Product compliance: CE, GPSR and EPR

This is the lesson that decides whether your listings stay switched on. Three separate regimes apply, they come from different laws, and satisfying one does nothing for the others. Most sellers discover them in the wrong order: a listing is deactivated, and the education begins.

CE marking: does your product need it?

CE marking signifies that a product sold in the European Economic Area has been assessed to meet safety, health and environmental protection requirements. It is compulsory only for products covered by the relevant EU product legislation, and it is forbidden to affix it to other products.¹

Who does what:

• The manufacturer carries out the conformity assessment, sets up the technical file, issues the EU declaration of conformity, and affixes the marking.¹ If you are a private label seller, the factory may do the testing, but the obligations attach to whoever places the product on the market under their name.
• Importers and distributors must know the legal requirements and ensure that what they import or distribute meets them.¹ “My supplier said it was fine” is not a defence.

A point worth internalising: the Commission states plainly that CE marking does not mean a product was approved as safe by the EU or any authority.¹ It is a declaration by the responsible party, backed by a file they must be able to produce.

GPSR: somebody in the Union must be responsible

The General Product Safety Regulation, Regulation (EU) 2023/988, has applied since 13 December 2024. Its central requirement for a seller outside the Union is short: for each product covered, there must be a responsible economic operator established in the EU — an EU manufacturer, importer, authorised representative or fulfilment service provider — entrusted with tasks relating to the product's safety.²

The regulation also puts obligations on marketplaces. Providers must cooperate with market surveillance authorities, register in the Safety Gate portal, and maintain two single points of contact — one for authorities, one for the public. They must ensure that manufacturers and importers comply, refuse products they consider non-compliant, inform authorities through the Safety Business Gateway where they believe a dangerous product is on the market, and act on removal orders.²

That is why enforcement reaches you through Amazon rather than through a ministry: the marketplace is legally obliged to check, and switching a listing off is the cheapest way for it to comply.

EPR: one registration per country, per category

Extended producer responsibility makes whoever puts packaging, electrical equipment, batteries and other regulated goods onto a national market responsible for financing their collection and recycling. It is national law, not Union law, so it multiplies by country.

• Germany. The Packaging Act requires registration in the LUCID packaging register before the first sale, with no minimum volume threshold, alongside participation in a dual system and data reporting.³
• France. Registration with an approved éco-organisme and a unique identification number per applicable category, across a framework covering many categories including electrical and electronic equipment, batteries, packaging, furniture, textiles and tyres.⁴
• Everywhere else. Each member state has its own scheme. A German LUCID number does nothing for France, and a French identifier does nothing for Italy.

Amazon requires these numbers and enforces their absence. Its own guidance states that sellers must register with the producer responsibility organisations, report and pay eco-contributions, and provide their identification numbers, and that where a seller is considered non-compliant Amazon may deactivate the non-compliant listings, or comply on the seller's behalf — which means paying the contribution and charging it to you.⁴

The order to do this in

1. Classify the product. Which EU product legislation covers it, if any? This decides whether CE marking applies and what testing is needed.
2. Name the responsible economic operator inside the Union, and get their agreement in writing.
3. Assemble the documentation: technical file, declaration of conformity, test reports, and the product identification and traceability information the regulation requires on distance sales.
4. Register for EPR in each country you will sell into, for each applicable category, before goods arrive.
5. Enter the numbers in Seller Central, because Amazon checks them.
6. Keep records of complaints and accidents, which the regulation expects of distance sellers and which you will want if a recall is ever discussed.

Mistakes that switch listings off

• Assuming CE marking is optional or universal. It is mandatory where product law applies and forbidden where it does not.
• Having no responsible economic operator in the Union. Required since December 2024, and marketplaces are obliged to check.
• Treating a German LUCID number as European coverage. EPR is national and per category.
• Registering after stock arrives. Germany requires registration before the first sale, with no threshold.
• Letting Amazon comply on your behalf. It is the most expensive way to become compliant.
• Relying on a supplier's assurance without the file. The obligation sits with whoever places the product on the market.
• Costing compliance after choosing the product. It belongs in the unit economics from the start.

Next

Lesson 6 is importing into the Union: customs, duties, the €150 line, and what an inspection costs in time.