6 Terminology Under the Consumer Duty, the terms ‘manufacturer’, ‘co-manufacturer’, and ‘distributor’ are all defined terms and defined as follows. Manufacturer A firm which creates, develops, designs, issues, manages, operates, carries out a product. Distributor A firm which offers, sells, recommends, advises on, arranges, deals, proposes or provides a product. Co-manufacturer Same as for manufacturer. A firm which creates, develops, designs, issues, manages, operates, carries out a product. It’s important to note that under the Consumer Duty the definition of ‘product’ includes a service. A service is defined as ‘any service which involves or includes carrying on a regulated activity or an ancillary activity’. The reference to ‘product’ in the definitions of manufacturer, distributor, and co-manufacturer above therefore captures services such as advice propositions and discretionary management services.
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