Am I a manufacturer if I put my own brand on a purchased product?

Your own brand on a product makes you a manufacturer

Yes: whoever places a product on the market under their own name or own brand is considered a manufacturer under GPSR — even if the product was made elsewhere and only the logo has been added. It is not about who physically produced the product, but about whose name it reaches the consumer under. A web shop that purchases a ready-made product from a factory and has its own brand name placed on it is therefore not a distributor under GPSR but a manufacturer, with the full set of obligations that entails: from risk analysis to technical documentation.

This does not only apply to a logo. Anyone who materially modifies a product — changes the composition, adds something, or changes its intended use — can thereby become a manufacturer themselves, even without their own brand name on it. That is the other side of the same rule: the criterion is not who sealed the box, but who presents themselves outwardly as responsible or has materially changed the product. A party that resells a product unchanged under another's brand remains a distributor, and therefore does not bear the manufacturer's obligations — that lighter role does indeed exist, just not for anyone who puts their own name on it. This role division follows directly from the Regulation and applies in exactly the same way in all twenty-seven Member States; what differs from country to country is the supervisory authority and the language in which the mandatory information must reach the consumer, not the question of whether someone is a manufacturer.

Where that appears in the Regulation: Article 3 and 13

Article 3 of Regulation (EU) 2023/988 defines the concept of manufacturer, and Article 13 clarifies when another market participant than the original producer is nonetheless classified as a manufacturer — including when carrying their own name or brand on the product, and when it is substantially modified.