Which rule bites first?

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.

Do I need an EU Responsible Person?

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.

What has to be on the product or the packaging?

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.

How long do I have to keep the technical file?

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.

Do I have to register under REACH?

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.

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

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

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

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.

Why was my Amazon listing suspended?

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.

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

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.

What does an EU Responsible Person cost?

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.

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

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.

What happens if I ignore this?

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.

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

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.

Is anything exempt from the GPSR?

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.

Where do I have to register for EPR?

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.

Who counts as the producer if I only import?

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.

Can one product trigger more than one EPR scheme?

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.

What changes for packaging in August 2026?

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.

Does CBAM apply to what I import?

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.

Do I need to be an authorised CBAM declarant?

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.

When do I actually pay for CBAM?

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.

Bringing grain and meals into the EU; buyers, rules, contracts

The grain and meal trade

Who buys grain and meals in the EU? no register

Four kinds of buyer, linked by traders: flour and starch mills that buy wheat and maize; crushers that buy oilseeds and sell the meal on; feed compounders that buy maize, wheat and every meal for animal feed rations; and biofuel plants that buy maize and wheat as process input. Port silos and international traders connect all of them.

How the market is organised in practice:

Millers and starch; quality wheat and maize on spec and protein; the most quality-driven desks.
Crushers; buy rapeseed and sunflower seed, sell oil and meal; their meal output is why protein meals trade in the volumes they do.
Feed compounders; the volume buyers of meals and feed grains, buying continuously against ration formulas that shift with relative prices.
Biofuel and ethanol; maize and wheat as process input where plants run on grain.
Traders and port storage; the layer that blends origins and parcels into what end-buyers actually take.

As a seller outside the EU, the realistic entry points are traders and the larger compounders and crushers; the term-and-formula mechanics of those relationships are on the offtake page.

Common mistake: approaching end-buyers with one vessel. EU compounders buy positions, not favours; sellers without a trading relationship usually arrive through a trader or a broker first.

Source: market structure as observed by the desk behind this guide, September 2026; no official register of grain buyers exists. Checked: 22 September 2026.

What import duty and quotas apply? TARIC

For most grains and meals into the EU the common customs tariff is the starting point, and for many origins trade agreements or preferential schemes reduce it to zero; Ukraine trades under autonomous trade measures that suspend duties entirely into 2026 and are periodically extended. The number that applies to your cargo is the TARIC line for your grain, your origin and your agreement; it is public, and it is never a guess.

How to get your real number:

Classify the goods; the combined nomenclature code for the grain or meal as shipped, not as marketed.
Look the code up in TARIC, the Commission's tariff database; it shows the third-country duty and every preferential measure attached to it.
Check your origin's agreement or scheme; preference papers (a certificate of origin or the agreed proof) are what turn a preferential rate into the rate you pay.
For Ukraine specifically, the autonomous trade measures suspend the duties; verify their current validity period before contracting, because they are extended by regulation in steps.

Our free import duty calculator does the arithmetic once you have the rate; the calculator never invents a rate, and neither should your counterparty.

Common mistake: pricing a contract on a duty rate someone quoted from memory. Rates and preferences change with agreements; a TARIC check costs minutes and prevents a margin error that costs the cargo.

Source: Union Customs Code framework; TARIC database; Regulation (EU) 2024/1362 (Ukraine autonomous trade measures). Checked: 22 September 2026.

What plant-health documents does a cargo need? per origin

Grain is a plant, and the EU treats it as one: most grain imports need a phytosanitary certificate from the exporting country's plant-health authority, and the cargo must enter through an approved border control post where documents, identity and the goods themselves are checked before release.

What the plant-health regime means operationally:

The EU plant-health regulation (2016/2031) and its implementing rules set which plants and origins need certificates and checks.
The phytosanitary certificate is issued in the country of export by its authority; a cargo that arrives without the right one does not get a second chance at the border.
Border control posts at the entry point do documentary, identity and physical checks at risk-based frequencies; budget time for them in your demurrage arithmetic.
Storage and onward movement may carry conditions (for example to prevent pest escape); your buyer's logistics desk will know the local drill.

Not every product from every origin is regulated the same way; the Commission publishes the requirements per commodity; that publication, not habit, is the reference your documents should be built against.

Common mistake: loading on the strength of last season's document set. Requirements per origin and commodity are revised; a certificate that was right in spring can be the wrong document by harvest.

Source: Regulation (EU) 2016/2031 and its implementing rules; Commission plant-health requirement database. Checked: 22 September 2026.

What about maize and soya; the GMO rules? authorised events

Genetically modified grain may only enter as food or feed if the specific event is authorised in the EU. In practice: buy from origins with a clean event profile for the EU, test at loading, and know exactly what the zero-tolerance treatment of unauthorised events means for your cargo.

The regime in practice:

GM food and feed need an authorisation under Regulation (EC) 1829/2003; the register of authorised events is public and searchable.
For approved events, labelling and traceability rules apply (Regulation (EC) 1830/2003); conventional cargoes sail under a documented non-GM chain with tolerance thresholds.
Unauthorised events have no tolerance: a cargo that tests positive for an event the EU has not authorised does not enter as food or feed, whatever its paperwork says.
Standard practice is a pre-shipment PCR test by an accredited laboratory at origin; buyers ask for it and sellers build it into the loading sequence.

Maize from some origins and soybeans almost everywhere are where this bites hardest; wheat and barley trade largely outside it; know which regime your cargo lives in before you contract.

Common mistake: treating "GMO-free" as a sales phrase. It is a documented chain with tests and thresholds; a claim without the paper behind it converts a rejected cargo into a fraud allegation.

Source: Regulation (EC) 1829/2003; Regulation (EC) 1830/2003; EU register of authorised GM food and feed. Checked: 22 September 2026.

What contaminant limits apply? tested

The EU sets maximum levels for the mycotoxins and heavy metals that occur in grain; deoxynivalenol in wheat is the classic; with prescribed sampling methods, because a limit without a sampling rule is unenforceable. Buyers test at destination and contract price deductions or rejection against the results.

What the contaminant framework does:

Regulation (EU) 2023/915 sets maximum levels for contaminants in food, including the mycotoxins relevant to grain; feed has its own limit framework under the feed hygiene and marketing rules.
Sampling and analysis follow prescribed methods (the mycotoxin sampling regulation); the laboratory result is only as valid as the sample plan behind it.
Contracts translate the limits into money: deductions per band, rejection beyond a threshold; the specifics differ per buyer, the existence of the regime does not.

Practical defence for a seller: know your origin's typical mycotoxin profile by season, pre-test at loading, and keep the sample sealed and split so disputes are decided on evidence rather than on who shouts loudest.

Common mistake: blaming the buyer's laboratory when a result is bad. Mycotoxins are heterogeneous; without a properly drawn sample from your own loading, you have nothing to argue with, and the buyer's certificate stands.

Source: Regulation (EU) 2023/915 (contaminants in food); Regulation (EC) 401/2006 (mycotoxin sampling and analysis). Checked: 22 September 2026.

Which contract standards does the trade use? GAFTA/FOSFA

The grain and meal trade runs on standard-form contracts with arbitration built in; GAFTA forms for grains and FOSFA forms for oilseeds, oils and meals; on top of the Incoterms and payment instruments of commodity trade generally. Standard forms are not bureaucracy; they are why disputes between strangers end in awards instead of silence.

What the standard-form world gives you:

Default quality clauses (moisture, impurities, hectolitre or protein) with established analysis and appeal mechanics.
Default default-interest, demurrage and force-majeure terms that both sides have seen before.
Arbitration under the association's rules, with quality appeals decided by umpire analysis rather than correspondence.
A vocabulary ("in store", "free overboard", the delivery periods) that port silos, banks and inspectors all understand.

The payment and security layer; instruments, documents, exposure management; is covered on the offtake page and applies unchanged here.

Common mistake: writing a bespoke contract for a first cargo to "keep it simple". A simple bespoke contract is a dispute waiting for a judge; a standard form with your specifics filled in is a machine both sides already know how to operate.

Source: GAFTA and FOSFA standard-form contract practice; desk practice of the guide's trading desk, September 2026. Checked: 22 September 2026.

Do sanctions matter for grain? origin

Yes, by origin. The EU has banned grain originating in Russia and continues to restrict Belarusian potash and related trade; and any cargo can brush against designated parties; vessels, traders, banks. Screening origin and counterparties before contracting is now part of ordinary grain hygiene, not paranoia.

The practical layer:

The Russia trade restrictions extend to grain of Russian origin since mid-2024, under the regulation that carries the EU's Russia trade measures; "origin" is the legal test, not the port of loading.
Separately, designated companies and vessels appear across this trade; a counterparty or a ship on a list stops a cargo regardless of what it carries.
Our free sanctions check searches the lists any party or vessel can appear on, with a dated record per search.

For a seller the habit is one workflow: screen the counterparty, know your origin's status, keep the dated evidence. Buyers increasingly ask for exactly that file.

Common mistake: assuming sanctions are the buyer's problem because the cargo enters the EU. Sellers upstream carry the consequences of a stopped trade too; the screening costs a minute.

Source: Regulation (EU) No 833/2014 as amended (trade restrictions on Russia); EU restrictive measures in force. Checked: 22 September 2026.

Bringing grain and meals into the EU, answered