15 common mistakes EU importers make

The errors that cost the most money, grouped by regime, each with the regulation and the article it rests on. Not opinions: these are the gaps between what the law requires and what importers actually do.

Every mistake on this page is preventable. The expensive ones are the ones you did not know about, not the ones you chose to skip.

What they cost

Five amounts, each taken from the answer on this site that establishes it, with that answer's own source and check date.

Where it bites	What it costs	Source
Listing suspended (GPSR)	Marketplaces suspend listings without a recorded EU Responsible Person, regardless of whether the product itself is safe. The goods stay off sale until the listing data is complete. Full answer.	Source: Regulation (EU) 2023/988, Article 22 (obligations of online marketplaces); marketplace seller policies, 2025–2026. Checked: 2 September 2026.
GPSR fines	The regulation sets no amounts; member states do. Germany's amended Product Safety Act tops out at €100,000 for serious offences; the Netherlands reaches around €900,000 at the indexed top category. Full answer.	Source: Regulation (EU) 2023/988, Article 44; German ProdSG amendment (government draft, 2026); Dutch Warenwet enforcement framework. Checked: 3 September 2026.
Packaging register (Germany)	Selling packaged goods in Germany without a LUCID registration can be fined up to €200,000 per case, and the sales stopped outright. Full answer.	Source: Verpackungsgesetz (VerpackG); Zentrale Stelle Verpackungsregister (ZSVR), LUCID register. Checked: 3 September 2026.
Wrong HS code	Customs assesses the difference retroactively with interest over the recovery period, normally three years and ten where a criminal act is involved; on everything imported in that window, at once. Full answer.	Source: Union Customs Code, Articles 103 and 105 (limitation of the customs debt); Article 121 (repayment and remission). Checked: 4 September 2026.
Sanctions breach	In the Netherlands an intentional violation carries up to six years' imprisonment; since the 2024 EU directive, company fines for serious offences must be at least 1% of worldwide annual turnover. Full answer.	Source: Sanctiewet 1977 Article 2 (Wetten.overheid.nl); Directive (EU) 2024/1226; ECLI:NL:RBROT:2024:11674; European sanctions enforcement trackers. Checked: 4 September 2026.

GPSR: General Product Safety

Mistake 1: Assuming a CE certificate covers GPSR ¶

CE marking and GPSR are separate frameworks. A product can be fully CE-marked under LVD/EMC/RoHS and still lack the Responsible Person that GPSR requires since 13 December 2024. The listing gets suspended anyway.

Source: Regulation (EU) 2023/988, Article 16. Checked: 4 September 2026.

Mistake 2: Appointing a Responsible Person who disappears ¶

When you stop paying a Responsible Person service, the appointment ends, and every listing recorded against that address is at risk. Ask what happens on termination before signing.

Source: Regulation (EU) 2023/988, Articles 16 and 10. Checked: 4 September 2026.

Mistake 3: English-only warnings ¶

Safety information must be in the language of every country you sell into. An English-only label fails in France, Germany, Italy, Spain and most other EU markets.

Source: Regulation (EU) 2023/988, Article 9(4). Checked: 4 September 2026.

Mistake 4: No technical file ¶

The technical file (risk assessment, design documentation, test reports) must exist and be handed to authorities within 15 days on request. The Responsible Person holds it for ten years.

Source: Regulation (EU) 2023/988, Articles 8 and 10. Checked: 4 September 2026.

REACH: chemicals

Mistake 5: Not knowing the one-tonne threshold counts per year ¶

The REACH registration duty triggers at one tonne per legal entity per substance per calendar year, not per shipment and not per product line. Track the running total across all imports.

Source: Regulation (EC) 1907/2006, Article 6. Checked: 4 September 2026.

Mistake 6: Believing a 'REACH certificate' from a supplier ¶

There is no such thing as a REACH certificate. Every document with that name is a supplier self-declaration. What you need is the registration number or proof of an Only Representative.

Source: Regulation (EC) 1907/2006, Articles 5-8. Checked: 4 September 2026.

EPR: packaging and electronics

Mistake 7: Thinking there is one EU-wide EPR registration ¶

There is no EU-wide register. Each member state runs its own scheme with its own number, fee and report. Selling in five countries means five registrations.

Source: National EPR regimes per member state. Checked: 4 September 2026.

Mistake 8: Selling before registering ¶

Several member states treat selling without an EPR registration number as an offence, not an oversight. Register before the first sale into that country.

Source: National EPR enforcement. Checked: 4 September 2026.

Mistake 9: Forgetting transport packaging ¶

Pallets, drums, wrapping and liners count as packaging in most member states. Bulk goods without retail packaging still trigger EPR.

Source: Regulation (EU) 2025/40, Article 3(1), points (5), (6) and (7), defining sales, grouped and transport packaging; transport packaging expressly excludes road, rail, ship and air containers; national schemes. Checked: 4 September 2026.

CBAM: carbon border

Mistake 10: Waiting for the threshold warning that never comes ¶

Nobody warns you at 49 tonnes. The authorisation must be in place before you cross 50 tonnes of CBAM goods per year. Track the running total yourself.

Source: Regulation (EU) 2023/956 as amended. Checked: 4 September 2026.

Sanctions screening

Mistake 11: Relying on the bank's screening ¶

Your bank's screening is not your screening and it is not a defence. Screen counterparties yourself against the relevant lists before every transaction.

Source: Regulation (EU) 269/2014; Directive (EU) 2024/1226. Checked: 4 September 2026.

Mistake 12: Ignoring ownership above 50% ¶

A company that is more than 50% owned by a listed person is caught by sanctions even if the company itself is not on any list. Name matching alone misses this.

Source: EU best-practice guidelines on ownership. Checked: 4 September 2026.

Customs

Mistake 13: Wrong HS code ¶

Product classification is the single most expensive thing to get wrong. A wrong HS code means wrong duty, wrong VAT and wrong restrictions, and it compounds on every shipment.

Source: Union Customs Code (Reg. 952/2013), Article 57 (tariff classification). Checked: 4 September 2026.

Mistake 14: Not keeping import documents long enough ¶

Customs records: three years minimum. GPSR technical file: ten years. Since one shipment generates both, keep everything ten years.

Source: Union Customs Code (Reg. 952/2013), Article 51 (retention of documents, at least three years); Regulation (EU) 2023/988, Article 10. Checked: 4 September 2026.

Incoterms and shipping

Mistake 15: Using FOB for containers ¶

FOB is a ship's-rail rule from the bill-of-lading era. With containers, goods are handed to a carrier at a yard long before any vessel, so FOB leaves an uninsurable risk gap. The ICC itself steers container traffic to FCA.

Source: ICC Incoterms 2020, explanatory notes. Checked: 4 September 2026.

How to avoid all fifteen

Three tools on this site catch most of these before they bite:

The product check: seven questions, and the regimes that apply to you appear with their requirements.
The GPSR checklist: fifteen checks with the article each rests on.
The counterparty verifier: VAT validation and sanctions screening in one flow.

Not sure which mistake applies to your situation? Run the free check: it takes two minutes and tells you which regimes to take seriously.