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.

Feedstock for HVO and SAF; what plants and projects need

The feedstock question

What feedstock can an HVO or SAF plant actually use? Annex IX

Lipid streams, above all: used cooking oil, animal fats (tallow), vegetable oils, and oils recovered from residues; plus for the newer pathways ethanol and green hydrogen for synthetic fuel. What counts toward the targets is decided by the directive's feedstock lists, not by the plant's nameplate.

The directive sorts the world into three buckets that matter commercially:

Annex IX Part A; residues from forestry, agriculture and industry (tall oil pitch, molasses and their kin). Fuels from these count toward the directive's advanced-fuel target with a multiplier on their energy content.
Annex IX Part B; wastes including used cooking oil and certain animal fats. No advanced multiplier, but eligible for the waste-based premium, with a cap on how much of them may count.
Food and feed crops; heavily limited in what they may contribute, which is why nobody builds an HVO line on virgin food oil for the European market.

Most operating renewable diesel runs on a mixed slate of Part B wastes and processed residues; the plant's pretreatment train, not its brochure, decides what it can really digest.

Common mistake: reading a project's feedstock list as a purchase commitment. A plant that "can process" ten streams may contract seriously for three; the seller's question is which three, and at what volume.

Source: Directive (EU) 2018/2001 (RED II), Articles 26 and 27 and Annex IX, as amended by Directive (EU) 2023/2413. Checked: 22 September 2026.

Why do waste feedstocks command a premium? mandates

Because obligated parties must blend renewable fuel and the directive rewards waste-based volumes most; a tonne of certified used cooking oil carries policy value a tonne of virgin oil does not. The premium is therefore policy-sensitive: it tracks targets, caps and enforcement, not harvests alone.

The chain of value, in order:

Obliged fuel suppliers must deliver a rising renewable share of transport energy (raised again by the 2023 amendment).
Waste and residue feedstocks from the Annex IX lists count toward those obligations; advanced streams with a multiplier.
Certification under a recognised scheme is what lets the volume be counted at all; that is the door through which the premium reaches the collector.

When policy tightens (targets up, enforcement up) the premium holds; when caps bind or fraud scandals erode trust in a stream, the premium narrows for everyone in it. Sellers who understand this price their long-term contracts with indexation and their relationships with clean paper.

Common mistake: treating the waste premium as a permanent structural feature. It is a policy artefact; it has a direction and it can move against a stream.

Source: Directive (EU) 2018/2001, Articles 25–29 as amended by Directive (EU) 2023/2413. Checked: 22 September 2026.

What specs matter for HVO feedstock? catalysts

Different ones than for biodiesel: free fatty acids are workable, but the catalyst killers rule the spec sheet; phosphorus, metals, sulphur, chlorides and water. A renewable diesel buyer will usually forgive FFA and forgive nothing that poisons its pretreatment or its reactor.

What the spec sheet is really protecting:

Phosphorus and metals; deactivate hydrotreating catalysts, which are expensive and slow to replace; hard ceilings are normal.
Chlorides and sulphur; corrosion and catalyst risk, strictly limited.
Water and sediments; paid at zero, penalised beyond thresholds, and the first thing a pretreatment train bills you for.
Composition (fatty-acid profile); less critical than in FAME, but still the fingerprint of what your cargo actually is.

Practical consequence for sellers: a buyer's differentials between "good UCO" and "great UCO" are mostly a materials story; know your own analysis before the buyer's laboratory tells you (the UCO page covers the parameter landscape).

Common mistake: quoting FAME-market specs at an HVO buyer. The markets share feedstocks, not spec sheets; the seller who knows which regime the counterparty runs under prices accordingly.

Source: desk practice in renewable-diesel feedstock contracting, September 2026; hydrotreating catalyst constraints as standard process knowledge. Checked: 22 September 2026.

What changes for SAF specifically? ReFuelEU

The mandate. Since 2025 every fuel supplier at EU airports must blend sustainable aviation fuel, rising steeply toward mid-century; and the dominant certified pathway today is built on the same lipid feedstock pool as renewable diesel. SAF demand therefore bids against HVO demand for your cargo.

What the aviation regulation does:

It sets a SAF share for fuel supplied to EU airports, starting at a low percentage in 2025 and rising by steps (2% in 2025, 6% from 2030, 20% from 2034, on to much higher shares), with a sub-obligation for synthetic fuels that grows from 2030.
Eligible pathways are certified (HEFA; the lipid route; alcohol-to-jet, power-to-liquids and others as they qualify).
HEFA runs on oils and fats; used cooking oil, tallow and relatives; which pulls the same cargoes the renewable-diesel pool wants.

For a feedstock seller this is a demand story more than a paperwork story: aviation's obligation arrives on top of road fuel's, with airlines and oil majors signing long offtakes to cover it.

Common mistake: assuming SAF requires new paperwork from the feedstock side. The certification chain is the same recognised-scheme world; what is new is who is buying and how long their contracts run.

Source: Regulation (EU) 2023/2405 (ReFuelEU Aviation), Articles 4 and 5 and Annex I. Checked: 22 September 2026.

How do projects secure feedstock? bankability

With long agreements signed early; feedstock is the first thing financiers ask about on a renewable-fuel project. Multi-year supply contracts with indexation, certification flow-down and honest volume tolerances; plus a spread of counterparties so no single stream or supplier can starve the plant.

What a bankable feedstock position looks like:

Coverage; a meaningful share of nameplate volume under term agreements before financial close, the rest on spot and short term.
Indexation; prices that move with the market rather than fixed numbers that break when the market moves.
Certification flow-down; every supplying interface certified, because one uncertified link voids the sustainability value of the volume.
Diversification; feedstocks and geographies spread enough that a bad harvest, a rule change or a fraud case in one stream does not stop the plant.

The mechanics of term feedstock agreements; what they contain, what to insist on; are on the offtake page; the questions are the same with the roles reversed.

Common mistake: a startup negotiating its first supply deal as if it were a spot purchase. The buyer is not just buying your cargo; it is diligencing you as part of its financing story, and sloppiness that would pass in spot ends the conversation in term.

Source: desk practice in renewable-fuel project supply, September 2026; Directive (EU) 2018/2001 certification requirements. Checked: 22 September 2026.

What does a multi-feedstock plant mean for a seller? competition

That your stream is always competing with the plant's alternatives. Multi-feedstock flexibility is the plant's hedge; on any given day the buying desk runs its slate on relative economics, and your cargo either fits the formula or it waits.

How that shows up in a seller's life:

Nominations under term contracts flex within tolerance bands; expect your monthly offtake to breathe, and contract the tolerance honestly.
Spot inquiries concentrate around the streams that are momentarily cheap; a seller whose quality is stable gets asked first, at better differentials.
A plant outage or pretreatment limit can pause a stream for weeks; diversify your buyers the way the plant diversifies its feedstock.

The discipline is symmetrical: the plant hedges feedstock risk by owning optionality, and you hedge buyer risk by never needing one desk too much.

Common mistake: building your volumes on one plant's one line. The relationship is real and worth nurturing; the dependency is not worth what it costs when the slate moves against you.

Source: desk practice, September 2026. Checked: 22 September 2026.

What is the fraud and double-counting risk? traceability

The same fraud economics as every premium stream: waste-based value attracts claims that waste was not. The market's defences are fingerprint testing, certification audits and the Union Database registering each transaction once; an honest seller's defence is the same clean, boring, complete paper trail.

The three lines of defence:

Laboratory fingerprints; fatty-acid profiling catches virgin oil dressed as waste (see the UCO page's answer on adulteration).
Certification audits; the recognised scheme audits origin evidence interface by interface (ISCC page).
The Union Database; transactions registered once, so the same sustainability claim cannot be sold twice (Article 31 RED II, phased in).

European policy debate keeps returning to fraud risk in waste-based claims; each wave of scrutiny tightens the paperwork for everyone. Sellers whose records are complete experience that as an advantage over sloppier competitors, which is exactly what it is.

Common mistake: assuming the buyer's due diligence is your due diligence. When a chain is unwound years later, every interface re-opens its files; yours should close again on its own.

Source: Directive (EU) 2018/2001, Article 31; certification practice; European policy discussion on waste-based biofuel fraud. Checked: 22 September 2026.

Feedstock for HVO and SAF, answered