Selling to the EU from Taiwan

No. There is no free trade agreement between the EU and Taiwan, so your goods pay the ordinary Common Customs Tariff rate. There is no preferential origin to claim and no origin paperwork to produce for duty purposes; which does not remove the non-preferential origin rules that decide anti-dumping and labelling.

Yes: this is the most common misconception among Taiwanese manufacturers. CE and GPSR are separate frameworks: CE proves conformity with technical directives; GPSR is the general safety net covering all consumer products. A product can be fully CE-marked and still lack the Responsible Person that GPSR requires.

€200–800 per year per catalogue, depending on product complexity and risk category. Electronics and children's products sit at the higher end. Ask for the cap on the number of products covered before signing.

Two products in one box, each with its own law. The bicycle is machinery: Directive 2006/42/EC today, and Regulation (EU) 2023/1230 for anything placed on the EU market from 20 January 2027. What decides which text applies is the date the bicycle is placed on the market, not the year it was designed or the season it was built for; a model placed on the market before that date in conformity with 2006/42/EC may still be made available afterwards (Article 52).

The battery is a separate product under Regulation (EU) 2023/1542, in the light means of transport category written for e-bikes and e-scooters. Chapter VIII of that Regulation has applied since 18 August 2025. The party it binds is the 'producer', meaning whoever first makes the battery available on a member state's market on a professional basis. For batteries arriving from Taiwan that is normally your EU importer, because he is established in a member state and supplies them there for the first time (Article 3(47)(c)). He may only make them available on that market once he is entered in that member state's producer register, and the same applies to batteries already built into the bicycle (Article 55(2)). Registration is required in each member state where he himself first makes batteries available, not in every member state the goods eventually reach. The filing may be made on his behalf by a producer responsibility organisation (Article 55(6)) or by an authorised representative for extended producer responsibility (Article 55(7)). Registration is separate from what it obliges him to do: extended producer responsibility means financing the separate collection, transport, treatment and recycling of waste batteries (Article 56), with the collection duty for light means of transport batteries in Article 60. Allow for the lead time, because the competent authority has up to 12 weeks from the moment the file is complete (Article 55(9)(b)). If you sell direct to users in a member state by distance contract, you are the producer there yourself and must appoint an authorised representative in every member state you sell to (Article 56(3)). From 18 February 2027 every LMT battery also needs a battery passport reachable from a QR code on the battery itself. In practice your EU importer holds those registrations and prices them back to you.

RoHS and WEEE, and they work in opposite ways. RoHS (Directive 2011/65/EU, Annex II as amended by Delegated Directive (EU) 2015/863) restricts ten substances in electrical and electronic equipment: lead, mercury, cadmium, hexavalent chromium, the brominated flame retardants PBB and PBDE, and the four phthalates DEHP, BBP, DBP and DIBP. The limit does not apply to the appliance as a whole but per homogeneous material (Article 4(2)). Every separate material has to stay under the limit on its own: a solder joint, a cable sheath, a piece of housing, a coating. A test report that measures a whole appliance as one sample therefore says nothing about compliance. Cadmium is capped at 0.01 % by weight; the other nine at 0.1 %. The four phthalates have applied since 22 July 2019, and since 22 July 2021 for medical devices and monitoring and control instruments, and they do not apply to cables or spare parts for equipment placed on the market before those dates. RoHS is a product requirement proven in the technical file; there is nothing to register. What it asks of your EU importer is in Article 9: place only equipment on the market for which the manufacturer carried out the conformity assessment, check that the technical documentation and the EU declaration of conformity exist and that the CE marking is affixed, keep that declaration for ten years, and put his own name and address on the product, the packaging or the accompanying documents. Note Article 11: an importer who puts the equipment on the market under his own name or trade mark, or modifies it, is considered the manufacturer and carries the full Article 7 obligations. With private label out of Taiwan he is the manufacturer in the sense of the Directive, whatever the purchase contract says.

WEEE (Directive 2012/19/EU) is the opposite: a registration, and there is no EU-wide register. Each member state keeps its own producer register (Article 16), so it is up to 27 national filings. On equipment brought in from Taiwan the EU importer is himself the 'producer', because Article 3(1)(f)(iii) defines the producer as whoever is established in a member state and places EEE from a third country on that member state's market on a professional basis. The registration and collection duties sit with him, not with the maker in Taiwan. An authorised representative under Article 17 is not a way round that: Article 17(1) covers only producers established in another EU member state, and even for them it is a possibility, not a duty; Article 17(2) binds only distance sellers under Article 3(1)(f)(iv) who are themselves established in a member state. A manufacturer in a third country falls under neither. The one exception is direct distance selling: a Taiwanese supplier who sells online straight to users in a member state is the producer there himself (Article 3(1)(f)(iv)) and has to be registered in the member state he sells to. WEEE is a directive, not a regulation, so the binding rules are in the national transposition; check the national register and the national law per member state, not only the text of the Directive. Components supplied for assembly into someone else's equipment are not themselves electrical equipment; the finished appliance is.

It can be right. Article 16 of Regulation (EU) 2023/988 says the Responsible Person must be established in the Union and can be the manufacturer, the importer, an authorised representative holding a written mandate, or a fulfilment service provider. If your distributor is the one importing the goods, he is the importer and the role is already his. Two things follow. Get the appointment in writing, naming the products, because the common failure is that both sides assumed the other had accepted it. And he can only carry it with your material: the technical documentation, the risk assessment, the type or batch identifier you print on the product, and the name and address that go on the label. Note also that the appointment follows the goods, not your company: if that distributor stops buying, the Responsible Person for those products stops with him.

The provider list or ask for three introductions.