15 common mistakes EU importers make
The errors that cost the most money, ordered by how often we see them — each with the regulation, the article and what it costs you. 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.
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, 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 4; national schemes. 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, wrong restrictions — and it compounds on every shipment.
Source: Union Customs Code (Reg. 952/2013), Articles 57-59. 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: UCC Article 129; Regulation (EU) 2023/988, Article 10. Checked: 4 September 2026.