EU Product Compliance for E-Commerce: GPSR, CE Marking and the Responsible Person Explained

You have found your product, your supplier is ready, and you have a fulfilment partner lined up in the Netherlands. Then someone mentions GPSR, CE marking, or the "responsible person" requirement — and suddenly the timeline needs revisiting.

Product compliance is the area where we see the most confusion among brands entering the EU market for the first time. The rules are not new in principle, but the enforcement has changed. Since December 2024, the EU's General Product Safety Regulation (GPSR) has been in force, and both customs authorities and online marketplaces are actively checking for compliance. Getting it right before your first shipment arrives is significantly easier than fixing it after goods are sitting in a warehouse.

What is GPSR and why does it matter now?

GPSR — the General Product Safety Regulation (EU 2023/988) — replaced the old General Product Safety Directive on 13 December 2024. It applies to all non-food consumer products placed on the EU market, whether sold online or in a physical shop.

The regulation is not a radical departure from previous rules, but it tightens several areas that directly affect e-commerce sellers:

• Every product must have a responsible person established in the EU, with their name, postal address, and email address on the product or its packaging.
• Online marketplaces are required to verify that sellers have the necessary compliance information before listing products.
• Sellers must be able to provide a technical file or documentation proving the product meets applicable safety requirements.
• Products sold online must display the responsible person's details in the product listing, not just on the physical packaging.

The practical impact is straightforward: if you cannot name an EU-based responsible person for your product, you cannot legally sell it in the EU. Amazon, Bol.com, and other major marketplaces now enforce this during seller onboarding.

The responsible person: who it is and who it is not

Under GPSR, the responsible person is the economic operator who takes accountability for the product's compliance. The regulation defines a clear hierarchy:

1. The manufacturer, if established in the EU.
2. The importer, if the manufacturer is outside the EU.
3. An authorised representative, appointed in writing by the manufacturer.
4. A fulfilment service provider, but only if none of the above are established in the EU.

For most non-EU brands shipping inventory to a Dutch warehouse, the responsible person will be either your EU importer (if you use one) or an authorised representative you appoint specifically for this role.

A common question we receive: "Can the fulfilment centre be our responsible person?" Technically, GPSR allows it as a last resort. In practice, most fulfilment providers — including us — do not take on this role, because it carries legal liability for product safety. The responsible person must be able to provide technical documentation, cooperate with market surveillance authorities, and take corrective action if a product is found to be unsafe. That is a compliance function, not a logistics function.

The right approach is to appoint a dedicated authorised representative before your goods enter the EU. Several specialist firms in the Netherlands offer this service, and the cost is modest relative to the exposure of non-compliance.

CE marking: when you need it and when you do not

CE marking is frequently confused with GPSR, but they are separate requirements that sometimes overlap.

CE marking is required for product categories covered by specific EU harmonised legislation. The most common categories for e-commerce sellers include:

• Electronics and electrical equipment — Low Voltage Directive, EMC Directive, RoHS, Radio Equipment Directive
• Toys — Toy Safety Directive
• Personal protective equipment — PPE Regulation
• Machinery — Machinery Regulation
• Medical devices — MDR
• Construction products — CPR
• Cosmetics — Cosmetics Regulation (separate marking requirements, not CE)

CE marking is not required for general consumer products that do not fall under harmonised legislation — clothing, accessories, furniture, home décor, bags, stationery, and similar items. These products still need to comply with GPSR's general safety requirements and labelling obligations, but they do not carry the CE mark.

If your product does require CE marking, the process involves:

1. Identifying which directive(s) or regulation(s) apply to your product.
2. Ensuring the product meets the essential requirements defined in those directives.
3. Having the product tested by an accredited laboratory where required (some categories allow self-certification).
4. Preparing a Declaration of Conformity and the supporting technical file.
5. Affixing the CE mark to the product, packaging, or accompanying documentation.

This must be completed before the product enters the EU, not after. Products arriving at Dutch customs without proper CE marking where required can be refused entry.

Labelling requirements: what must be on the product

Between GPSR and category-specific regulations, the labelling requirements for EU-bound products are more detailed than many sellers expect. At a minimum, most consumer products must display:

• The product name or type identifier
• The name and postal address of the manufacturer
• The name, postal address, and email of the responsible person in the EU (if different from the manufacturer)
• Warnings and safety information in the language(s) of the destination country
• Country of origin
• CE mark (where applicable)
• Batch or serial number for traceability

For products sold online, the responsible person's details and any applicable warnings must also appear in the product listing — a customer scrolling through your Amazon or Shopify store must be able to see this information before purchasing.

Getting the labels right at source — at your manufacturer — is significantly cheaper than re-labelling at the warehouse. If your packaging is already printed, your fulfilment partner can apply compliance stickers as a value-added service, but this adds time and cost to every unit. Design it in from the start.

What marketplaces are actually checking

Since GPSR came into force, the major EU marketplaces have implemented compliance verification as part of their seller and product listing processes:

• Amazon EU — requires responsible person details during product listing, blocks listings without them, and requests Declarations of Conformity for regulated categories.
• Bol.com — enforces responsible person information and has increased spot checks on product documentation.
• Zalando, Otto, Kaufland — similar requirements, with varying levels of automation in their verification.

If you are selling direct-to-consumer through your own Shopify or WooCommerce store, marketplace enforcement does not apply — but the legal obligation is identical. Market surveillance authorities in EU member states can and do check online shops, and non-compliant products can be ordered removed from sale.

REACH, RoHS, and other chemical regulations

GPSR and CE marking cover product safety and market access. Chemical compliance is a separate layer that catches many sellers off guard:

• REACH — restricts or bans specific chemicals in products sold in the EU. Relevant for textiles (azo dyes, formaldehyde), jewellery (nickel, lead, cadmium), electronics, and products with coatings or treated materials.
• RoHS — restricts hazardous substances in electrical and electronic equipment. If your product has a plug, a battery, or a circuit board, RoHS applies.
• EU Packaging and Packaging Waste Regulation — evolving rules on recyclability, labelling of packaging materials, and Extended Producer Responsibility (EPR) schemes that may require registration in each country you sell to.

Your product test reports from the manufacturer should cover REACH and RoHS where applicable. If they do not, arrange testing before shipping — not after your inventory is in Europe and a market surveillance authority requests documentation you cannot provide.

The practical sequence for getting compliant

If you are six to eight weeks from your first EU shipment, this is the order that works:

1. Identify your regulatory obligations. Which directives apply to your product? Do you need CE marking? What are the chemical compliance requirements?
2. Appoint a responsible person. Either your EU importer or a dedicated authorised representative. Get this in writing.
3. Ensure your test reports are in order. Safety testing, CE certification (if required), REACH and RoHS reports. These should come from an accredited lab.
4. Update your labelling. Manufacturer details, responsible person details, CE mark, batch numbers, multilingual warnings. Do this at source if possible.
5. Prepare your technical file. This is the documentation package that proves compliance — test reports, Declaration of Conformity, risk assessment, product description, labelling samples.
6. Register for EPR schemes in countries where you will sell, if applicable to your product category and packaging.
7. Set up your import route and VAT registration in parallel — compliance and customs preparation should run on the same timeline.

Steps 1 through 3 take the most time, especially if your manufacturer needs to arrange additional testing. Do not wait until the container is booked.

What your fulfilment partner should help with

A fulfilment centre is not a compliance consultancy, and you should be cautious of any provider that offers to "handle all your compliance" as part of a logistics package. The roles are distinct:

Your fulfilment partner should:

• Verify that inbound products carry the correct labelling before they are put away into stock
• Apply compliance stickers or additional labels as a value-added service when needed
• Provide the warehouse address for your responsible person registration and customs documentation
• Flag obvious compliance gaps during inbound inspection — missing CE marks, absent responsible person labels
• Store your technical documentation references alongside your product records

Your fulfilment partner should not:

• Sign Declarations of Conformity on your behalf
• Act as your responsible person (unless explicitly agreed and they have the capability)
• Ship products they know to be non-compliant
• Advise on which regulations apply to your specific products — that is work for a regulatory consultant or your authorised representative

At Euroship, we support brands with inbound quality checks, re-labelling services, and documentation coordination. We work with your compliance team or authorised representative to make sure what arrives at our warehouse is ready to ship to your customers — but the compliance decision-making stays with you and your regulatory advisors.

The cost of getting it wrong

Non-compliance is not an abstract risk. The consequences are concrete and increasingly common:

• Products seized at customs — your container does not clear, and you pay storage while the issue is resolved or the goods are destroyed.
• Marketplace delisting — your products are removed from Amazon or Bol.com, often with limited ability to appeal until documentation is provided.
• Mandatory recall — if a product already in consumers' hands is found unsafe, you bear the cost of recall and replacement.
• Fines — member state authorities can impose financial penalties, which vary by country but are designed to be dissuasive.
• Inventory write-off — products sitting in a European warehouse that cannot legally be sold represent a total loss.

We have seen brands arrive at our warehouse with a full container of product and no compliance documentation. The goods sit on the shelf, unsellable, until the paperwork catches up — which can take months. The warehousing cost alone turns a viable product launch into a loss-making exercise.

A note: this article provides general guidance on EU product compliance. Regulatory requirements vary by product category, and the rules evolve. Work with a qualified regulatory consultant or authorised representative to confirm the specific obligations for your products.

If you are preparing to launch in the European market and want a fulfilment partner who understands the practical side of compliance, get in touch. We handle B2C and B2B fulfilment from our facilities near Schiphol for brands across Asia, the Middle East, Turkey, and Europe — and we can walk you through exactly what needs to be in place before your first inbound shipment arrives.