# Contract Manufacturer vs Manufacturer of Record: Who Signs the DoC?

If a contract manufacturer builds your product and you put your brand on it, you are the legal manufacturer under CE, UKCA, and FCC rules — not your CM. The Declaration of Conformity is yours to sign, the technical file is yours to hold, and when something goes wrong in the market, you are the party regulators come to. Most founders don't realize this until there's a problem.


## Transcript

### Your brand on the product means your liability

Your contract manufacturer builds the product and puts your name on the label — under EU, UK, and US law, you're the manufacturer. You sign the Declaration of Conformity, hold the technical file, and when it goes wrong, regulators come to you, not your CM.

### How the law defines manufacturer

Under EU law, the manufacturer is whoever markets a product under their own name — not whoever built it. Your brand signs the DoC and holds the technical file. UKCA and FCC follow suit. Require test-report ownership contractually.

### What to put in your CM contract

Check your CM contract for four things: you own all test reports and technical documentation, the CM must notify you of any change that could affect compliance, the CM indemnifies you for its manufacturing defects, and you can audit the facility.

Tags: contract manufacturer, CE marking, Declaration of Conformity, OEM, product liability