Yes, in most cases. The GPSR regulation does not look at who designed or produced a product, but at who places it on the market under their own name or brand. As soon as your logo, your house style, or your brand name appears on the product, packaging, or accompanying documentation, the regulation treats you as a manufacturer — even if you purchased the product unchanged from a factory that also sells it under its own name.
For many entrepreneurs, this is the first real surprise with GPSR: it is not about who makes something, but about who puts their name behind it. A webshop that has T-shirts, kitchen utensils, or toys produced and puts its own label on them bears the same obligations as the factory itself — including the risk analysis, technical documentation, and mandatory information on the product page.
Where exactly the line is drawn
The regulation refers to a product placed on the market under the name or brand of a market participant. This goes beyond just a logo on the packaging. Your own item number on an otherwise unchanged product, your own instructions for use with your company name on them, or having a product produced according to your specifications, can all count as reasons to be classified as a manufacturer. The precise line depends on the situation, and that is exactly where much uncertainty arises: is repackaging alone enough, or must something change in the product itself?
Conversely: whoever sells a product unchanged under the name of the original manufacturer, without adding their own brand or logo, generally remains outside this role. That situation — the pure reseller — has its own, much lighter regime, with different obligations than those of a manufacturer.
What changes if you are a manufacturer
The difference between a distributor and a manufacturer is not cosmetic. As a manufacturer, you are the one who prepares the risk analysis for the product, compiles and keeps the technical documentation for six years, and provides the mandatory safety information on the product page and label — in the language or languages of the countries where you sell. You are also the first point of contact for complaints or safety incidents, and the one who takes action if a recall becomes necessary.
This does not mean you have to figure everything out yourself. Much of the underlying information — test reports, material specifications, certificates — comes from the factory where you purchase. But the responsibility to have that information complete, assess it, and retain it lies with you as a manufacturer, not with your supplier. If you source from outside the EU, there is an additional layer on top: not only the question of whether you are a manufacturer, but also who acts as the responsible person in the EU on your behalf.
Why this is often overlooked
Most entrepreneurs who encounter this were not aware of this classification. They see themselves as traders or brand owners, not as producers — after all, the product comes ready-made from the factory. But the regulation reasons from liability: whoever attaches their name to a product, creates the expectation with the consumer that they stand behind its safety, and therefore bears the same obligations as whoever actually made it.
This doesn't just affect small online shops. Larger retailers that sell part of their range under their own house brand are subject to the same rule for those products. Moreover, the role you play can vary by product line: for one item you may be purely a reseller, for another — with your logo on it — you're a manufacturer. So it's not a matter of one label for the entire company, but something that needs to be assessed per product.
How you assess this for your own assortment
Because the classification can differ per product and depends on concrete details — whether your name appears on the packaging, on the product itself, in the instructions for use, or nowhere at all — it makes sense to go through this systematically rather than rely on instinct. check in a few questions which role you play gives a first indication of this, free of charge and without obligation. If you'd like to read more broadly about how the different roles in the supply chain relate to each other, you'll find that explained in the knowledge base by topic.
If the check shows that you qualify as a manufacturer, the next step is usually to set up the file per product: the risk analysis, the technical documentation, and the information that must appear on the product page. How that process works and what is needed for it is explained on the page that explains how the system works. If you're still unsure about specific situations, such as a product you have slightly modified before it receives your brand, those are questions that come up often and are answered in the frequently asked questions.
The role check is a good starting point to see whether this applies to your products, and if so, which obligations follow from it for your specific range.