§4.2.2.4 Possible scenarios

The product must always bear the manufacturer’s name and address. Imported products must also bear the importer’s name and address. Products under the scope of Article 4 of Regulation (EU) 2019/1020 and placed on the Union market must bear the name and address of the responsible economic operator established in the EU. Hence, in conclusion, a product normally bears one or two addresses (214): — If the manufacturer is within the European Union, the product will bear only one (manufacturer’s) address as there is no importer involved. — If the manufacturer (declaring himself as a manufacturer by putting his name and address on the product) is outside the EU and the products are placed on the Union market by an importer, the product will bear two addresses: the one of the manufacturer and the one of the importer. — If the original manufacturer is outside the EU and the importer places the product on the market under his own name or trademark or modifies the product already placed on the market (in such a way that compliance with the applicable requirements may be affected), the importer is considered the manufacturer. The only address that in this case will figure on the product (or packaging or accompanying document) is the address of the importer who is considered as the manufacturer (215) (216). — If the manufacturer is within the EU (a company located in the EU declaring itself to be a manufacturer by putting its name and address on the product) although the products are manufactured outside the EU, that company is considered to be the manufacturer who places the product on the Union market, even if actual importation is done by another company. In this case there is no importer in the meaning of the importer’s definition and it is sufficient to put only the manufacturer’s address. — Where the product falls within the scope of Article 4 of Regulation (EU) 2019/1020 and is placed on the Union market, if the manufacturer is located outside the EU, there is no importer for the product (because it is shipped directly or via fulfilment service provider to the end-user from outside the Union), and the manufacturer has appointed an authorised representative to fulfil on its behalf the tasks of Article 4(3), the product will have to include two addresses (or the packaging or accompanying document, or for the economic operator referred to in Article 4, the parcel): the manufacturer’s and the authorised representative’s as the economic operator referred to in Article 4. This will also be the case if the manufacturer is established inside the EU but has appointed an authorised representative to fulfil on its behalf the tasks of Article 4(3). — Where the product falls within the scope of Article 4 of Regulation (EU) 2019/1020 and is placed on the Union market, if the manufacturer is located outside the EU, there is no importer and the manufacturer has not appointed an authorised representative, but the product is handled by a fulfilment service provider established in the EU, two addresses must be indicated on the product (or the packaging or accompanying document, or for the economic operator referred to in Article 4, the parcel): the manufacturer’s and the fulfilment service provider’s as the economic operator referred to in Article 4.

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