Overview
Economic operators are the supply-chain roles that EU product law assigns compliance duties to. Who you are in the chain decides what you have to do. The same physical product can carry very different obligations depending on whether you made it, imported it or simply resell it.
The roles are defined functionally, not by company size or sector. A firm can be a manufacturer for one product and a distributor for another.
Makes a product, or has it made, and places it on the market under its own name or trademark. This role carries the heaviest duties, including conformity assessment and technical documentation.
Brings a product from outside the EU into the EU market. The importer checks that the manufacturer did its job and takes on responsibility for products entering the Union.
The distributor sells the product on without changing it, for example a retailer or wholesaler. Its duties are lighter, focused on handling, storage and not putting non-compliant goods on the shelf.
Downstream user under REACH
REACH adds another role. A downstream user is a company that uses a substance or mixture in its own industrial or professional activity, such as a formulator mixing a coating or a factory using a solvent. The downstream user does not register the substance but must use it within the conditions the registration set out.
The label follows the function. If you change a product or sell it under your own name, you can take on manufacturer duties even if someone else physically built it.
Related roles include the Only Representative, who can take over importer duties under REACH, and the act of placing on the market, which is what triggers most of these obligations. For electronics, manufacturer duties include applying the CE marking.
Note: general educational information, not legal advice. Check the official source before relying on it.