Importers or distributors shall be considered manufacturers for the purposes of this Regulation and shall be subject to the obligations of the manufacturer under Article 8 where they:
((a))
place a detergent or surfactant on the market under their name or trade mark;
((b))
modify a detergent or surfactant already placed on the market in such a way that compliance with this Regulation could be affected; or
((c))
make a surfactant that is not an end-user surfactant available on the market to end-users.