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Inside GEROM · Compliance
Your logo on the box: when a furniture distributor becomes the manufacturer
Key facts
- Since 12 August 2026, the EU Packaging Regulation (PPWR) treats whoever has a packaged product made under its own name or trademark as its manufacturer, even if another brand is visible on the box.
- Each packaged product has only one manufacturer in the supply chain, according to the European Commission's June 2026 guidance.
- The manufacturer signs the EU declaration of conformity for the packaging. Harmonised labelling is due from August 2028 and recyclability and minimisation rules from 2030, at the earliest in both cases.
- Under the General Product Safety Regulation (GPSR), a distributor selling under its own brand is also the product's manufacturer and keeps technical documentation for ten years.
Many distributors of contract furniture sell part of their range under their own brand. They find a reliable source, put their logo on the product and the carton, and clients come to know the range as theirs.
Commercially, that makes sense. Since 12 August 2026, it also carries legal weight that is easy to overlook.
Who is the manufacturer of a packaged chair?
The EU Packaging and Packaging Waste Regulation (PPWR) treats as the manufacturer of a packaged product whoever has it designed or made under their own name or trademark. That holds even if another brand is also visible on the box.
The Commission's guidance, published in June 2026, adds that each packaged product has only one manufacturer in the supply chain. A chair in a carton with the distributor's logo therefore has the distributor as its manufacturer. The company that packed it is not.
There is one narrow exception. Micro-enterprises, with fewer than 10 staff and annual turnover or balance sheet total of up to EUR 2 million, can pass these duties to an EU-based packaging supplier.
What the role involves
The manufacturer signs the EU declaration of conformity for the packaging and keeps the technical documentation behind it. Since August 2026, that documentation has to show the packaging meets the substance requirements, including a limit on heavy metals.
More requirements follow: harmonised labelling from August 2028, and detailed rules on recyclability and minimal packaging from 2030. Both dates apply at the earliest and move later if the Commission's implementing rules arrive late.
The manufacturer's name, postal address and electronic contact go on the packaging, together with a type or batch identifier. When the goods come from outside the EU, the importer's details are added as well. If a market surveillance authority has questions, it writes to whoever is named there.
The same logic applies to the furniture
The General Product Safety Regulation (GPSR), applied since 13 December 2024, treats a distributor selling a product under its own name or trademark as that product's manufacturer.
That brings an internal risk analysis before sale, technical documentation kept for ten years, identification and contact details on the product, and responsibility for corrective action, up to a recall.
GPSR covers products that consumers use or are likely to use. Children's furniture sold for home use falls clearly within it. For furniture supplied only to kindergartens, schools and offices the line is less sharp, so it is worth checking with your own adviser.
What to agree with your supplier
Most of the documents a private-label distributor now needs can only come from the supplier:
- for packaging, data on substances, materials and weight for each packaging type;
- for the product, test reports to the relevant standards, which for school chairs and tables are EN 1729-1 and EN 1729-2;
- for traceability, a batch identifier on every piece that links back to production records.
A contract clause on who provides which document, and within what time, is easier to agree before the first order than after a letter from market surveillance.
How we handle private label
When a partner sells under its own brand, we name the partner's company as the manufacturer and put its logo on the products. GEROM stays on the label as the importer.
We have prepared the packaging documentation a partner needs to sign its declaration of conformity, and our packing lists show packaging weight by material: cardboard, wood and polyethylene.
This article is a short overview of the rules and not legal advice. If you sell under your own brand and want to see the documents, get in touch below.
Sources: Regulation (EU) 2025/40 on packaging and packaging waste (PPWR); Regulation (EU) 2023/988 on general product safety (GPSR).
Questions distributors ask
Is a private-label distributor the manufacturer under PPWR?
Yes. Under the PPWR, whoever has a packaged product designed or made under its own name or trademark is its manufacturer, even if another brand also appears on the packaging. The only narrow exception covers micro-enterprises, which can pass these duties to an EU-based packaging supplier.
What does a PPWR manufacturer have to do?
Sign the EU declaration of conformity for the packaging, keep the technical documentation behind it, and put its name, postal address, electronic contact and a type or batch identifier on the packaging. Substance limits apply since 12 August 2026, harmonised labelling from August 2028 and recyclability and minimisation rules from 2030, at the earliest.
Whose details go on the packaging when furniture is imported into the EU?
Both the manufacturer's and the importer's. For a private-label product, the manufacturer is the brand owner, and the importer that brings the goods into the EU adds its own name and contact details.
Does GPSR apply to school furniture?
GPSR covers products that consumers use or are likely to use. Children's furniture sold for home use falls clearly within it. For furniture supplied only to kindergartens, schools and offices the line is less sharp, so check with your own adviser.
Which documents should a private-label distributor get from the supplier?
Packaging data on substances, materials and weight for each packaging type, test reports to the relevant standards (EN 1729-1 and EN 1729-2 for school chairs and tables), and a batch identifier on every piece that links back to production records.