Import Rules

Question 1

Which rule bites first?

Accepted Answer

GPSR, because it applies to every consumer product with no threshold at all, and because marketplaces enforce it themselves by suspending listings. The others have thresholds or deadlines you may still be under.

Question 2

Do I need an EU Responsible Person?

Accepted Answer

Yes, if the manufacturer is outside the EU. No consumer product may be placed on the EU market unless an economic operator established in the Union is responsible for it, and their name and address must be visible to the buyer.

Question 3

What has to be on the product or the packaging?

Accepted Answer

The name and contact address of both the manufacturer and the Responsible Person, plus something that identifies the specific product; a type, batch or serial number. Warnings and safety information must be in the language of every country you sell into.

Question 4

How long do I have to keep the technical file?

Accepted Answer

Ten years from the day the product is placed on the EU market, and you must be able to hand it to an authority on request. As an importer you keep your own copy; pointing at the manufacturer is not enough.

Question 5

Do I have to register under REACH?

Accepted Answer

You must register if you import one tonne or more per year of a given substance, whether on its own, in a mixture, or intended to be released from an article. Below one tonne there is no registration duty, but other obligations still apply.

Question 6

Is the one-tonne threshold per shipment or per year?

Accepted Answer

Per legal entity, per substance, per calendar year. Not per shipment, not per product line, and not per warehouse.

Question 7

What is an Only Representative, and do I need one?

Accepted Answer

An Only Representative is an EU-based entity appointed by a non-EU manufacturer to carry the registration duties that would otherwise fall on every one of their EU importers. If your supplier appoints one, your own registration duty disappears; you become a downstream user.

Question 8

Why was my Amazon listing suspended?

Accepted Answer

Most likely because the listing has no valid EU Responsible Person recorded against it. Amazon, Kaufland and other marketplaces have been enforcing this since 2025 and suspend listings that lack it, regardless of whether the product itself is safe.

Question 9

I dropship from outside the EU. Does any of this apply to me?

Accepted Answer

Yes. The duties follow whoever places the product on the EU market, and that is the seller of record; even if you never see, touch or store the goods. Shipping direct from a supplier abroad does not move the obligation to that supplier.

Question 10

What does an EU Responsible Person cost?

Accepted Answer

Published prices run from roughly €200 to €800 per year. Most services price per company or per catalogue rather than per product; a basic small-catalogue arrangement sits at the bottom of that range, and toys, electrical goods or large catalogues sit at the top.

Question 11

Can a UK company be the Responsible Person for EU sales?

Accepted Answer

Not from a UK address. The Responsible Person must be established in the Union , and the United Kingdom has not been part of it since 2021, so a UK establishment and a UK address do not qualify. What decides it is the place of establishment, not the nationality of the owner: a UK group with a subsidiary or branch established in a member state can name that EU entity, and it is that EU address that must appear on the product.

Question 12

What happens if I ignore this?

Accepted Answer

The GPSR itself sets no fine amounts; Article 44 makes every member state set penalties that are “effective, proportionate and dissuasive”, and they differ widely. Germany’s amended Product Safety Act (draft, expected 2026) tops out at €100,000 for serious offences; the Netherlands runs one of the strictest regimes, with fine categories reaching around €900,000 at the indexed top level. Before any fine comes the measure that hurts sooner: the listing suspension.

Question 13

The authorities found a problem; how fast must I act?

Accepted Answer

Two working days. When a market surveillance authority asks an economic operator to act on a safety issue, the operator must respond within two working days; and recalls and corrective measures run through the Safety Gate alert system that every member state reads.

Question 14

Is anything exempt from the GPSR?

Accepted Answer

Yes: a fixed list: medicinal products for human or veterinary use, food and feed, living plants and animals (and GMOs in contained use), animal by-products, plant protection products, transport equipment used in the context of a transport service provided to consumers and not operated by the consumers themselves , low-risk aircraft, antiques, and products clearly marked to be repaired or reconditioned prior to use. Read the transport line carefully: a ride or attraction that consumers operate themselves is not exempt.

Question 15

Where do I have to register for EPR?

Accepted Answer

In every member state where you sell, separately. There is no EU-wide EPR register; each country runs its own national producer register, with its own categories, its own fees and its own registration number.

Question 16

Who counts as the producer if I only import?

Accepted Answer

Under every European EPR regime the producer is not the company that made the product; it is the company that first places it on that national market. If you import and sell, that is you.

Question 17

Can one product trigger more than one EPR scheme?

Accepted Answer

Yes, and routinely four at once in the same country: packaging, electrical equipment, batteries and paper. Each has its own register, its own number and its own report.

Question 18

What changes for packaging in August 2026?

Accepted Answer

From 12 August 2026 the EU Packaging Regulation requires a seller who supplies end users in a member state directly to appoint an authorised representative for packaging in that state. Article 3(1), point (15)(c) and (d) covers a seller established in a member state or in a third country alike, so shipping straight to consumers from outside the EU is caught. Sell to a distributor established in that country instead and he is the producer there; for other third-country producers each member state decides whether to require a representative.

Question 19

Does CBAM apply to what I import?

Accepted Answer

Only to a defined list of goods: iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. If your goods are not on that list, CBAM does not touch you; no report, no certificates, nothing.

Question 20

Do I need to be an authorised CBAM declarant?

Accepted Answer

Yes once you expect to pass 50 tonnes of net mass per calendar year, counted over iron and steel, aluminium, cement and fertilisers together; and the authorisation must be applied for before you cross that threshold, not after. Hydrogen and electricity do not count towards the 50 tonnes and have no threshold of their own: for those you are in scope from the first consignment, however small.

Question 21

When do I actually pay for CBAM?

Accepted Answer

Later than most people expect. Certificates for 2026 imports can only be bought from February 2027, and the annual declaration for 2026 is due by 30 September 2027.

CHOE Chun-Sik

Australian Sanctions List (DFAT)

Swiss list (SECO)

EU consolidated list

France: Registre national des gels

US Nonproliferation Sanctions

UK Sanctions List (FCDO)

UN Security Council

What this profile is, and is not