What does customer mean?
Customer is the ESPR actor term for a person or organization that purchases, hires, or receives a product for their own use.
customer
The ESPR downstream-use actor that purchases, hires, or receives a product for their own use.
1 official sourceSingle-source term
Common boundary mistakes
Do not use customer as a loose synonym for consumer, buyer, dealer, distributor, or economic operator. A customer may be a person or organization receiving a product for their own use, but the term does not by itself allocate manufacturer, importer, marketplace, or passport-service-provider responsibility.
Source context
In ESPR, the customer definition anchors the recipient side of product offers, distance selling, and product-information access. It identifies who receives the product for use; it is not the same as the manufacturer, importer, distributor, or economic operator responsible for placing or making a product available on the market.
What this means for implementation
In implementation work, use customer to test whether product information, DPP access, and sales-channel disclosures are understandable to the recipient of the product. Keep that access layer separate from the legal evidence records and operator responsibilities that sit behind it.
Official definitions by source
ESPR
Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products
a natural or legal person that purchases, hires or receives a product for their own use whether or not acting for purposes which are outside their trade, business, craft or profession;
Reference: Article 2, point 35
Practical application
Implementation records should capture the customer identifier, own-use context, purchase/hire/receipt event, offer channel, product-information access, distance-selling link where relevant, and distinction from upstream economic-operator evidence duties.
Minespider commentary
Customer is a downstream-use actor control: the evidence consequence is that product-information access can be designed for the recipient of the product while keeping manufacturer, importer, distributor, and economic-operator duties separate. Customer access is not proof that product information has been delivered or that the underlying evidence is complete.
Common confusions
- Treating every buyer in a supply chain as the ESPR customer without checking whether the product is being received for the actor’s own use.
- Assuming customer is the same as consumer even though the ESPR wording can include natural or legal persons.
- Treating customer access to a DPP or product page as proof that manufacturer or economic-operator evidence duties have been met.