US seller? Here's every EU regulation that applies to your products
If you sell products to EU consumers from the United States, you face 9 EU regulations — GPSR, PPWR, EmpCo, EPR, Battery, CE, REACH, and more. Here's exactly what applies, what you need to do, and the registration numbers you need before your first sale.
If your products reach EU consumers — whether through Amazon.de, your own Shopify store, or wholesale distribution — every EU regulation applies to you, regardless of where your company is based. The EU doesn't exempt non-EU sellers. It makes you carry additional obligations that EU-based sellers don't have.
This is not theoretical. Amazon is suppressing EU listings that lack product-safety contact data or packaging registration numbers. Customs authorities in Germany, the Netherlands and France are opening parcels and checking labels. Etsy and eBay now ask for the same safety fields at listing level. Every month, the gap between "I ship to Europe" and "I'm allowed to sell in Europe" gets more expensive to ignore.
This guide covers every EU regulation that applies to US sellers, the specific obligations you carry as a non-EU economic operator, and the exact registrations and appointments you need before placing your first product on the EU market. It is written in plain language: where a legal term matters, we explain it.
1. The non-EU operator position — why it matters
EU product law is built around "economic operators" — the manufacturer, the importer, the distributor and the fulfilment service provider. Each role carries duties. The question for a US seller is which role you occupy, because that decides what you owe.
You are a non-EU manufacturer if you make the product, or if you have it made and sell it under your own brand or trademark. Private-label Amazon sellers are manufacturers in the eyes of EU law, even if a factory in Shenzhen did the actual making. As a non-EU manufacturer, you must appoint an EU-based representative for each regulation that requires one — an Authorised Representative under the CE directives, a Responsible Person under product-safety law, and producer representatives for waste and packaging schemes.
You are a distance seller if you sell directly to EU consumers from outside the EU — your own website, a Shopify store with EU shipping, or a marketplace account that ships from the US. There is no EU importer standing between you and the customer, so nobody else is picking up the importer's duties. Under the General Product Safety Regulation (GPSR, Regulation (EU) 2023/988), a product may only be placed on the EU market if there is an economic operator established in the EU responsible for it (Article 16), and your online offer must show the manufacturer, the EU responsible person and the safety information before purchase (Article 19).
The critical point: a US seller doesn't get lighter obligations. In many cases, they get heavier ones. An EU-based brand satisfies the "established in the EU" condition simply by existing. You need representatives, registrations and signed mandates to achieve the same legal position.
If you are also selling into the UK, the structure is similar but the appointments are separate — UK sellers face similar obligations — read the UK guide.
2. Every regulation that applies — the full stack
The EU does not have one "product compliance law". It has a stack of regulations and directives, each covering a different risk. Here is the full list as it applies to a US seller.
| Regulation | What it covers | Applies to US sellers? | Key obligation for non-EU sellers |
|---|---|---|---|
| GPSR (2023/988) | Product safety, traceability, EU Responsible Person | Yes — all consumer products | Appoint an EU Responsible Person (Art. 16) and show their details on the product and listing |
| PPWR (2025/40) | Packaging recyclability, labelling, packaging EPR | Yes — all packaged products | Register for packaging EPR per country and appoint an authorised representative for producer responsibility |
| EmpCo (Dir. 2024/825) | Environmental and sustainability claims | Yes — if you make any eco claim | Substantiate every claim to EU standards; generic claims are banned |
| EPR (packaging, WEEE, batteries) | Extended Producer Responsibility — paying for the waste your products create | Yes — per country, per waste stream | Register before first sale and appoint an authorised representative per country |
| Battery Regulation (2023/1542) | Labelling, QR code, battery passport, removability, battery EPR | Yes — if the product contains a battery | Battery EPR registration, labelling and an authorised representative |
| CE marking (LVD, EMC, RoHS, Toys, RED, Machinery) | Conformity with product-specific safety directives | Yes — if your product is in scope of any directive | Conformity assessment, EU Declaration of Conformity, technical file and an EU authorised representative |
| REACH (1907/2006) | Chemical substance restrictions and SVHC communication | Yes — all products that contain chemical substances | Article 33 communication and SCIP notification for SVHCs above 0.1% |
| DPP / ESPR (2024/1781) | Digital Product Passport and ecodesign requirements | Yes — when the delegated act for your category applies | Prepare passport data (materials, origin, repairability) |
| Right to Repair (Dir. 2024/1799) | Repair obligations, spare parts, repair information | Yes — for the product groups it covers | Provide repair information and make spare parts available |
Most US sellers face 5–7 of these regulations simultaneously. A US electronics brand selling on Amazon EU with a battery-powered product and sustainability claims on its website faces: GPSR + PPWR + EmpCo + EPR (packaging + WEEE + batteries) + Battery Regulation + CE (LVD + EMC + RoHS) + REACH. That's 7 regulations with dozens of obligations each.
Not sure which apply to your catalogue? The free compliance quiz answers that in five questions.
3. The Authorised Representative stack — the cost most US sellers miss
Almost every guide online tells you to "get an EU Responsible Person". That is the first appointment, not the only one. EU law asks for several legally distinct representatives, and each one exists for a different regulator.
- GPSR — EU Responsible Person (Article 16). Their name and contact details must appear on the product, its packaging, the parcel or an accompanying document, and in your online listing. They hold your technical documentation and cooperate with market-surveillance authorities.
- PPWR — authorised representative for packaging EPR. Producers not established in a Member State must appoint one there to carry out their packaging producer obligations, country by country.
- Battery Regulation — authorised representative for battery EPR. The same logic, applied to batteries: a representative in each Member State where you make batteries available.
- CE directives — EU Authorised Representative. A mandated party who keeps your EU Declaration of Conformity and technical file available for authorities for ten years.
- WEEE — registration and an authorised representative per country. Electrical and electronic equipment needs a national WEEE registration in each Member State, and the WEEE Directive (Article 17) allows non-established producers to register only through an authorised representative there.
These are legally distinct appointments. One person or entity CAN serve multiple roles — but the mandates are separate, the registrations are separate, and the costs stack. A US seller shipping to 5 EU countries may need: 1 GPSR RP + 5 packaging EPR registrations + 5 battery EPR registrations (if applicable) + 5 WEEE registrations (if electronics) + 1 CE authorised representative.
The representative and registration costs alone — before any compliance work — can run €3,000–€10,000/year for a US seller in 5 EU markets. This is a real operating cost that should be factored into EU market entry decisions. The country-by-country detail — which registry, which scheme, what fee model — is in our EPR registration playbook, which covers all 27 Member States.
4. Marketplace enforcement — what Amazon, Shopify and Etsy check
Regulators are slow; marketplaces are not. For most US sellers, the first enforcement they meet is a marketplace suppressing a listing, not a letter from a regulator.
Amazon EU. Amazon requires the EU Responsible Person's details in listing attributes, the LUCID packaging registration number for Germany, a battery registration number where applicable, and a WEEE registration number for electronics. Missing any of these means listing suppression — and because the EU marketplaces share catalogue data, a gap can take a listing down across Amazon.de, .fr, .it, .es, .nl, .se, .pl and .be at once. The fields, the Seller Central paths and the document checklist are in the Amazon compliance kit. To see which fields your live listing is missing, paste it into the free GPSR checker.
Shopify. There is no platform-level enforcement yet — but the legal obligations are identical. Enforcement comes from customs and market-surveillance authorities in the destination country. A German consumer buying from your Shopify store has the same consumer-protection rights as one buying on Amazon.de, and a parcel that reaches German customs without a responsible person on the label can be held or refused. Shopify Markets handles currency and tax; it does not handle compliance.
Etsy. Etsy requires GPSR Responsible Person data in listing attributes for sellers shipping to the EU, and EPR enforcement is increasing — France and Germany in particular expect marketplaces to verify packaging registration numbers.
5. Step-by-step — how to start selling to the EU compliantly
Here is the order that works for most US sellers, from the first product to a steady state.
- Determine which regulations apply. Take the free compliance quiz. It maps your product category, markets and sales channels to the nine regulations above.
- Appoint an EU Responsible Person. For GPSR, this is the first and most enforced requirement. The RP must be established in the EU. Get a signed written mandate and put their details on labels, packaging and listings.
- Register for EPR in every EU country where you sell. Packaging EPR at minimum, plus WEEE and battery EPR if applicable. Start with Germany (LUCID) — it's the strictest enforcer, and Amazon checks it automatically.
- Assess CE marking requirements. If your product is electrical, electronic, a toy, or contains a radio transmitter, CE directives apply. Get testing done by an accredited lab against the EU harmonised standards, then compile the technical file and sign the Declaration of Conformity.
- Review your environmental claims. If your product, packaging or website makes any sustainability claim, EmpCo now requires substantiation. Remove generic claims such as "eco-friendly", "green" or "climate neutral" unless you can prove recognised excellent environmental performance.
- Check REACH compliance. Request SVHC declarations from your suppliers. File SCIP notifications with ECHA if a Candidate List substance exceeds the 0.1% weight-by-weight threshold in any article.
- Calculate your total cost. Use the free cost calculator to see what compliance costs across all applicable regulations — doing it yourself, on software, or with a consultant.
Before your first live listing, run the listing itself through the GPSR checker — it catches the missing safety fields marketplaces suppress for.
A worked example: a US kitchen-gadget brand
Take a Texas brand selling a rechargeable milk frother on Amazon.de, Amazon.fr and its own Shopify store, with "eco-friendly packaging" printed on the box. Here is what the stack looks like in practice.
Regulations in play. GPSR (it is a consumer product), CE marking under the Low Voltage, EMC and RoHS directives (it plugs into a charger and contains electronics), the Battery Regulation (it has a built-in lithium cell), WEEE (it is electrical equipment), packaging EPR under PPWR (it ships in a box), REACH (plastics and coatings), and EmpCo (the "eco-friendly" claim). That is seven regulations before a single unit sells.
Appointments. One EU Responsible Person for GPSR, who can also act as the CE authorised representative if the mandate covers both. In Germany and France: a packaging EPR registration, a WEEE registration and a battery registration in each — six national registrations, most of them made through a local authorised representative.
Listing changes. The Amazon listings need the responsible person's details, the LUCID number, the WEEE number and the battery registration number in the compliance attributes. The Shopify product page needs the same safety block visible before checkout, plus the German and French safety warnings in the local language.
Product and packaging changes. The CE mark, the crossed-out wheeled-bin symbol for WEEE, the battery labelling, the manufacturer's and responsible person's names on the box, and — because "eco-friendly" is a generic claim with no recognised excellent environmental performance behind it — new box artwork without that phrase.
Documents. A technical file with the lab test reports, a signed EU Declaration of Conformity, a GPSR risk assessment, supplier SVHC declarations for REACH, and a folder of registration certificates your responsible person can hand to an authority within days.
None of these steps is hard on its own. What catches US brands out is the number of them, the fact that each one sits with a different registry, and the order: marketplaces check the registrations first, so a brand that starts with lab testing and leaves EPR for later often finds its listings suppressed while the lab report is still pending.
How long it takes
For a single product in two or three markets, a realistic timeline is four to eight weeks: one to two weeks to appoint representatives and file the German packaging registration, two to four weeks for CE testing if the product has not been tested to EU standards before, and one to three weeks for WEEE and battery registrations depending on the country. Plan backwards from your launch date, and never list a product before the registration numbers are issued.
6. Common mistakes US sellers make
"I sell through a fulfilment centre, so the fulfilment company handles compliance." No. The producer obligation sits with you, not your 3PL. A fulfilment service provider can act as the GPSR economic operator only if it has formally agreed to — and most FBA-style warehouses have not. Your EPR registration is always yours.
"I only sell a few units, surely there's a threshold." There is no size or volume exemption for most obligations. EPR has some country-specific de minimis thresholds, but GPSR, CE and REACH have none. One unit placed on the market carries the full duty.
"My product is already FDA-approved / FCC-certified, so it's fine in the EU." US certifications have zero recognition in the EU. CE marking is a separate process against separate standards. Your FCC test report may help a lab reuse some data, but it cannot replace the EU assessment.
"I'll just put a European address on the label." The EU Responsible Person must be a real entity established in the EU, with a written mandate and the ability to answer authorities — not a mailbox. Authorities verify, and a fake address turns a paperwork gap into a misleading-labelling case.
"I'll deal with it when Amazon asks." By then the listing is already suppressed. Registration numbers take days to weeks to issue (LUCID is fast; some WEEE registers take over a month), and sales stop in the meantime.
Closing
EU compliance for a US seller is not optional and it's not simple — but it is manageable. The key is knowing what applies, getting the right representatives in place, and documenting everything. Start with the regulations that marketplaces enforce today — GPSR, packaging EPR and, from 27 September 2026, EmpCo claims — then work through CE, REACH and the category-specific rules. For the wider market-access picture, including customs and VAT, see our EU compliance guide for US and UK brands.
More on EU product compliance
- EU Product Compliance for Small Businesses — Do small businesses need EU product compliance? Yes — there is no size exemption.
- EU Compliance Services — Platform vs Consultant — EU compliance services compared: self-serve platform, managed service or consultant — cost, speed and upkeep.
- Best EU Compliance Platform 2026 — Comparison — How to choose an EU product compliance platform in 2026: seven criteria and a fair look at the main options.
- EU Compliance Audit — What It Costs & What You Get — What an EU compliance audit covers, the deliverable you should get, typical prices and a self-audit checklist.
- Free compliance cost calculator → — Estimate your EU compliance cost across nine regulations.
- The complete playbook collection — All eight playbooks in one bundle.
- The Regonance knowledge hub — overview
Frequently asked questions
Do US sellers need EU compliance?+
Yes. If your products reach EU consumers — through Amazon EU, your own store or wholesale — EU product regulations apply regardless of where your company is based. Non-EU sellers often carry additional duties, such as appointing EU-based representatives, because there is no EU importer to take them on.
What is an EU Authorised Representative?+
An Authorised Representative is an EU-established party mandated by a non-EU manufacturer to perform specific tasks under a regulation — under the CE directives, for example, keeping the EU Declaration of Conformity and technical file available to authorities for ten years. Under GPSR the equivalent role is the Responsible Person, and packaging and waste schemes may require their own representatives.
Need hands-on help? Our team can handle your compliance — from a €499 single-product scan to full catalogue management. Book a consultation →
Run a free compliance scan
Three products, all nine EU regulations, source-traced findings. No card required.
Start free workspaceEvery EU deadline, on one page.
Nine mandates, each with dates attached between now and 2030. Get the calendar, plus a note when the guidance behind an article like this one changes.
- → Every applicable EU compliance date
- → Which mandate hits your category first
- → An alert when a rule or guidance changes
Compliance guidance based on published EU regulatory texts. Not legal advice. Consult qualified counsel for your specific situation.