§4.1 Manufacturers established in the EU

A manufacturer is a natural or legal person that manufactures a product or has a product designed or manufactured, and markets that product under its name or trademark (Article 3 of the Regulation) (34). If established in the EU, it is in principle the economic operator referred to in Article 4, unless it has appointed an authorised representative for the specific tasks under Article 4. Manufacturers established in the EU already have responsibilities under sector-specific legislation that in general overlap with and go beyond the obligations under Article 4(3). An exception is that – unlike Article 4 – EU legislation on outdoor noise, machinery and ecodesign does not explicitly require them to inform the market surveillance authorities where they have reason to believe that a product covered by such legislation presents a risk. Manufacturers established in the EU and who are the economic operator referred to in Article 4 will however have to do this for the products covered by these legislative acts. Most sector-specific legislation requires that the manufacturer’s name/trademark and address are indicated on the product; however: — for some sectors, that information can in certain circumstances be indicated on the packaging or in an accompanying document instead, — ecodesign legislation contains no such requirement, — the legislation on outdoor noise and machinery requires instead that the name and address be indicated in the declaration of conformity (35) (or in the declaration of incorporation, in the case of partly completed machinery (36)) and that the declaration accompany the product (37). Therefore, in the exceptional case of a product covered by ecodesign legislation but not by the other sector-specific legislation covered by Article 4, Article 4 requires manufacturers established in the EU and who are the economic operator referred to in Article 4 to take the additional action of indicating their name and contact details.

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Source: EUR-Lex (Cellar) · retrieved 2026-09-07