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Direct to consumer for manufacturers: sell D2C and wholesale online

Direct to consumer for manufacturers: sell D2C and wholesale from one online store in the EU, keep distributors on side, set prices per group, meet GPSR.

The CloudCart team15 min read
A small manufacturing workshop with a row of identical product boxes, one parcel for a home customer, a pallet of cartons for retailers and a laptop showing an abstract catalog with two price columns
In this article · 11 sections
  1. What is direct to consumer, and why do manufacturers want it?
  2. How do you sell direct without a conflict with your distributors?
  3. How do you set retail, dealer and distributor prices?
  4. How do you set a minimum order quantity for resellers?
  5. Dealer catalog: sign-in, a closed store or an XML feed?
  6. Own brand and private label: who counts as the manufacturer?
  7. Marketplaces, price comparison sites and Google Shopping for manufacturers
  8. GPSR and the other EU duties of a manufacturer selling online
  9. How to launch retail and wholesale in CloudCart: 8 steps
  10. The most common manufacturer mistakes in online sales
  11. Frequently asked questions

In short: direct to consumer (D2C) means the manufacturer sells to end customers in its own online store. One store can serve two groups of buyers: consumers at the recommended retail price, and signed-in dealers at their own prices, minimum quantities and payment by invoice. Channel conflict stays low when your store sells at the same price you recommend to retailers.

This guide is for European manufacturers of food, cosmetics, furniture, clothing and homeware who sell through distributors and want their own online sales, with examples in CloudCart, the ecommerce platform with 0% commission on sales.

What is direct to consumer, and why do manufacturers want it?

Direct to consumer (D2C, also written DTC) means the manufacturer sells to the end customer itself, without a wholesaler or retailer in between. In its own online store the manufacturer keeps the whole retail margin, sees who buys what, and decides how the brand looks. Selling wholesale online is the other half: dealers, shops and restaurants order from the same website at trade prices.

The usual channels of a manufacturer differ in margin, customer data and risk:

ChannelMargin for the manufacturerCustomer dataWho carries the costsMain risk
Own retail store (D2C)Highest: the full retail priceComplete: orders, emails, repeat purchasesYou: advertising, shipping, returns, customer serviceAdvertising cost per order
Dealers and shops (wholesale)Medium: the trade priceOnly the retailer, not the end customerThe retailer sells, you deliver in bulkPrice conflict with your D2C store
Distributor (for a region or country)Lowest per unit, largest volumeAlmost noneThe distributor: warehouse, retailers, logisticsDependence on one partner
MarketplaceRetail price minus the marketplace commissionLimited, under the marketplace rulesYou, or the marketplace if it does fulfilmentA price war with your own dealers on the same listing

B2C, B2B and D2C are compared by capital and risk in ecommerce business models.

How do you sell direct without a conflict with your distributors?

Channel conflict is avoided with three rules: the retail price in your store equals the recommended retail price, the trade price leaves the reseller a real margin, and you promise no one an exclusivity that your own store breaks. When your store sells at the same price as your dealers, it advertises the product for them too.

The EU rules for agreements between a manufacturer and its resellers are in the Vertical Block Exemption Regulation (EU) 2022/720, in force from 1 June 2022 until 31 May 2034. Four of its rules matter most to a manufacturer with its own store:

  • A recommended price is allowed, a fixed or minimum resale price is not. Under Article 4(a) you may recommend a resale price or set a maximum one. You may not force a reseller to sell at a fixed or minimum price, either by pressure or by incentives.
  • Resellers may sell online. Under Article 4(e) you may not prevent a buyer from using the internet effectively to sell. You may set other conditions for online sales, for example quality standards for the reseller's website.
  • Selling both yourself and through resellers is allowed. Article 2(4)(a) covers dual distribution: the manufacturer also sells at retail, and the buyer is only a reseller, not a competing producer. Information exchanged between you must relate to the agreement and be needed for distribution (Article 2(5)).
  • A market share threshold. The exemption applies when the market share of the supplier and of the buyer each stays at or below 30% (Article 3). Above that, agreements are assessed case by case.

Important: have a lawyer review your distribution contracts, territory and exclusivity clauses. The regulation sets the framework, and your specific contract may include terms not covered here.

Change the recommended price in your store and the dealer price list on the same day, and reserve bundles or colours for your store instead of selling cheaper.

How do you set retail, dealer and distributor prices?

A manufacturer's price ladder starts from the recommended retail price and steps down with a discount for each level of reseller. Every step must leave a margin for the next one: the distributor sells to the dealer, and the dealer sells to the consumer at the recommended price. If the steps are too close, the reseller has no reason to stock the product.

Level (example; percentages depend on your costs)Discount off the list pricePrice for a product listed at €40Who sees it
Retail customer0%€40.00Every visitor of the store
Dealer, shop−30%€28.00Only customers in the "Dealers" group
Dealer from 48 units−35% (quantity tier)€26.00"Dealers" group, with 48 units in the cart
Distributor−45%€22.00Only the "Distributors" group

In CloudCart the ladder is built with customer groups and discounts. Every customer is in exactly one group, and the group decides price, payment and shipping. There is no separate wholesale price column on the product: the dealer price is a discount aimed at the group. It can be a percentage on the whole catalog, a category or selected products, an exact price per product or variant, or quantity tiers, up to 12 for a product with one variant. With a percentage discount, a new list price updates the dealer price automatically.

The number of groups depends on the plan: Starter Pack 3, CC Pro 5, CC Master 100, and Baby Pack has no customer groups (see pricing). The count includes the two system groups Default and Guests, so a ladder with dealers and distributors needs at least 4 groups, which means CC Pro. Creating groups and discounts is covered in B2B ecommerce and selling wholesale online.

How do you set a minimum order quantity for resellers?

A minimum order quantity (MOQ) protects the manufacturer from wholesale orders for 2 units. CloudCart has two tools for it: a minimum quantity on the product and a minimum order value in the cart settings.

  • Minimum quantity on the product. In the product editor, under the advanced stock settings, is the field "Minimum order qty". It applies to every buyer of that product, so it suits products sold only by the case or pack, for example 6 bottles.
  • Minimum order value. It is set in the cart and order settings. Below that amount no order goes through, for any buyer, so in a mixed retail and wholesale store keep it low or empty.
  • Quantity tiers instead of a ban. When consumers should still be able to buy 1 unit, leave the minimum at 1 and give the "Dealers" group a lower price from 12, 48 or 120 units. The reseller reaches the quantity on their own, because that is where their price is.

Payment and shipping can also be split by group. With Cart Rules and the condition "customer group", bank transfer against an invoice is shown only to resellers, while card payment stays for everyone. The number of rules depends on the plan: 1 on Baby Pack and Starter Pack, 2 on CC Pro and 3 on CC Master.

Dealer catalog: sign-in, a closed store or an XML feed?

The dealer catalog is where resellers see your range, their prices and your stock. There are four ways to build it:

OptionWhen it fitsHow it works in CloudCart
One open store with groupsYou sell to consumers and resellers from one websiteThe catalog is public and ranks in Google, and dealer prices appear only after sign-in
A closed store for resellers onlyYou do not sell retail, or prices must not be publicApps → Private Store: registration, manual approval of every company and a choice of public pages
Several stores with shared stockYou want a retail site plus a dealer portal, or a store per country with its own language and currencyExtra stores in a multistore setup and Stores Sync, which aligns quantities only, by SKU or barcode. Multistore is in the Enterprise plan with an individual contract (see multistore)
An XML feed for resellers' websitesDealers sell your products in their own online storesApps → XML Feed Generator: a feed at a public or password-protected address, by category or brand, with a markup or discount

Private Store closes the whole site to search engines, so it suits manufacturers who sell only to the trade; the blog and information pages can stay public so new resellers still find you.

An XML feed saves dealers from copying your descriptions, photos and stock by hand. The dealer adds the feed address to their store, and price and stock changes reach them at the next refresh, usually about every 6 hours if the catalog has changed. Feeds are 1 on Baby Pack and Starter Pack, 2 on CC Pro and 3 on CC Master, with up to 100, 2,000, 7,500 and 10,000 products.

Own brand and private label: who counts as the manufacturer?

Private label is a product you make and a retailer sells under its own name or brand. These orders usually run on an individual contract, so a staff member creates them in the admin for that customer at the agreed price.

EU law decides who is responsible for the safety of such a product. Under Article 13(1) of the General Product Safety Regulation (EU) 2023/988 (GPSR), a person who places a product on the market under their own name or trade mark is considered the manufacturer and takes on the manufacturer's obligations under Article 9. A retailer with a private label brand takes on those obligations, and your contract should settle documentation, labelling and recalls.

Your own brand also needs barcodes. Retail chains, marketplaces and Google Shopping expect GTINs registered with GS1 in your name, as explained in barcodes, EAN and GS1 for products.

Marketplaces, price comparison sites and Google Shopping for manufacturers

A marketplace brings a manufacturer new buyers in exchange for a commission on each sale. In CloudCart, eMAG connects for Romania, Bulgaria, Hungary and Poland, each country with its own seller contract. The XML Feed Generator has ready formats for price comparison sites such as Skroutz, Compari.ro, Árukereső and Glami, and the catalog reaches Google Shopping through Merchant Center.

Your own resellers often sell the same product on a marketplace, so sell there at your recommended price. Which marketplaces fit which products is covered in selling on marketplaces, and every ready connection is on the multichannel selling page.

GPSR and the other EU duties of a manufacturer selling online

The GPSR, Regulation (EU) 2023/988 on general product safety, applies from 13 December 2024. A manufacturer has more obligations than a shop that resells: they are in Article 9 and apply whether you sell yourself or through resellers. Food, feed and medicinal products are outside the GPSR (Article 2(2)) and follow their own rules.

  1. Risk analysis and technical documentation. Before placing a product on the market you carry out an internal risk analysis and draw up technical documentation (Article 9(2)), and keep it for 10 years after the product is placed on the market (Article 9(3)).
  2. A product identifier. A type, batch or serial number that consumers can easily see and read, on the product or, where that is not possible, on the packaging (Article 9(5)).
  3. Your details. Name or trade mark, postal and electronic address on the product, its packaging or an accompanying document (Article 9(6)).
  4. Instructions in the local language. Clear instructions and safety information in a language set by each country where you sell (Article 9(7)). Selling in Austria, Poland and Czechia means German, Polish and Czech.
  5. A complaints channel. A phone number, email or website section where consumers report safety issues (Article 9(11)), plus an internal register of complaints and recalls (Article 9(12)).
  6. Action on a dangerous product. Immediate corrective measures, including withdrawal or recall, informing consumers and notifying the authorities through the Safety Business Gateway (Article 9(8)).

Article 19 adds what every online offer must show: the manufacturer's name and addresses, a picture and identifier of the product, and its warnings. Which CloudCart field is for what is explained in GPSR for online sellers.

Selling retail in your own store also brings the duties every seller has towards consumers. In the EU a consumer may withdraw from an online purchase within 14 days of delivery without giving a reason (Your Europe, returns), as covered in returns and consumer rights. Once your distance sales to consumers in other EU countries pass €10,000 a year in total, VAT is due at the customer's rate, declared through the One Stop Shop (Your Europe, cross-border VAT); see OSS and EU VAT on cross-border sales. Wholesale orders from companies are invoiced, and the 14-day withdrawal right does not apply because the buyer is not a consumer.

How to launch retail and wholesale in CloudCart: 8 steps

A manufacturer can launch a D2C store and wholesale ordering in one CloudCart store within a few days, if the catalog and price list are ready:

  1. Import the catalog. Products with variants, SKU, barcode and brand come in through CSV or XML import. In the Vendors card choose the manufacturer, so it shows on the product page.
  2. Use your recommended prices as list prices. The list price is the retail price you also show resellers as recommended.
  3. Create the groups. Customers → Customer groups → Add customer group: "Dealers", "Distributors", "Private label".
  4. Set prices per group. Marketing → Discounts: a global percentage discount for the group, fixed discounts for negotiated products and quantity tiers for the pack and the case.
  5. Set the minimums. A minimum quantity on products sold only by the pack, and a minimum order value in the cart settings if you need one.
  6. Split payment and shipping. Bank transfer with your IBAN in the description, shown through Cart Rules only to resellers; card payment for everyone.
  7. Import your resellers. Use the customer import with the right group, so they see their prices from the first sign-in.
  8. Launch the feeds. XML Feed Generator for dealers with their own online stores, and the ready connections for marketplaces, price comparison sites and Google Shopping.

All wholesale features are on the B2B online store page. If you have distributors in several countries who sell on to their own customers, see the path with a dedicated B2B platform on the B2B wholesale platform page, and for country stores with their own language and currency, a multilingual, multi-currency store.

The most common manufacturer mistakes in online sales

  • A store cheaper than your resellers. It brings orders in the short term, and in the long term dealers stop stocking the product.
  • Minimum prices or an online sales ban in the contract. Both are hardcore restrictions under Article 4 of Regulation 2022/720.
  • Dealer prices in a PDF. After every change some resellers order from the old list. The price in their account is always the current one.
  • Labels without the GPSR details. A missing batch number, address or local-language instructions can stop the product in your store and at your resellers.
  • One store for every country. Consumers in Germany, Poland or Italy expect their language, currency and local payment methods, which is what a store per country gives them.

Frequently asked questions

Direct to consumer (D2C or DTC) is a model where the manufacturer sells straight to the end customer, usually in its own online store. It keeps the full retail margin and the customer data, and takes on advertising, shipping and customer service.

Yes. Regulation (EU) 2022/720 covers dual distribution, where the manufacturer sells at retail and also through resellers. As a consumer seller you follow the EU consumer rules, including the 14-day right of withdrawal.

With customer groups. Consumers buy at the list price, and resellers sign in and see their group's prices, quantity tiers and payment by invoice. In CloudCart groups start on Starter Pack, and separate groups for dealers and distributors need CC Pro.

A manufacturer may recommend a resale price or set a maximum one, but not a fixed or minimum price. That is Article 4(a) of Regulation (EU) 2022/720, valid until 31 May 2034. Pressure or incentives that turn a recommended price into a fixed one are also prohibited.

No. Under Article 4(e) of Regulation 2022/720 a manufacturer may not prevent a reseller from using the internet effectively to sell, though it may set other conditions for online sales. One exception: a buyer operating at the wholesale level may be restricted from selling to end users (Article 4(b)(iv)).

A risk analysis and technical documentation kept for 10 years, a batch or serial number on the product, your name and addresses, instructions in the local language, a complaints channel with a register, and action on dangerous products through the Safety Business Gateway. They are in Article 9 of Regulation (EU) 2023/988, which applies from 13 December 2024 and does not cover food.

Questions about prices per group or the dealer feed go to support@cloudcart.com.

Sources

  1. Vertical Block Exemption Regulation (EU) 2022/720eur-lex.europa.eu
  2. General Product Safety Regulation (EU) 2023/988 (GPSR)eur-lex.europa.eu
  3. Your Europe, returnseuropa.eu
  4. Your Europe, cross-border VATeuropa.eu
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