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Who is a manufacturer? The GPSR defines a manufacturer as any natural or legal person who manufactures a product or has a product designed or manufactured, and who markets the product under the person’s name or trademark. Firstly, the manufacturer must first have either manufactured the product, or had a product designed or manufactured on its behalf. Secondly, it must market the product under its name or trademark. Natural or legal persons are therefore considered manufacturers if they market the product under their name (even if they did not produce the product themselves); additionally, they are also considered manufacturers if they substantially modify the product manufactured by another person and place it themselves on the market. Example: A company A purchases mugs from another company B that produced them. Company A brands them with its logo and sells to consumers. Company A becomes the manufacturer of these mugs and is subject to the manufacturer’s obligations under the GPSR.

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Source: EUR-Lex (Cellar) · retrieved 2026-09-07 · Text as adopted (Official Journal); later amendments are not incorporated in this text.