what obligations do I incur as a manufacturer of a private label product

Private label means: manufacturer, with all the obligations that come with it

Anyone who has a product made by a third party and places it on the market under their own name or brand is considered a manufacturer for the purposes of GPSR — not a distributor or importer, even if the factory is in another country and all production takes place there. This is precisely the own-brand rule that comes up repeatedly on this platform: it is not about who physically made the product, but about whose name or brand appears on it. A webshop that only has a logo printed on a ready-made purchased article falls under the same rule. Anyone in doubt about whether this applies to their own situation can verify this with Am I a manufacturer if I put my own brand on a purchased product?.

As a manufacturer, a series of obligations apply that a distributor does not have: drawing up technical documentation, conducting a risk analysis per product, ensuring correct instructions and warnings in the consumer's language, and maintaining a complaints register. For supply to Dutch consumers, this means Dutch-language labels and product information — English or German is not sufficient. A distributor who only resells a private label product without changing the brand or name remains a distributor and does not carry those manufacturer obligations; the distinction between roles is therefore not a formality but determines which obligations do or do not apply, as described at What are the obligations of a distributor under the GPSR?.

Where this follows from: Article 3 and 13 of the regulation

Article 3 of Regulation (EU) 2023/988 defines the concept of manufacturer, and Article 13 explicitly determines who else is also considered a manufacturer — including anyone who places a product on the market under their own name or brand or substantially modifies a product after it has been placed on the market. Articles 9 through 12 of the same regulation then set out the specific obligations applicable to each role, with a clear distinction between what is expected of a manufacturer and a distributor.