The basis for the location is first and foremost the headquarter. Then we check the parent companies to see if it has non-European parents.
The manufacturing is not part of the decision (yet) as that would be very difficult for cases where manufacturing is global, both inside Europe and outside - when would it be non-European? 51% outside? Even if that should be the basis, it is a very time consuming task to source these information (if possible at all).
Therefore although it's not perfect, this is the way we handle these cases.