Most brands discover EU product-safety rules the same way: a listing goes live, and then it quietly stops being visible. Nothing was rejected, nobody called. A compliance field was empty, and the marketplace acted on it. The question worth answering before that happens is a narrow one — what must a brand owner have in order before its products can be sold compliantly, and under control, on European marketplaces?
This guide is an operator's working answer to that, not legal advice. Where your products fall under sector-specific rules — toys, electronics, cosmetics and so on — those regimes keep applying on top of everything below, and a specialist should confirm your particular case.
GPSR in plain words
The General Product Safety Regulation — Regulation (EU) 2023/988 — has applied since 13 December 2024. It is the catch-all safety regime for consumer products that other EU legislation does not fully cover. Two of its requirements shape everything a marketplace asks you for.
The first is Article 16: a consumer product may only be placed on the EU market if there is an economic operator established in the EU who is responsible for it. That party has real duties — check that the compliance documentation exists, keep it available for authorities, and cooperate when corrective action is needed.
The second is disclosure. The responsible party's name and contact details, postal and electronic, must appear on the product or its packaging, parcel or accompanying document, alongside the manufacturer's identification. Warnings and safety information must be in a language consumers can easily understand, as determined by the member state where the product is sold. And the online offer itself has to carry that information: manufacturer identification, the responsible person's details where different, warnings, a product identifier and an image. That last point is why this stops being a paperwork exercise and becomes a listing field.
Who is the responsible economic operator
There is no choice to make here so much as a fact to establish. Three set-ups cover almost every brand we speak to.
An EU manufacturer. If you make the product inside the EU, you are the responsible economic operator. Your details go on the product and in the offer, and nothing needs appointing.
A non-EU brand with an EU authorised representative. You appoint a party established in the EU, in writing, to carry the role. Their details appear alongside your manufacturer identification. This is the route that keeps the responsibility inside a relationship you control directly.
A non-EU brand whose stock is imported and sold by an EU operator. Where the manufacturer is not established in the EU, the importer is one of the parties the regulation names as responsible operator — in practice the default when no EU authorised representative has been appointed to carry the role instead. A fulfilment service provider established in the EU can carry it only where none of the above exists. The importing operator's name and address then need to appear on the product or packaging and in the listing. Worth being precise about what the rule demands: it requires the details to be present. Who physically applies the label — the factory at production, or the operator at the warehouse — is an operational agreement between brand and operator, not something the regulation decides for you. Settle it before the first container ships, because relabelling on arrival is slow and expensive.
What the marketplaces actually enforce
The platforms do not assess your safety file. They enforce the fields — and they enforce them per listing.
On Amazon, compliance attributes cover manufacturer contact and responsible person contact, and listings with them missing risk suppression. bol asks for responsible economic operator details per product and states plainly that a non-EU manufacturer must appoint an importer, authorised representative or fulfilment provider. Allegro requires responsible person fields whenever the manufacturer sits outside the EU, entered per offer or in bulk. Kaufland does the same via portal, CSV or API, reports which products are still missing the data, and hides listings that do not meet it.
The pattern is consistent: the marketplace enforces the fields, you supply the facts. Enforcement is also live and changing, so treat "it passed last quarter" as no evidence at all.
Brand gating and Brand Registry
Compliance gets you sellable. It does not get you control of your own shelf — that is a separate problem, and the most common misconception we meet.
Amazon's Brand Registry needs a registered or pending text trademark at a recognised IP office, and it unlocks enhanced content, brand tools and IP reporting. What it does not do is stop other sellers from listing your products. Brand Registry is not gating. Gating — restricting who may sell a brand — is a separate, case-by-case matter, and getting approved to sell a gated brand generally means producing invoices or an authorisation letter from the brand owner. That cuts both ways: the same paperwork trail is what lets you decide who is authorised and who is not.
The other platforms have their own routes. bol operates an IP infringement and notice-and-takedown process for rights holders; Allegro runs a Rights Protection Cooperation Program; Kaufland routes rights complaints through seller support. All of them assume you hold a registered trademark and can evidence it. Without one you have no lever at all, which is the practical starting point of stopping price erosion from grey-market sellers.
The checklist
- Identify who in your chain is EU-established — manufacturer, authorised representative, importer or fulfilment provider. That party is your responsible economic operator. If nobody is, you do not yet have a route to market.
- Appoint the responsible person in writing, with the role and duties stated, before the first shipment leaves.
- Collect the identification data: manufacturer name, postal address and e-mail; responsible person name, EU postal address and e-mail; the product identifier for every SKU.
- Decide where the details are physically applied — on-product, on packaging, or on an accompanying document — and who applies them, at manufacture or on arrival.
- Translate warnings and safety information into the language of every country you intend to sell in, not only the ones you start with.
- Make your technical documentation and test reports retrievable on request, by a named person, in days rather than weeks.
- Register your trademark (or get an application pending) in the EU, then enrol in Brand Registry and the equivalent rights programmes.
- Write your reseller policy down: who is authorised, what an authorisation letter says, and which invoices you will supply for ungating.
- Fill the compliance fields per listing, per marketplace, before go-live — and re-check them when platform requirements change.
What an operator takes off your plate — and what stays with you
An operator route changes who does the work, not who owns the facts. Selling through our own EU accounts, we carry the EU establishment, the importer role and the responsible-operator details where that is how the chain lands, the per-listing compliance fields on all four marketplaces, the translated content, and the monitoring when a platform changes what it asks for.
What cannot move is what only a brand owner holds: the technical file and test reports, correct labelling at the point of manufacture, the source text for warnings, the trademark registrations, and the authorisation letters that decide who may sell you. A partner can carry the whole operation and still not invent a test report. That division is the same one described in selling into Europe from outside the EU.
If you want a direct read on where your range stands — what is missing, what would gate you, and what Europe is realistically worth for your products — the Brand Review is free, in writing, within five working days.