Manufacturer, Importer, Distributor: Your GPSR Role

Two Allegro sellers sell identical solar lamps from China. The first imports them directly from 1688 and lists them in Poland. The second buys the same lamps from a Polish wholesaler. Both get asked about GPSR — but their obligations differ dramatically. Why? Because GPSR assigns obligations not to "the seller", but to the specific role you play in the supply chain.

This article explains the difference between manufacturer, importer and distributor under GPSR (General Product Safety Regulation, EU 2023/988), and how to recognise which role you play — because that determines how much work lies ahead of you.

Key points at a glance

• GPSR (Regulation EU 2023/988) distinguishes between economic operators: manufacturer, importer, distributor and platform provider.

• Your role is determined by what you do with the product, not by how you name your business.

• Importing from outside the EU = usually the importer role, with the widest scope of obligations.

• Selling under your own brand can make you a manufacturer even without your own factory.

Manufacturer — who counts as one under GPSR

A manufacturer isn't only someone who physically produces a product. GPSR also treats as a manufacturer anyone who:

• sells a product under their own name or trademark (private label),

• significantly modifies a product already placed on the market.

This matters for importers from China: if you commission production and brand the goods with your own logo, under GPSR you're a manufacturer, even though you don't have your own factory. The manufacturer has the widest scope of obligations: risk assessment, technical documentation, warnings, traceability, and ensuring an EU responsible person.

Importer — the most common role for a seller from China

You're an importer when you're the first to bring a product from outside the EU and make it available on the Union market. This is the dominant situation in trade with AliExpress, 1688 or Alibaba. Because the Chinese manufacturer is outside EU jurisdiction, the importer takes on the key obligations:

• checking that the manufacturer carried out a risk assessment and the product is safe,

• placing your own details (name, address) on the product or packaging,

• ensuring warnings and instructions in Polish,

• fulfilling or designating the EU responsible person,

• keeping documentation and cooperating with market surveillance authorities.

Distributor — narrower scope, but not zero

You're a distributor when you make available on the market a product already placed in the EU by someone else — e.g. you buy from a Polish wholesaler. Your obligations are smaller, but real:

• you check whether the product has the required markings, manufacturer/importer data, and responsible person data,

• you don't make available a product you know, or should know, is dangerous,

• you cooperate with authorities and provide information allowing the supplier to be identified.

Comparing the roles

Obligation	Manufacturer	Importer	Distributor
Risk assessment	Yes	Verifies / creates	No
Technical documentation	Yes	Yes (holds/has access)	No
Data on the product	Yes	Yes (own)	Checks presence
EU responsible person	Ensures	Fulfils/designates	Checks presence
Warnings in Polish	Yes	Yes	Checks presence

How to recognise your role — three questions

1. Do I sell under my own brand or significantly modify the product? → if yes, you're a manufacturer.
2. Am I the first to bring the product in from outside the EU? → if yes, you're an importer.
3. Do I buy goods already present on the EU market and just resell them? → if yes, you're a distributor.

You can play several roles at once for different products. What matters is knowing, for each product, which role you're in — because that determines the scope of documentation. We map out the full implementation path in GPSR step by step — from product to compliance. We explain who is covered and since when in GPSR — since when it applies and who it covers.

Platform provider — the fourth role

For completeness, it's worth mentioning the fourth role, played by marketplaces such as Allegro, Amazon or Kaufland. GPSR imposes its own obligations on online platform providers: enabling sellers to provide safety data, reacting to reports of dangerous products, cooperating with authorities, and removing listings linked to Safety Gate entries.

This is why the platform enforces GPSR data from you — not on its own initiative, but because it is itself subject to the regulation. Your role (importer/distributor) and the platform's role overlap: you create and provide the data, the platform enforces and verifies it.

Why the role can't be "outsourced" to China

It's tempting to think: "the Chinese factory is the manufacturer, let it be responsible". GPSR is unambiguous here — the obligations of a manufacturer outside the EU, who cannot be held accountable within the Union, pass to the importer. This isn't about unfairness, but effectiveness: the consumer in Poland and the Polish authority need a real, reachable responsible entity. A factory in Shenzhen won't show up in response to a UOKiK summons and won't accept a return of a faulty batch. You, as the importer, are that reachable "anchor", and that's why the burden of documentation rests on you.

Frequently asked questions

Am I a manufacturer if I don't have my own factory?

Yes, if you sell the product under your own name or trademark, or significantly modify it. GPSR also treats private-label sellers as manufacturers if they commission production in China and brand the goods with their own logo, despite not having their own factory.

How does an importer differ from a distributor?

An importer is the first to bring a product in from outside the EU and takes on the manufacturer's obligations: risk assessment, data on the product, responsible person, warnings in Polish. A distributor resells goods already present on the EU market and mainly checks that the required markings and data are present.

I buy from AliExpress and sell in Poland — what am I?

Most likely an importer. You bring the product in from outside the EU and are the first to make it available to consumers in the Union, so you take on the key obligations of the manufacturer, who can't be held accountable outside EU jurisdiction.

Can I play several roles at the same time?

Yes. For some products you may be an importer (bringing them in from China), and for others a distributor (buying from a Polish wholesaler). Determine the role separately for each product, because it decides the scope of GPSR documentation required.