File 03: Economic operators and their duties
Manufacturer, importer, distributor, fulfilment provider and marketplace: who owes what, and where duties change hands.
The file guide
Working guides in this file
03Changed It, Own the Change: Responsibility After Modification When a product is modified, responsibility follows the modification, so the business that changes design, material, or use must assess whether the change creates a new risk or a new product. 03Dropshipping Without Seeing the Product: Duties That Still Apply Dropshipping does not remove product safety duties, because the seller who offers the product still owes care over identification, listing accuracy, and action when complaints arrive, even without ever touching stock. 03First Foot in the EU: Importer Duties Under GPSR Importer duties under GPSR begin before the product enters the market, covering identification, checks on the manufacturer work, contact details, and readiness to act if a problem surfaces. 03Made It, Own It: Manufacturer Duties Under GPSR Manufacturer duties under GPSR cover the safety work before sale, from hazard identification and design choices through labelling, identification, and keeping complaint and recall readiness in place. 03Marketplaces Are Not Bystanders: Their Duties Explained Online marketplace duties cover the systems that let dangerous products be spotted, listings checked, and takedowns and consumer warnings handled, alongside duties of the sellers who use them. 03Paper That Protects Products: Contracts That Back Safety Duties Contracts support product safety duties when they name who supplies what information, who keeps which records, and what happens when a safety question arises, rather than merely fixing price and delivery. 03Shared Work, Clear Edges: Splitting Duties Across a Chain Sharing duties across a supply chain works when each handover names what was checked, what was passed on, and what remains open, so no duty falls between two businesses. 03The Middle of the Chain: What Distributors Owe Under GPSR Distributor duties under GPSR centre on care before making a product available, checking identification and labelling, storing products properly, and acting promptly when a safety issue emerges. 03The Warehouse in the Middle: Fulfilment Provider Duties Fulfilment service providers owe care over storage, packing, and handling that can affect safety, and over cooperation when a product needs to be identified, withdrawn, or traced. 03When a Distributor Crosses the Line into Manufacturer Duties A distributor becomes subject to manufacturer duties when it puts its own name on a product, or modifies a product in a way that affects safety, so the role changes with the act, not with the job title. 03Your Name on It, Your Duties With It: Private Label Responsibility Private label and own brand responsibilities mean the business whose name appears on the product carries manufacturer level duties, even when another factory physically makes it.