reg 36 Cases in which obligations of manufacturers apply to importers and distributors
An economic operator (“A”) who would, but for this regulation, be considered an importer or distributor, is to be considered a manufacturer for the purposes of these Regulations and is subject to the obligations of a manufacturer under Part 2, where A— (a) places radio equipment on the market under A's own name or trademark, or (b) modifies radio equipment already placed on the market in such a way that it may affect whether the radio equipment is in conformity with Part 2.