Own-brand imports: am I the manufacturer?
Under most UK product rules, selling imported goods under your own name or trade mark makes you responsible as the manufacturer, even when a Chinese factory makes them. You take over the applicable manufacturer duties, including compliance evidence and corrective action. Cambridge China Bridge helps buyers obtain evidence from factories.
Establish the role before approving artwork
The trigger is marketing the product under your name or trade mark, not owning the factory or designing the product. Our OEM and ODM guide explains the basic distinction and the own-brand trigger. A modification affecting compliance can also bring manufacturer duties. Check the product regime rather than assuming every category works alike.
Before ordering, record the intended product use, selling territory, brand owner and business that will issue any required declaration. Review the product, packaging and instructions together. The duties below use electrical equipment supplied in Great Britain as a worked example; do not treat them as a universal checklist for every product or for Northern Ireland.
Take control of the compliance evidence
For electrical equipment within the relevant rules, the manufacturer must ensure safe design and manufacture, determine and carry out the applicable conformity assessment, and prepare technical documentation before placing the equipment on the Great Britain market. The manufacturer's documentation and declaration responsibilities are explained in our certification guide.
Ask for evidence tied to your actual branded model: drawings, component specifications, test reports, label artwork and instructions. Compare model identifiers, materials and components across the documents and approved sample. Agree how you will obtain missing information and review changes. A report for a similar factory product is a reason to investigate, not a reason to approve shipment.
Approve identification and instructions
For the electrical equipment example, manufacturer labelling must include the manufacturer's name or trade mark, postal address and product identification, such as a batch or serial number. Where it is not possible to put this information on the equipment, it must appear on the packaging or an accompanying document. Instructions must be clear, legible and in easily understandable English.
Request photographs of the finished branded item and its labels, packaging and enclosed instructions before shipment. Compare them with the approved artwork and documentation. Give the factory the exact business details to print, and check that the identification used in your records matches the goods. Do not leave these decisions to the packing team.
Control repeat production and retain records
Electrical equipment manufacturers must have procedures to keep series production compliant, taking account of design changes and relevant changes to standards or technical specifications. They must retain the technical documentation and declaration of conformity for 10 years after the equipment is placed on the Great Britain market and make them available to the market surveillance authority.
Agree a written change process covering materials, components, suppliers and artwork. Require the factory to flag proposed substitutions before using them, then assess whether the evidence still covers the revised product. Keep your own accessible document archive and connect each shipment to its approved specification. Use our inspection guide to plan physical checks alongside document review.
Prepare for problems after sale
For electrical equipment, manufacturers must investigate non-compliance complaints and keep records of complaints, non-compliant products and recalls; risk-appropriate sample testing is also required. If they have reason to believe equipment is non-compliant, they must bring it into conformity, withdraw it or recall it. Where it presents a risk, they must immediately inform the market surveillance authority.
Assign a person to receive complaints, identify affected batches and contact distributors and customers. Rehearse retrieving the supporting documents without depending on a factory employee being available. A sourcing agent can help gather evidence and coordinate checks, but does not remove your responsibility. Our imported-product liability guide covers the separate question of claims for damage.
Frequently asked questions
Does putting my logo on imported goods make me the manufacturer?
For electrical equipment covered by the Great Britain rules, having goods manufactured and marketing them under your own name or trade mark brings manufacturer duties. For other products, confirm the applicable responsibilities with the relevant authority; do not assume that the identity of the factory settles the question.
Can I use the Chinese factory's test reports?
Use them as supporting evidence after checking that they cover your actual model, materials and components. Resolve differences before approving the branded product or its documentation.
How long must I keep the technical file?
For electrical equipment covered by the Great Britain rules used here, keep technical documentation and the declaration for 10 years after placing the equipment on the market. Check the retention rule for your product category.
Can a sourcing agent take over my manufacturer responsibility?
A sourcing agent can obtain documents, coordinate checks and help investigate factory changes. That support does not remove the manufacturer responsibilities your business has taken on.