EU product rules for importers, answered

The Responsible Person is the contact point for market surveillance authorities and for consumers. They hold the technical documentation, check that it matches the product, and answer when an authority asks.

Who can take the role, in order of preference:

• The manufacturer, if established in the EU.
• An importer established in the EU — which is you, if you are the one bringing the goods in.
• An authorised representative appointed in writing by the manufacturer.
• A fulfilment service provider established in the EU, where none of the above exists.

If you are an EU-based importer, you are already the Responsible Person for what you import. You do not need to hire one — you need to do the job.

Where it goes, in order: on the product itself; if that is not possible, on the packaging; and only if neither works, in a document accompanying the product. "On the website" is not one of the options, though the details do also have to appear in an online listing.

The language requirement is the one that catches people out. Selling the same item into the Netherlands, Germany and Poland means warnings in Dutch, German and Polish — determined by where the consumer is, not where you are.

The file has to contain a risk assessment: what could go wrong with this product, how likely it is, and what was done about it. A supplier declaration on its own does not qualify as a risk assessment.

Practically, ten years means the file has to outlive your relationship with the supplier. Collect it while you are still buying from them, not when an inspector asks and the factory has stopped answering email.

Three things are commonly missed:

• The duty follows the substance, not the product. Ten different products containing the same substance are added together.
• Substances intended to be released from an article count — the ink in a pen, the scent in a candle.
• Registration is not the only duty. Safety data sheets, communication down the chain and the candidate-list obligations apply well below one tonne.

Twelve monthly shipments of 100 kg of the same substance is 1.2 tonnes in a year, and therefore registrable. Splitting an order across shipments or across product lines changes nothing.

What it does follow is the legal entity. Two companies under the same ownership each count separately — which is a planning fact, not a loophole to lean on: the moment either one crosses the line, it registers.

This is the single most useful thing an importer can ask a supplier for, and almost nobody asks. One Only Representative covers all of that manufacturer's EU customers at once. Without one, every importer registers separately and pays separately for the same substance.

Two conditions to check before you rely on it:

• The appointment must be in writing and you must be named in the Only Representative's list of covered importers. Being a customer is not the same as being covered.
• The Only Representative must cover the tonnage you actually import. If they registered for 10 tonnes and their customers together import 30, the cover runs out.

What the marketplace checks is the listing data, not your paperwork. Even where you hold a complete technical file, the listing is suspended until the Responsible Person's name and reachable EU address appear in the required fields.

To restore a listing you generally need: the Responsible Person's details in the listing, a compliant safety label on the product or packaging, and warnings in the language of each country the listing serves.

In practice this means a dropshipping model selling to EU consumers needs a Responsible Person with a physical EU address, technical documentation held for ten years, and labelling in the right languages — per product, from every supplier you use.

That is workable with a small, stable range from one supplier. It is not workable with a catalogue of a thousand items from twenty suppliers, which is what most dropshipping actually is.

This is the part that surprises people who expect the single market to work like a single market. Selling the same item into six countries means six registrations, six annual reports and six sets of fees.

Fees increasingly depend on how recyclable the material is, so the same product can cost noticeably more per unit in one country than in another — even where the tonnage reported is identical.

The word "producer" doing something other than what it means in ordinary speech is the single biggest source of missed EPR registrations. Your Chinese manufacturer is not the producer in Germany. You are.

A non-EU seller can appoint an authorised representative in a member state to carry the obligation instead. That representative must be established in that specific country — one appointment does not cover the EU.

A cordless drill shipped in a cardboard box with a paper manual and a lithium battery hits all four in every country you sell it in. Nothing about that is unusual — it is the normal case for consumer electronics.

The battery registration deadline of 18 August 2025 has already passed. Selling batteries into a market where you never registered means you have been non-compliant since that date, not that you have time left.

If you sell cross-border into countries where you have no legal presence, this is the date that changes your obligations rather than merely your paperwork. Appointment takes time and the representatives are not unlimited in supply.

The scope is by customs code, not by how carbon-intensive your product feels. A steel bracket inside a finished appliance is generally out of scope; the same bracket imported on its own may be in.

Since 1 January 2026 CBAM has been in its definitive regime, which means real financial obligations rather than the reporting-only phase that ran before it.

Below 50 tonnes a year you fall under the simplified treatment introduced by the Omnibus amendment, which was designed to keep small importers out of the full regime.

Applications opened in March 2026. Importers who filed by 31 March 2026 may keep importing while their application is being assessed. Filing later does not carry that protection.

The quarterly holding requirement was reduced from 80% to 50% of embedded emissions, which cuts the amount of cash tied up in certificates during the year.

The obligation that starts now is data, not money: you need embedded-emissions figures from your supplier for goods imported during 2026, and those are far harder to obtain retroactively than at the time of shipment.

A workable order of attack for an importer starting from nothing:

1. GPSR — no threshold, enforced by marketplaces today. Fix the Responsible Person, the labelling and the technical file first.
2. EPR — registration is per country and the battery deadline has already passed, so any gap here is already a live exposure rather than a future one.
3. REACH — only bites at one tonne per substance per year. Check whether you are near it before spending money on it.
4. CBAM — only for six goods categories above 50 tonnes a year. Most importers can rule it out in a minute.

The reason this order matters: the first two carry obligations you may already be in breach of, while the last two may not apply to you at all. Working alphabetically or by how alarming the acronym sounds costs money in the wrong place.