR Art. 16(1); Regulation (EU) 2019/1020 Art. 4(1)]

### On the product and in the offer

- Put a type, batch or serial number on the product, together with your name, registered trade name or registered trade mark and your postal and electronic address (under the Low Voltage Directive, the postal address). Where the product's size or nature does not allow it, use the packaging or an accompanying document. [GPSR Art. 9(5) and 9(6); LVD Art. 6(5) and 6(6)]
- Supply clear instructions and safety information in the language determined by the Member State where the product is made available. [GPSR Art. 9(7); LVD Art. 6(7)]

### Records to keep

- Keep the technical documentation, and for CE products the EU declaration of conformity, at the disposal of the market surveillance authorities for 10 years after the product was placed on the market. [GPSR Art. 9(3); LVD Art. 6(3)]
- 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

- Keep procedures in place so that series production stays in conformity when the design, the materials or the standards change. [GPSR Art. 9(4); LVD Art. 6(4)]
- Under the GPSR, offer public channels for complaints, investigate complaints and accident information, and keep an internal register of complaints, recalls and corrective measures. Under the Low Voltage Directive, where the risks warrant it, sample-test marketed equipment, investigate, keep a register of complaints, non-conforming equipment and recalls if necessary, and keep distributors informed. [GPSR Art. 9(11) and 9(12); LVD Art. 6(4)]
- When you sell online or at a distance, show in the offer the manufacturer's name and addresses, 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 placed on the market is dangerous, act at once: take the corrective measures, including withdrawal or recall, inform consumers, and inform the market surveillance authorities through the Safety Business Gateway. Keep the other companies in your supply chain informed of safety issues. [GPSR Art. 9(8) and 9(10)]
- Under the Low Voltage Directive, if equipment you placed on the market does not conform, at once bring it into conformity, withdraw or recall it; where it presents a risk, at once inform the national authorities where you made it available. [LVD Art. 6(8)]
- Notify an accident caused by the product that resulted in death or serious adverse effects on health and safety through the Safety Business Gateway, without undue delay. This duty applies to CE products too. [GPSR Art. 20(1) and 20(2)]
- In a recall, notify the affected consumers you can identify directly, give written recall information as a recall notice with the content the GPSR lists, and offer the consumer a choice of at least two of repair, replacement and refund. These recall rules apply to CE products too. [GPSR Art. 35(1), 36 and 37(2)]

The name on the product decides who the manufacturer is. The General Product Safety Regulation (EU) 2023/988 defines the manufacturer as any person who manufactures a product or has it designed or manufactured, and markets it under its own name or trademark (Article 3(8)). A person who places a product on the market under its own name or trademark is deemed to be the manufacturer and is subject to the manufacturer's obligations (Article 13(1)). The Low Voltage Directive 2014/35/EU says the same for importers and distributors (Article 10). [1] [2]

Which articles apply depends on the product. Consumer products without a product-specific act fall under Article 9 of the GPSR: an internal risk analysis, technical documentation kept for 10 years, an identifier and the manufacturer's name and addresses on the product, instructions and safety information, complaint channels and a register. 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 itself sets the manufacturer's duties, for example the conformity assessment, the EU declaration of conformity and the CE marking under Article 6 of the Low Voltage Directive. 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. Whoever places on the EU market a product not designed or made for it, or a used product from outside the EU, takes on the manufacturer's role (Blue Guide, section 3.1). [1] [2] [5]

The manufacturer cannot pass the responsibility on. The Commission's Blue Guide states that a manufacturer who subcontracts design or production keeps the entire responsibility for the conformity assessment, and that it must have the documentation and certificates at its disposal even when somebody else produced them. [5]

A manufacturer established in the Union is also the economic operator responsible for the product towards the market surveillance authorities (Regulation (EU) 2019/1020, Article 4(2)(a); GPSR Article 16(1)). For products under the GPSR or the CE acts listed in Article 4(5) of that Regulation, a manufacturer outside the Union needs an importer, an authorised representative with a written mandate or, failing those, a fulfilment service provider in the Union to fill that role. [1] [3]

## What Conphora does for the manufacturer

- **The manufacturer's steps, product by product** — The product workspace sets the role for each product and lists the steps that role carries under the regulations that apply to it.
- **Technical file assembly** — The documents filed on a product are assembled into one technical file, so there is one document to send when an authority or a customer asks.
- **Declaration of conformity and product passport** — The declaration is generated from the product's own data, and the product passport gives the product one page with its compliance information.
- **Supplier requests** — Ask a supplier of parts or materials for test reports and declarations through one link. What comes back is filed on the product with the sender's name.
- **Radar and recall** — Compliance Radar reports changes in the rules and Safety Gate alerts for your product types, and the recall manager runs a recall from the first alert to closure.

## Who you share with

- **the importer** — You give: 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. You receive: Requests for documents, the markets the product is sold in, complaints and accident information.
- **the distributor** — You give: A marked product with instructions and safety information, and word of any safety issue you find. You receive: Complaints, accident information and non-conformities found in the shop.
- **the authorised representative** — You give: A written mandate that names the tasks, the declaration of conformity and access to the technical documentation. You receive: Requests from authorities, and word when the representative has reason to believe a product is dangerous.
- **Market surveillance authorities** — You give: The technical documentation and the declaration on request; notifications of dangerous products, corrective measures and accidents. You receive: Reasoned requests, orders for corrective action, withdrawal or recall.

## Regulations that bind the manufacturer

- [GPSR — General Product Safety Regulation](https://www.conphora.com/regulations/gpsr/): Art. 5, 9, 15, 16, 19, 20, 35, 36, 37
- [MDR — Medical Devices Regulation](https://www.conphora.com/regulations/mdr/): Art. 5, 7, 10, 10a, 11, 15, 18, 19, 20, 22, 27, 29, 31, 32, 51, 52, 61, 83, 84, 85, 86, 87, 88, 89, 120, 123
- [IVDR — In Vitro Diagnostic Medical Devices Regulation](https://www.conphora.com/regulations/ivdr/): Art. 5, 6, 7, 10, 10a, 11, 15, 17, 18, 24, 26, 28, 29, 47, 48, 56, 78, 79, 80, 81, 82, 83, 84, 110, 113
- [BattR — EU Batteries Regulation](https://www.conphora.com/regulations/battr/): Art. 7, 8, 10, 11, 13, 14, 17, 18, 20, 38, 47, 48, 49, 50, 52, 77, 96
- [RED — Radio Equipment Directive](https://www.conphora.com/regulations/red/): Art. 3, 3a, 4, 5, 10, 15, 17, 18, 19, 20, 21
- [PPWR — Packaging and Packaging Waste Regulation](https://www.conphora.com/regulations/ppwr/): Art. 4, 5, 6, 7, 9, 10, 11, 12, 14, 15, 16, 22, 24, 25, 26, 27, 29, 38, 39
- [PED — Pressure Equipment Directive](https://www.conphora.com/regulations/ped/): Art. 4, 6, 11, 12, 13, 14, 15, 17, 18, 19, 43c
- [SPVD — Simple Pressure Vessels Directive](https://www.conphora.com/regulations/spvd/): Art. 1, 4, 6, 11, 13, 14, 16, 38c
- [PyroD — Pyrotechnic Articles Directive](https://www.conphora.com/regulations/pyrod/): Art. 6, 8, 9, 10, 11, 15, 17, 18, 19, 20
- [RCD — Recreational Craft Directive](https://www.conphora.com/regulations/rcd/): Art. 4, 7, 13, 15, 16, 17, 18, 19, 22, 24, 25
- [UAS — UAS Regulation](https://www.conphora.com/regulations/uas/): Art. 4, 6, 11, 13, 14, 15, 16, 17
- [PPE — PPE Regulation](https://www.conphora.com/regulations/ppe/): Art. 5, 8, 13, 15, 17, 18, 19
- [NAWI — Non-automatic Weighing Instruments Directive](https://www.conphora.com/regulations/nawi/): Art. 4, 6, 11, 13, 14, 16, 17, 18
- [CIR — Cableway Installations Regulation](https://www.conphora.com/regulations/cir/): Art. 6, 11, 12, 16, 18, 19, 21
- [EMC — Electromagnetic Compatibility Directive](https://www.conphora.com/regulations/emc/): Art. 6, 7, 12, 14, 15, 16, 17, 18, 19
- [TSD — Toy Safety Directive](https://www.conphora.com/regulations/tsd/): Art. 4, 9, 10, 11, 13, 15, 16, 17, 18, 19, 20, 21
- [ATEX — ATEX Directive](https://www.conphora.com/regulations/atex/): Art. 2, 4, 6, 11, 13, 14, 16
- [ELR — Energy Labelling Framework Regulation](https://www.conphora.com/regulations/elr/): Art. 2, 3, 4, 6, 8, 9, 10, 11, 12
- [FPR — Fertilising Products Regulation](https://www.conphora.com/regulations/fpr/): Art. 4, 6, 12, 15, 16, 17, 18, 19
- [GAR — Gas Appliances Regulation](https://www.conphora.com/regulations/gar/): Art. 5, 7, 12, 14, 15, 16, 17, 18
- [LiftD — Lifts Directive](https://www.conphora.com/regulations/liftd/): Art. 5, 7, 8, 13, 15, 16, 17, 19
- [LVD — Low Voltage Directive](https://www.conphora.com/regulations/lvd/): Art. 3, 6, 11, 15, 16, 17
- [ErP — Ecodesign Directive](https://www.conphora.com/regulations/erp/): Art. 3, 5, 7, 8, 11, 14, 15
- [ExplD — Civil Explosives Directive](https://www.conphora.com/regulations/expld/): Art. 5, 15, 20, 21, 23
- [MID — Measuring Instruments Directive](https://www.conphora.com/regulations/mid/): Art. 6, 8, 13, 17, 18, 19, 21, 22
- [RoHS — RoHS Directive](https://www.conphora.com/regulations/rohs/): Art. 4, 5, 7, 12, 13, 15
- [CER — Ceramics Directive](https://www.conphora.com/regulations/cer/): Art. 2, 2a
- [DetR — Detergents Regulation](https://www.conphora.com/regulations/detr/): Art. 3, 4, 4a, 5, 6, 7, 9, 11
- [MED — Marine Equipment Directive](https://www.conphora.com/regulations/med/): Art. 9, 10, 12, 15, 16, 25
- [TLR — Tyre Labelling Regulation](https://www.conphora.com/regulations/tlr/): Art. 4, 5, 9, 11
- [FCM — Food Contact Materials Framework Regulation](https://www.conphora.com/regulations/fcm/): Art. 15
- [REACH — REACH Regulation](https://www.conphora.com/regulations/reach/): Art. 5, 6, 10, 11, 12, 14, 22, 31, 32, 36, 41, 46, 56, 65, 67
- [MetrD — Metrology Framework Directive](https://www.conphora.com/regulations/metrd/): Art. 2, 4, 5, 6, 7, 8, 11, 12
- [TexR — Textile Regulation](https://www.conphora.com/regulations/texr/): Art. 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 19, 20
- [TPED — Transportable Pressure Equipment Directive](https://www.conphora.com/regulations/tped/): Art. 2, 4, 11, 12, 14, 15, 26, 33a, 33c
- [HWB — Hot-Water Boilers Directive](https://www.conphora.com/regulations/hwb/): Art. 7
- [OND — Outdoor Noise Directive](https://www.conphora.com/regulations/ond/): Art. 3, 4, 8, 11, 12, 14
- [PIM — Plastics Regulation](https://www.conphora.com/regulations/pim/): Art. 3a, 4, 5, 6, 8, 9, 10, 11, 12, 14a, 15, 16, 17, 18
- [BottD — Measuring Container Bottles Directive](https://www.conphora.com/regulations/bottd/): Art. 1, 2
- [FtLblD — Footwear Labelling Directive](https://www.conphora.com/regulations/ftlbld/): Art. 1, 4, 5
- [EUDR — EU Deforestation Regulation](https://www.conphora.com/regulations/eudr/): Art. 2, 5
- [POPs — POPs Regulation](https://www.conphora.com/regulations/pops/): Art. 2, 3, 4, 5
- [AerD — Aerosol Dispensers Directive](https://www.conphora.com/regulations/aerd/): Art. 3, 8
- [PVD — Paints Directive](https://www.conphora.com/regulations/pvd/): Art. 2, 3, 4
- [UoMD — Units of Measurement Directive](https://www.conphora.com/regulations/uomd/): Art. 1, 2, 3, 4
- [CosR — Cosmetics Regulation](https://www.conphora.com/regulations/cosr/): Art. 2, 4, 8, 10, 11, 12, 18
- [ELVD — ELV Directive](https://www.conphora.com/regulations/elvd/): Art. 4, 6, 8
- [PPWD — Packaging and Packaging Waste Directive](https://www.conphora.com/regulations/ppwd/): Art. 8, 9, 11

## Problems people in this role ask about

- [We are launching our first physical product in the EU](https://www.conphora.com/solutions/problem/first-product-launch/)
- [We added Bluetooth or Wi-Fi to an existing product](https://www.conphora.com/solutions/problem/connected-product-radio/)
- [We have never written a declaration of conformity](https://www.conphora.com/solutions/problem/first-declaration-of-conformity/)
- [We have no risk analysis for the product](https://www.conphora.com/solutions/problem/risk-analysis-missing/)
- [One product, several acts: we need one declaration](https://www.conphora.com/solutions/problem/several-acts-one-doc/)
- [Our test report refers to a withdrawn standard](https://www.conphora.com/solutions/problem/test-report-outdated/)
- [Which harmonised standards should we test against?](https://www.conphora.com/solutions/problem/which-standards/)
- [Do we need a notified body for our product?](https://www.conphora.com/solutions/problem/notified-body-needed/)
- [Hundreds of variants and only one set of documents](https://www.conphora.com/solutions/problem/variant-families/)
- [Can we provide the instructions online only?](https://www.conphora.com/solutions/problem/instructions-online-only/)
- [The product is too small for the required marking](https://www.conphora.com/solutions/problem/small-product-label/)
- [Our CE mark has the wrong proportions or placement](https://www.conphora.com/solutions/problem/ce-mark-wrong/)
- [We heard batteries must be removable by the user](https://www.conphora.com/solutions/problem/battery-removability/)
- [Our connected device faces new cybersecurity rules](https://www.conphora.com/solutions/problem/radio-cybersecurity/)
- [Our product failed an EMC test](https://www.conphora.com/solutions/problem/emc-test-failed/)
- [We designed our own eco label or badge](https://www.conphora.com/solutions/problem/own-eco-label/)
- [Our sustainability report needs product compliance data](https://www.conphora.com/solutions/problem/sustainability-report-products/)
- [A retailer wants proof of compliance before listing](https://www.conphora.com/solutions/problem/retailer-proof/)
- [A new regulation applies and nobody knows what changes](https://www.conphora.com/solutions/problem/new-regulation/)
- [A product needs to be recalled](https://www.conphora.com/solutions/problem/recall/)
- [Marketing wants to say the product is sustainable](https://www.conphora.com/solutions/problem/green-claim/)
- [A retailer's supplier portal asks questions we cannot answer](https://www.conphora.com/solutions/problem/retailer-supplier-portal/)
- [A retailer announces a compliance audit of our range](https://www.conphora.com/solutions/problem/retailer-compliance-audit/)
- [A retailer asks for proof that the CE mark is real](https://www.conphora.com/solutions/problem/retailer-asks-ce-proof/)
- [A business customer sends a compliance questionnaire](https://www.conphora.com/solutions/problem/b2b-customer-questionnaire/)
- [A tender requires compliance documentation per product](https://www.conphora.com/solutions/problem/tender-compliance-docs/)
- [A retailer asks for packaging data per product](https://www.conphora.com/solutions/problem/retailer-packaging-data/)
- [A retailer wants to sell our product under its own brand](https://www.conphora.com/solutions/problem/private-label-retailer/)
- [We do not know if our product needs CE marking](https://www.conphora.com/solutions/problem/needs-ce-marking/)
- [Are we the manufacturer, the importer or the distributor?](https://www.conphora.com/solutions/problem/which-role-are-we/)
- [We have no EU responsible person](https://www.conphora.com/solutions/problem/no-eu-responsible-person/)
- [We do not know which regulations apply to our product](https://www.conphora.com/solutions/problem/which-regulations-apply/)
- [We want to sell in another EU country](https://www.conphora.com/solutions/problem/new-eu-country/)
- [We do not know which languages the instructions must be in](https://www.conphora.com/solutions/problem/language-requirements/)
- [We want to appoint an authorised representative](https://www.conphora.com/solutions/problem/authorised-representative-mandate/)
- [We changed the product. Does our compliance still hold?](https://www.conphora.com/solutions/problem/product-change-recheck/)
- [Nobody in the company owns product compliance](https://www.conphora.com/solutions/problem/who-owns-compliance/)
- [We are unsure whether our product counts as a toy](https://www.conphora.com/solutions/problem/toy-or-not/)
- [We sell a product for babies or small children](https://www.conphora.com/solutions/problem/childcare-product/)
- [Management asks what the company is liable for](https://www.conphora.com/solutions/problem/management-liability/)
- [We are unsure whether our product is protective equipment](https://www.conphora.com/solutions/problem/ppe-or-not/)
- [Purchasing and marketing do not know the compliance basics](https://www.conphora.com/solutions/problem/train-the-team/)
- [We want to sell a cosmetic product in the EU](https://www.conphora.com/solutions/problem/cosmetic-product-launch/)
- [Our product touches food](https://www.conphora.com/solutions/problem/food-contact-product/)
- [We sell a machine or power tool](https://www.conphora.com/solutions/problem/machinery-or-tool/)
- [We are unsure whether our product is a medical device](https://www.conphora.com/solutions/problem/medical-or-wellness/)
- [We sell drones or drone accessories](https://www.conphora.com/solutions/problem/drone-product/)
- [Our product works under pressure](https://www.conphora.com/solutions/problem/pressure-equipment/)
- [We sell a scale or a measuring instrument](https://www.conphora.com/solutions/problem/measuring-instrument/)
- [We sell a construction product](https://www.conphora.com/solutions/problem/construction-product/)
- [We sell furniture and no specific EU act covers it](https://www.conphora.com/solutions/problem/furniture-general-safety/)
- [We sell in both the UK and the EU](https://www.conphora.com/solutions/problem/uk-and-eu/)
- [An authority asks for our technical documentation](https://www.conphora.com/solutions/problem/authority-asks-technical-file/)
- [We have sold for years without technical documentation](https://www.conphora.com/solutions/problem/no-technical-documentation/)
- [Which language must the declaration of conformity be in?](https://www.conphora.com/solutions/problem/doc-in-which-language/)
- [Our compliance documents are scattered everywhere](https://www.conphora.com/solutions/problem/documents-scattered/)
- [How long must we keep compliance documents?](https://www.conphora.com/solutions/problem/keep-documents-how-long/)
- [The person who knew our compliance has left](https://www.conphora.com/solutions/problem/employee-left/)
- [A buyer's due diligence asks for our compliance status](https://www.conphora.com/solutions/problem/due-diligence-buyer/)
- [Our label has no EU address on it](https://www.conphora.com/solutions/problem/label-no-eu-address/)
- [We do not know what the packaging rules mean for us](https://www.conphora.com/solutions/problem/packaging-rules-meaning/)
- [We are unsure whether we are a packaging producer](https://www.conphora.com/solutions/problem/packaging-producer-or-not/)
- [We do not know which recycling symbols to print](https://www.conphora.com/solutions/problem/recycling-labels/)
- [We do not know which warnings a toy needs](https://www.conphora.com/solutions/problem/warning-texts-toys/)
- [Our textile label lacks the fibre composition](https://www.conphora.com/solutions/problem/textile-label/)
- [We sell shoes without the material label](https://www.conphora.com/solutions/problem/footwear-label/)
- [Our product needs an energy label and EPREL registration](https://www.conphora.com/solutions/problem/energy-label/)
- [Our cosmetic label misses mandatory information](https://www.conphora.com/solutions/problem/cosmetics-label/)
- [Our packaging uses non-metric units](https://www.conphora.com/solutions/problem/units-of-measurement/)
- [A customer asks for our RoHS declaration](https://www.conphora.com/solutions/problem/rohs-substances/)
- [A customer asks if our product contains SVHCs](https://www.conphora.com/solutions/problem/reach-svhc-question/)
- [Could our product contain a banned persistent pollutant?](https://www.conphora.com/solutions/problem/pops-in-product/)
- [We sell jewellery: what are the nickel and lead limits?](https://www.conphora.com/solutions/problem/jewellery-nickel-lead/)
- [Our plastic toy was flagged for phthalates](https://www.conphora.com/solutions/problem/phthalates-toys/)
- [We want to sell a detergent or cleaning product](https://www.conphora.com/solutions/problem/detergent-product/)
- [We want to sell a fertiliser or a plant biostimulant](https://www.conphora.com/solutions/problem/fertiliser-product/)
- [An ingredient in our cosmetic has been banned or restricted](https://www.conphora.com/solutions/problem/cosmetics-banned-ingredient/)
- [We sell a product in a spray can](https://www.conphora.com/solutions/problem/aerosol-product/)
- [Our product contains a regulated explosives precursor](https://www.conphora.com/solutions/problem/explosives-precursors/)
- [Customers ask about chemicals in our clothing](https://www.conphora.com/solutions/problem/textile-chemicals/)
- [Our product contains a battery and we sell it as before](https://www.conphora.com/solutions/problem/battery-in-product/)
- [A customer asks about the battery passport](https://www.conphora.com/solutions/problem/battery-passport/)
- [We are asked about battery due diligence](https://www.conphora.com/solutions/problem/battery-due-diligence/)
- [We do not know how to label our batteries](https://www.conphora.com/solutions/problem/battery-labelling/)
- [We sell electronics and are not registered for take-back](https://www.conphora.com/solutions/problem/weee-registration/)
- [We heard our device must charge with USB-C](https://www.conphora.com/solutions/problem/charger-common-port/)
- [We sell LED lamps or luminaires](https://www.conphora.com/solutions/problem/led-lighting/)
- [We sell e-bikes or e-scooters](https://www.conphora.com/solutions/problem/e-bike-e-scooter/)
- [Our product falls under an ecodesign regulation](https://www.conphora.com/solutions/problem/ecodesign-requirements/)
- [A customer asks when we will have a digital product passport](https://www.conphora.com/solutions/problem/dpp-preparation/)
- [We made a green claim and cannot document it](https://www.conphora.com/solutions/problem/green-claim-no-evidence/)
- [We call our product climate neutral](https://www.conphora.com/solutions/problem/climate-neutral-claim/)
- [We claim recycled content and are asked for proof](https://www.conphora.com/solutions/problem/recycled-content-claim/)
- [We call the product biodegradable or compostable](https://www.conphora.com/solutions/problem/biodegradable-claim/)
- [We do not know which claims are on our own website](https://www.conphora.com/solutions/problem/website-claims-audit/)
- [We advertise durability or repairability](https://www.conphora.com/solutions/problem/durability-repair-claims/)
- [We sell single-use plastic products](https://www.conphora.com/solutions/problem/single-use-plastic/)
- [A large customer asks for ESG data per product](https://www.conphora.com/solutions/problem/esg-customer-request/)
- [A competitor complained about our environmental claim](https://www.conphora.com/solutions/problem/competitor-complaint-claim/)
- [A customer was injured by our product](https://www.conphora.com/solutions/problem/customer-injured/)
- [We got a safety complaint and cannot tell if it is serious](https://www.conphora.com/solutions/problem/safety-complaint/)
- [A market surveillance authority sent us a letter](https://www.conphora.com/solutions/problem/authority-letter/)
- [Our product, or one like it, is on Safety Gate](https://www.conphora.com/solutions/problem/product-on-safety-gate/)
- [We do not know how to word the recall notice](https://www.conphora.com/solutions/problem/recall-notice-wording/)
- [We cannot reach the customers who bought the product](https://www.conphora.com/solutions/problem/reach-the-buyers/)
- [We do not know whether to withdraw or recall](https://www.conphora.com/solutions/problem/withdrawal-or-recall/)
- [We have to report in the Safety Business Gateway](https://www.conphora.com/solutions/problem/safety-business-gateway/)
- [We keep no register of complaints](https://www.conphora.com/solutions/problem/complaints-register/)
- [An authority's test purchase failed](https://www.conphora.com/solutions/problem/test-purchase-failed/)
- [We do not know which remedy we must offer in a recall](https://www.conphora.com/solutions/problem/recall-cost-remedy/)
- [We must recall a product sold in several EU countries](https://www.conphora.com/solutions/problem/recall-in-several-countries/)
- [The recall is over and we want to prevent the next one](https://www.conphora.com/solutions/problem/after-the-recall/)
- [We are outside the EU and ship directly to EU consumers](https://www.conphora.com/solutions/problem/non-eu-seller-direct/)
- [A marketplace asks for our EU responsible person](https://www.conphora.com/solutions/problem/marketplace-responsible-person/)
- [A marketplace wants our declaration and test report uploaded](https://www.conphora.com/solutions/problem/marketplace-doc-upload/)
- [Our e-commerce parcels are mostly air](https://www.conphora.com/solutions/problem/packaging-empty-space/)
- [Our plastic kitchen product has no declaration of compliance](https://www.conphora.com/solutions/problem/plastic-food-contact/)
- [A customer asks where our wood, cocoa or rubber comes from](https://www.conphora.com/solutions/problem/deforestation-origin/)
- [We onboard a new supplier and want the documents first](https://www.conphora.com/solutions/problem/new-supplier-onboarding/)
- [The supplier changed a component without telling us](https://www.conphora.com/solutions/problem/supplier-changed-component/)
- [Our supplier contract says nothing about compliance](https://www.conphora.com/solutions/problem/contract-compliance-clauses/)
- [We audit the factory but not the product compliance](https://www.conphora.com/solutions/problem/factory-audit-scope/)

## Questions about the role

### A factory makes the product for us. Is the factory the manufacturer?

Not if the product is marketed under your name or trademark. The definition covers a person who has a product designed or manufactured and markets it under its own name (GPSR Article 3(8)).

### We only put our logo on the box. Are we still the manufacturer?

The test is whether the product is placed on the market under your name or trademark (GPSR Article 13(1); Low Voltage Directive Article 10). The Commission's Blue Guide includes those who pack or label ready-made products under their own name. If the box presents the product as yours, assume you are the manufacturer.

### Do the test reports have to be in our name?

No. The Blue Guide says the documentation and certificates need not be in the own-brand manufacturer's name, but it must be clear that they demonstrate compliance of the specific product placed on the market.

### Can an authorised representative take over our duties?

Only the tasks named in a written mandate. Under the Low Voltage Directive the duty to design and manufacture in conformity and the duty to draw up the technical documentation cannot form part of the mandate (Article 7(1)), and the Blue Guide states that a manufacturer may in no circumstances discharge itself of its responsibilities to an authorised representative.

### We are established outside the EU. Can we sell without an importer?

A product covered by the GPSR or by the CE acts listed in Article 4(5) of Regulation (EU) 2019/1020 may be placed on the market only when an economic operator established in the Union is responsible for it. Without an importer, the manufacturer can appoint an authorised representative with a written mandate.

### Is the manufacturer liable for damage a product causes?

Liability for damage is a separate regime from the duties on this page. Under the Product Liability Directive (EU) 2024/2853, which applies to products placed on the market or put into service from 9 December 2026, the manufacturer of a defective product is liable for the damage it causes, as national law transposing the directive provides (Articles 2(1) and 8(1)(a)). Directive 85/374/EEC continues to apply to products placed on the market or put into service before that date (Article 21).

## Sources

1. [Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529) — EUR-Lex, 2026-10-05
2. [Directive 2014/35/EU on electrical equipment (Low Voltage Directive), consolidated text of 30 May 2026](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0035-20260530) — EUR-Lex, 2026-10-05
3. [Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1020-20260812) — EUR-Lex, 2026-10-05
4. [Decision No 768/2008/EC on a common framework for the marketing of products](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008D0768) — EUR-Lex, 2026-10-05
5. [The 'Blue Guide' on the implementation of EU product rules 2022 (2022/C 247/01)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52022XC0629(04)) — European Commission, via EUR-Lex, 2026-10-05
6. [Directive (EU) 2024/2853 on liability for defective products](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024L2853) — EUR-Lex, 2026-10-05