Definition

Manufacturer

The party that develops or has developed a product with digital elements and markets it under its own name or trademark.

A natural or legal person who develops or manufactures products with digital elements, or has them designed, developed or manufactured, and markets them under their name or trademark, whether for payment, monetisation or free of charge. The definition follows the New Legislative Framework: the brand owner carries the obligations even when development is outsourced. Importers and distributors have lighter, separate duties, and open-source software stewards have a distinct light-touch regime.

Reference: Art. 3(13); obligations in Art. 13–14 · Regulation (EU) 2024/2847 on EUR-Lex

Updated 2026-09-12 · Paraphrase for orientation, not legal advice.