ln the case of the products any EU economic operator marketing products under its own trademark is considered the manufacturer placing these products on the Union market and he becomes solely responsible for the models with their trademark in EPREL and in front of the market surveillance authorities. These economic operators must as 'suppliers' register the relevant models in EPREL in their role of manufacturers established in the EU and must subsequently comply with all suppliers’ associated obligations under Articles 3 and 4 of Regulation (EU) 2017/1369 as well as of Article 3 of the product-specific Regulation in the case of lighting products Regulation (EU) 2019/2015. Also the obligations in relation to the CE marking of these products will be relevant for them. On the contrary, the importer cannot play any role according to the energy labelling legislation for these products.
More information is available under Who does what under Energy Labelling ? - European Commission (europa.eu)
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.