ntr15-C_2021100EN.01000101-E0015
(15) The manufacturer is defined by Article 3 of the Regulation as ‘any natural or legal person who manufactures a product or has a product designed or manufactured, and markets that product under its name or trademark’. The importer is defined as ‘any natural or legal person established within the Union who places a product from a third country on the Union market’. This implies that if the product is manufactured outside the EU, but a company located in the EU markets it under its name or trademark, that company is considered to be the manufacturer. And if that manufacturer places the product on the EU market, even if actual importation is done by another company, there is no ‘importer’ within the meaning of the Regulation.
Source: EUR-Lex (Cellar) · retrieved 2026-09-25 · Text as adopted (Official Journal); later amendments are not incorporated in this text.