For the purposes of Union harmonization legislation, a product is placed on the market when it is first made available on the EU market. This operation is reserved to the manufacturer or importer, who are the only economic operators placing products on the market.
When a manufacturer or importer supplies a product to a distributor or end user for the first time, this operation is always referred to in legal terms as 'placing on the market'. Any subsequent operation, for example from distributor to distributor or from distributor to end user, is referred to as 'making available'. For our kind of products, the moment in time when the product is placed on the market is when there is the transfer of property with the client, i.e. which generally is considered the invoice date.