Import Rules

Question 1

Do I need an EU Responsible Person?

Accepted Answer

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.

Question 2

What has to be on the product or the packaging?

Accepted Answer

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.

Question 3

How long do I have to keep the technical file?

Accepted Answer

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.

Question 4

Do I have to register under REACH?

Accepted Answer

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.

Question 5

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

Accepted Answer

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

Question 6

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

Accepted Answer

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.

Question 7

Why was my Amazon listing suspended?

Accepted Answer

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.

Question 8

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

Accepted Answer

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.

Question 9

What does an EU Responsible Person cost?

Accepted Answer

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.

Question 10

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

Accepted Answer

No. The Responsible Person must be established inside the European Union, and the United Kingdom has not been part of it since 2021. A UK company or a UK address does not qualify.

Question 11

Where do I have to register for EPR?

Accepted Answer

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.

Question 12

Who counts as the producer if I only import?

Accepted Answer

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.

Question 13

Can one product trigger more than one EPR scheme?

Accepted Answer

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.

Question 14

What changes for packaging in August 2026?

Accepted Answer

From 12 August 2026 the EU Packaging Regulation requires sellers without an establishment in a member state to appoint an authorised representative for packaging in that state. Sellers who never had a local entity are now inside the scope.

Question 15

Does CBAM apply to what I import?

Accepted Answer

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.

Question 16

Do I need to be an authorised CBAM declarant?

Accepted Answer

Yes, if you import more than 50 tonnes of CBAM goods per year — and the authorisation must be in place before you cross that threshold, not after. Hydrogen and electricity are treated separately.

Question 17

When do I actually pay for CBAM?

Accepted Answer

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.

Question 18

Which rule bites first?

Accepted Answer

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.

Selling into the UK — and back into the EU

The questions, with answers

Does the EU GPSR apply in the UK?

I sell from the UK into the EU. Do I need an EU responsible person?

Do I need UKCA marking to sell in Great Britain?

When do I need a UK Responsible Person?

What about selling into Northern Ireland?

Is the UK changing its product rules?

Who can handle both sides for me?

Next steps