One company may sell similar products and yet have a different role for each of them. In one case it will be the manufacturer under its own brand, in another the importer of goods from outside the European Union, and in a third only the distributor of a product bought from a European supplier. The GPSR links tasks to the undertaking's actual role in the supply chain, so simply entering the company name in a form is not enough.

Why the company's role must be determined for the product

The role does not follow only from the PKD code, the description of business activity or how the company presents itself to customers. What matters includes the origin of the product, the place of establishment of the manufacturer, the way it is marked, the use of its own brand and whether the undertaking modifies the product in a way that may affect safety. The same seller may therefore need different sets of data for different SKUs.

In practice, it is worth recording for each product: who manufactures it, who places it on the EU market, who makes it available further, what name or brand appears on the product and who is the responsible person in the Union. Such a record should have a source, a date and the person who approved it. This means the decision does not disappear in correspondence with the supplier and can be reassessed if the product or counterparty changes.

Manufacturer - not always a factory

A manufacturer is an entity that manufactures a product or has it designed or manufactured and offers it under its own name or trademark. A company ordering a finished product with its own logo may therefore carry out the manufacturer's duties, even if it does not have a production plant. This is important for own brands, importers commissioning production and sellers using the private label model.

Operationally, this means the need to maintain product identification, technical data, risk analysis, instructions, warnings and information enabling the origin of the batch to be traced. Documentation should not be limited to a certificate sent by the factory. It is necessary to know which variant the document concerns, whether it corresponds to the SKU being sold and who approved the use of the evidence.

Importer - the first entity placing a product from a third country

An importer is established in the Union and places a product from a third country on the EU market. Before making the product available, it should check whether the manufacturer has carried out the required actions, whether the product can be identified and whether it is accompanied by the appropriate information. The importer's data must be linked to the actual product, and not only to a general supplier card.

For an importer, a controlled handling of gaps is particularly important. If the supplier has not provided material for risk analysis, instructions or identification data, the gap should have an owner, a deadline and a status. Receiving a file does not yet mean that its scope, currency and link to the variant have been checked.

Distributor - duties do not end with buying from an EU supplier

A distributor makes a product available on the market but is neither the manufacturer nor the importer. It should act with due care, verify the required markings and information and react when it has reason to believe that the product may be dangerous or does not meet requirements. Storage and transport conditions under its control should also not worsen product safety.

In a distributor's documentation, it is worth keeping the supplier's data, product identification, the version of instructions and warnings, the date of the offer check and evidence of actions taken after a problem was reported. Such a set does not have to copy the manufacturer's entire dossier, but it should make it possible to show what the company checked and on what basis it allowed the product into its sales process.

Responsible person in the Union

For a product covered by the responsible person requirement, there must be a suitable entity established in the EU. Depending on the supply chain, this may be a Union manufacturer, an importer, an authorised representative or a fulfilment service provider meeting the relevant conditions. The data of that entity should be consistent in the documentation, on the product or packaging and in the distance selling offer.

The responsible person is not merely an address to be entered on a marketplace. It has specific tasks connected, among other things, with documentation, product information and cooperation with authorities. Therefore, before using the data, it is necessary to check the basis for performing this function, the scope of authorisation and the products concerned.

What an own brand or product modification changes

An undertaking may take over the manufacturer's duties if it makes the product available under its own name or mark, or modifies it in a way that may affect safety. A change of marketing packaging will not always have the same effect as a change of design, software, material or intended purpose. The assessment should be documented for the specific situation.

In the data system it is advisable to separate the base product from the variant sold under a given brand. The differences, shared documents, documents requiring separate assessment and the date of the decision should be recorded. Without this, it is easy to transfer the result of the analysis of one variant to another without justification.

Practical role sheet for an SKU

The most common mistake: one role assigned to the whole company

Setting one global role may be convenient, but it leads to overlooking differences between products. A safer model combines organisation data with a role sheet for the product or product family. A change of supplier, brand, country of origin or method of placing on the market should trigger a fresh review.

The GPSR / PPWR platform helps to keep these relationships, sources and decision history. However, it does not assign a role to the company automatically. The final classification belongs to the undertaking and, where necessary, its adviser.