Why the role matters so much
In the jewelry industry, a single company rarely makes everything itself. Casting, finishing, stone setting and packaging often come from different partners. Legally, however, what counts is not who operates the machine, but who places the product on the market as the manufacturer. The EU General Product Safety Regulation (GPSR) defines the manufacturer as any person or company that manufactures a product or has it designed or manufactured and markets it under its own name or trademark (Regulation (EU) 2023/988).
What the legal manufacturer takes on
- Product safety. Internal risk analysis and evidence that the product is safe.
- Technical documentation. Records on design, manufacturing and testing that are prepared before the product is placed on the market and kept for at least ten years (IHK Hannover).
- Labeling. Information on the manufacturer and on product identification.
- Point of contact for authorities. Providing information during market surveillance and taking action if a product is defective.
Own brand does not automatically mean manufacturer role
If you sell jewelry under your own brand, you may be considered the manufacturer. For retailers and brands without their own production and quality assurance, that is a considerable effort. It is therefore worth specifying in writing before the project starts who takes on this role and how labeling and documentation will be handled. Learn more about the obligations in our article GPSR for jewelry.
How we handle this at Aviano
For contract collections through Aviano Studio, Aviano is the legal manufacturer. This means we bear product and compliance responsibility, while you bear brand responsibility. For you, that means one contractual partner instead of many suppliers. Our manufacturing partners in Europe and Asia work for Aviano; coordinating with them is our job.
Frequently asked questions
Can I still put my brand on the product?
Yes. The brand on the product and packaging remains yours. Which manufacturer details appear in addition is determined in the project.
What happens if I substantially modify a product?
Anyone who substantially modifies a product that has already been placed on the market may themselves be considered the manufacturer. Changes should therefore be coordinated with the manufacturer.
Does this also apply to watches?
Yes. The manufacturer role applies to all consumer products. For watches, additional requirements may apply depending on the features, for example for batteries.
Related terms
Planning your own jewelry collection? As a jewelry manufacturer for your brand, Aviano supports you from the first idea to delivery.