A downstream market-actor term for a person in the supply chain who makes products or batteries available without being the manufacturer or importer, subject to the source rule.
Distributor is easy to mistake for a generic reseller or logistics role. The implementation risk is that product information, passport access, or label evidence is lost at channel handoff even though the downstream actor is not the legal manufacturer.
ESPR, EU Battery Regulation, and UK source layers use different distributor boundaries. ESPR and the EU Battery Regulation define distributor through supply-chain availability by an actor other than the manufacturer or importer, while the UK Waste Batteries Regulations define distributor as a person providing batteries on a professional basis to an end-user. PPWR context: Regulation (EU) 2025/40 defines packaging, packaging waste, prevention, reuse/refill systems, recyclability, and packaging actor roles for the EU packaging regime. Do not collapse PPWR producer/manufacturer/importer/distributor or market-entry wording into other product, battery, waste, or ELV source meanings.
Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products
any natural or legal person in the supply chain, other than the manufacturer or the importer, that makes a product available on the market;
Reference: Article 2, point 45
Regulation (EU) 2023/1542 concerning batteries and waste batteries
any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a battery available on the market;
Reference: Article 3, point 65
The Waste Batteries and Accumulators Regulations 2009
a person that provides batteries on a professional basis to an end-user.
Direct UK regulation definition from the interpretation provision for waste-battery producer responsibility and collection/recycling obligations.
Reference: Regulation 2(1)
Regulation (EU) 2025/40 on packaging and packaging waste
any natural or legal person in the supply chain, other than the manufacturer or importer, that makes packaging available on the market
Reference: Article 3, point 18
Distributor is a downstream market-actor term for a supply-chain actor, other than the manufacturer or importer, that makes a product or battery available on the market. It is not the same as producer, manufacturer, importer, hauler, or a generic logistics provider.
UK context: UK Waste Batteries Regulations defines this term in UKSI 2009/890. Keep this UK source layer separate from EU or other jurisdiction definitions where scope and obligations differ.
Capture a distributor identifier, channel record, product-information check, product identifier, market-availability event, handover event, supplier link, customer/end-user context, and evidence received from the manufacturer or importer. The record should show what information remained attached during downstream availability.
Distributor is a channel-handoff control: identifiers, labels, passport links, and compliance evidence must remain connected as products move through sales channels. The control distinguishes downstream availability from manufacturing, importing, transport, or producer-registration duties.
EU product regulation uses a layered actor model: manufacturer → authorised representative → importer → distributor → economic operator (umbrella). Each actor in this chain has different obligations, and the applicable obligations depend on which regulation is in play. A company should determine its actor status independently under each applicable regulation, as the same entity can be a manufacturer under one regulation and a distributor under another.