We sell imported goods under our own brand
Placing a product on the market under your own name or trademark makes you its manufacturer, even if a factory abroad designed and built it (GPSR Article 13(1); LVD Article 10). You then carry the full manufacturer duties: technical documentation, conformity assessment and declaration in your name, your details on the product and the complaints register. Secure the factory's documentation before you put your brand on it.
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Reviewed 4 October 2026 by the Conphora compliance team · Not legal advice
Why this happens
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 the manufacturer and is subject to the manufacturer's obligations in Article 9 (Article 13(1)). The Low Voltage Directive 2014/35/EU says the same for importers and distributors (Article 10).[1][2]
The Commission's Blue Guide calls these businesses own-brand labellers or private labellers. The manufacturer's responsibilities apply to anyone who assembles, packs, processes or labels ready-made products and places them on the market under its own name or trademark. Such an operator takes the entire responsibility for the conformity assessment, even if somebody else actually did it, and must have all documentation, including test reports, and certificates at its disposal. These do not need to be in its name, but they must clearly cover the specific product. A manufacturer who subcontracts may in no circumstances discharge itself of its responsibilities.[3]
The duties are the full set. Under the GPSR, the manufacturer carries out the internal risk analysis and draws up and updates the technical documentation, keeps it for 10 years, has procedures so that series production stays in conformity, puts a product identifier and its name and addresses on the product, supplies instructions and safety information, offers complaint channels and keeps a complaints register (Article 9). For products under Union harmonisation legislation, Chapter III, Section 1 of the GPSR does not apply (Article 2(1), third subparagraph, point (b)); the sector act sets the same core duties, for example the conformity assessment, the EU declaration of conformity and the CE marking under the Low Voltage Directive (Article 6).[1][2]
An own-brand manufacturer established in the Union is also the economic operator responsible for the product towards market surveillance authorities (Regulation (EU) 2019/1020, Article 4(2)(a); GPSR Article 16(1)). The authorities can require documents from it in any form and wherever they are stored (Regulation (EU) 2019/1020, Article 14(4)(a)).[1][4]
How to solve it
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List every product that carries your brand
Include the products where you only changed the label, the packaging or the name. A business that packs or labels ready-made products and places them on the market under its own name or trademark takes on the manufacturer's responsibilities. Where the factory's own brand stays on the product and you add an importer label, you remain the importer.
Regulation guidesKnow-how Free Open -
Get the factory's documentation into your hands
The own-brand manufacturer must have all the documentation and certificates needed to show conformity at its disposal. They do not have to be in your name, but they must clearly cover the specific product you place on the market. Agree with the factory that you receive the full technical documentation, the test reports and any certificates, and that they stay available for the whole retention period.
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Issue the declaration in your own name
For CE-marked products, the manufacturer draws up the EU declaration of conformity and, by doing so, assumes responsibility for compliance. That is now you. For consumer products under the GPSR alone, you carry out the internal risk analysis and keep the technical documentation as the manufacturer.
Documentation generatorCompliance engine Open in the console -
Put your details and the identification on the product
Your name, registered trade name or trade mark and your postal and electronic address go on the product, or on the packaging or an accompanying document where that is not possible, together with a type, batch or serial number. Established in the EU, you are also the economic operator responsible for the product towards the authorities.
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Take on the manufacturer's after-sales duties
Set up a public channel for complaints, investigate safety complaints and keep the internal register of complaints, recalls and corrective measures. Make sure series production stays in conformity: ask the factory to tell you about changes before they ship.
Work through the steps in the platform with your own product.
What you need to show
| Document | Where it comes from | Legal ground |
|---|---|---|
| Technical documentation for each own-brand product, including test reports and certificates | The factory, held at your disposal | GPSR Articles 9(2) and 13(1); LVD Articles 6(2) and 10 |
| EU declaration of conformity in your name, for CE-marked products | You, as manufacturer | LVD Article 15(4) |
| Label artwork with your name, addresses and the product identifier | Your packaging files | GPSR Article 9(5) and (6) |
| Complaints register and the agreement on change notification with the factory | Your quality files | GPSR Article 9(4) and (12) |
If you do nothing
You answer for a design you never saw
The person who places a product under its own name or trademark is deemed the manufacturer and subject to the manufacturer's obligations (GPSR Article 13(1)). The Blue Guide adds that a manufacturer who subcontracts cannot discharge itself of its responsibilities to a subcontractor.[1]
No file when the authority asks
Manufacturers keep the technical documentation at the disposal of market surveillance authorities for 10 years and make it available on request (GPSR Article 9(3)). Authorities can require documents wherever they are stored and order corrective action (Regulation (EU) 2019/1020, Article 14(4)).[4]
Penalties under national law
Member States lay down effective, proportionate and dissuasive penalties for infringements of the GPSR (Article 44).[1]
Questions about this problem
The factory has already CE-marked the product. Is that not enough?
Not once your brand is on it. The economic operator that places the product under its own name or trademark becomes the manufacturer and takes the entire responsibility for the conformity assessment, even if somebody else carried it out (Blue Guide, section 3.1). Hold the factory's evidence and sign the declaration yourself.
Do the test reports have to be in our name?
No. The Blue Guide says the documentation and certificates need not be under the own-brand manufacturer's name, but it must be clear that they demonstrate compliance of the specific product placed on the market.
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); LVD Article 10). The 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.
Can a distributor become the manufacturer too?
Yes. The GPSR applies the rule to any natural or legal person placing a product under its own name or trademark (Article 13(1)), and the Low Voltage Directive names importers and distributors expressly (Article 10).
Sources
- Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026) EUR-Lex · accessed 4 October 2026
- Directive 2014/35/EU on electrical equipment (Low Voltage Directive), consolidated text of 30 May 2026 EUR-Lex · accessed 4 October 2026
- The 'Blue Guide' on the implementation of EU product rules 2022 (2022/C 247/01) European Commission, via EUR-Lex · accessed 4 October 2026
- Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026) EUR-Lex · accessed 4 October 2026
About this page
- Reviewer
- Conphora compliance team
- Reviewed
- 4 October 2026
General information, not legal advice. Check the legal text or ask an adviser about your own product.
Conphora (2026). We sell imported goods under our own brand. Retrieved 13 October 2026 from https://www.conphora.com/solutions/problem/own-brand-import/
Conphora (2026) We sell imported goods under our own brand. Available at: https://www.conphora.com/solutions/problem/own-brand-import/ (Accessed 13 October 2026).
@misc{conphora2026wesellimportedgoodsunder,
author = {Conphora},
title = {We sell imported goods under our own brand},
year = {2026},
url = {https://www.conphora.com/solutions/problem/own-brand-import/},
note = {Retrieved 13 October 2026}
} See it working before you add a product
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