Whoever purchases a product and resells it unchanged, under the brand of the original manufacturer, within the EU, is considered a distributor under the regulation. This role does not carry an obligation to prepare technical documentation or a risk analysis as a manufacturer would. However, compliance duties do apply: checking whether the product bears the required information, warnings and markings, and not supplying it if there is reason to assume the product does not meet the requirements.
The essence of this role is therefore not "nothing to do", but "less than a manufacturer, and something different from an importer". As soon as you change anything on the product or packaging, or place your own brand on it, the role shifts — and with it the obligations. This is precisely the point where many resellers miscalculate their own position.
What a pure reseller must do
The regulation requires a distributor to check, before a product is offered, whether the required product information is present: name and contact details of the manufacturer or importer, a product identification such as a type or batch number, and where applicable the warnings in the language of the market where the product is offered. This is a check for presence, not a substantive assessment of the safety of the product itself.
Additionally, there is a duty to cooperate: if a supervisory authority asks for information about the origin of a product, a distributor must be able to provide it. This requires basic record-keeping — who supplied the product, when, in what quantity — even if no per-article file is maintained as is customary for a manufacturer or importer. How such internal registration can be structured, and which documents are practically useful, you can read in the knowledge base with explanations per role and obligation.
Where the role changes
The boundary between reseller and manufacturer is closer than many entrepreneurs think. Your own logo on the packaging, modified instructions for use, or bundling products into a new assembled article: these are all actions that the regulation may classify as "placing on the market under its own name", with the manufacturer obligations that come with it. Importing a product yourself from outside the EU also changes the role, regardless of whether anything else is changed on the product.
Whether a specific situation falls within the definition of distributor or already extends to manufacturer or importer depends on what actually happens to the product before it reaches the consumer. You can get an indication of where you stand as a business from the role check that maps out your position in just a few questions. This check is free and also explicitly states when an obligation does not apply to you.
What a reseller does not need to do
It is equally relevant to clarify what is not required of a pure distributor. There is no need to prepare technical documentation, no risk analysis as required for a manufacturer, and no obligation to assess yourself whether a product meets all safety requirements. That responsibility lies with the manufacturer, or with the importer if the product comes from outside the EU.
That does not mean a distributor can remain passive once signals emerge that a product is not in order. In case of reasoned doubt — for example a consumer complaint, or a publication on the European warning system about a comparable product — the regulation expects a distributor to respond, for instance by informing the manufacturer or importer or by stopping further supply. How those signals are captured and followed up internally is precisely where a compliance system with a complaints register proves its value, including for companies that are not manufacturers themselves.
In practice: what this means for your administration
For a reseller, the practical task is often more limited than for a manufacturer, but not zero. It concerns three things: knowing who a product comes from, being able to demonstrate that the required information was present on the product or packaging at the moment it was placed on the market, and having a way to respond if questions arise about this. What this requires in practice in terms of templates and documentation, and how that differs per product category, is detailed in the overview of the subscription with the associated templates.
Anyone uncertain whether their own position in the supply chain still falls within the distributor role would be well advised to clarify this first before investing time in a file that may not be necessary — or, conversely, before overlooking obligations that do apply. Start with the free role check for this, or read in the frequently asked questions about roles and obligations how other entrepreneurs view this issue.