(27)Importers and distributors that either place a detergent or surfactant on the market under their own name or trademark or modify a detergent or surfactant in such a way that compliance with this Regulation could be affected should be considered to be manufacturers and should therefore assume the obligations of manufacturers. Similarly, importers and distributors making available on the market to end-users a surfactant which was not produced for supply to end-users but to producers of detergents should assume the role of manufacturers and, among others, create a digital product passport. In other cases, economic operators that only package or repackage a detergent or surfactant already placed on the market by other economic operators should be able to prove that compliance with this Regulation has not been affected, by indicating their identity on the package and by keeping a copy of the original labelling information. Packaging and repackaging activities should be understood as providing products to end-users in individual packaging and should not cover refill sales.