The actor that manufactures a product, or has it designed or manufactured, and markets it under their name or trademark under the relevant source rule.
Manufacturer sounds like a factory label, but the legal manufacturer is not always the physical factory. The implementation risk is that technical documentation, declarations, and passport data are attached to the production site while the accountable actor is the entity that markets that product under their name or trademark.
ESPR Article 2, point 42 uses the own name or trademark test. The EU Battery Regulation uses similar battery-specific wording and also covers putting a battery into service for the actor’s own purposes, while India’s battery-waste rules frame manufacturer around facilities for manufacturing batteries or components. 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 that manufactures a product or that has a product designed or manufactured, and markets that product under their name or trademark;
Reference: Article 2, point 42
Regulation (EU) 2023/1542 concerning batteries and waste batteries
any natural or legal person who manufactures a battery or has a battery designed or manufactured, and markets that battery under its own name or trademark or puts it into service for its own purposes;
Reference: Article 3, point 33
Battery Waste Management Rules, 2022
a person or an entity or a company as defined in the Companies Act, 2013 (18 of 2013) or a factory as in the Factories Act, 1948 (63 of 1948) which has facilities for manufacturing of Battery and/or its components;
Rule 3(1)(s) of the India Battery Waste Management Rules, 2022. India-specific source layer; compare with other jurisdictions before reusing as a general definition.
Reference: Rule 3(1)
Regulation (EU) 2025/40 on packaging and packaging waste
any natural or legal person that manufactures packaging or a packaged product
Reference: Article 3, point 13
Manufacturer is the accountable product actor that manufactures a product, has it designed or manufactured, and markets that product under their name or trademark. The role can sit with a brand owner or commissioning entity even when another factory physically produces the item.
Model a manufacturer identifier, brand owner record, production-site link, technical documentation owner, declaration record, product family, trademark, authorised-representative link, and evidence-retention responsibility. The data model should separate physical manufacturing evidence from the legal manufacturer role.
Manufacturer is an accountable-actor control: product evidence, declarations, passport obligations, and authority-response duties must attach to the actor the source law treats as manufacturer. That control prevents outsourced production from obscuring who is responsible for the compliance file.
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.