EU Seller Kit

EU product compliance by product category: toys, cosmetics, electronics and textiles

EU product compliance by product category is not governed by one universal checklist. A toy, cosmetic, electronic device and textile product fall under different rules. Before you import or sell, identify the product’s actual category, the relevant sector legislation, your role in the supply chain and the requirements in each country where it will be marketed.

Key takeaways

  • A product can be subject to sector-specific rules, general product-safety rules and national obligations for waste, batteries or packaging at the same time.
  • CE marking is required only where harmonised EU legislation requires it; it does not apply automatically to every product sold in the EU.
  • The manufacturer remains responsible for conformity assessment, necessary testing, technical documentation and, where required, the EU declaration of conformity.
  • Before a first shipment, check the product, labelling, documents, EU-based economic operator and import formalities.

How do you identify the rules for your product category?

Start with the product’s intended use, functions and target user, not its marketing name. This classification determines which legislation applies, what evidence you need and whether CE marking may be required.

One item can fall under more than one regime. A soft toy with a Bluetooth module is first a toy, but its radio function may also bring radio-equipment rules into scope. A battery-powered heated garment may involve textile rules, general product safety and electrical or battery requirements, depending on its design.

Create a factual product record before you order stock: composition, intended age group or user, power source, connectivity, substances, claims, country of origin, storage countries and sales countries. The EU Market Entry Compliance Assessment helps you organise this review when planning a first launch or when you are not yet sure which obligations need checking.

The general safety framework is set by Regulation (EU) 2023/988 on general product safety, known as the GPSR. It applies in particular to consumer products where sector-specific legislation does not cover certain risks. More specific sector legislation takes precedence for the matters it covers.

In practice, do not confuse customs classification with product compliance. A tariff classification determines customs treatment; it does not prove that a product is safe or compliant. You can generate candidate subheadings with the HS classification assistant, then confirm the code in the Combined Nomenclature and TARIC before import.

EU Seller Kit — For a first market launch, use the EU Market Entry Compliance Assessment to sequence product, customs, VAT and economic-operator checks before you place an order or ship goods.

What should you do before importing or selling in the EU?

Use a clear sequence: classify the product, obtain manufacturer evidence, check labelling, arrange any required economic operator, then prepare import and online sales. Do not publish the product for sale before the documents have been reviewed.

A practical process before the first shipment

  1. Describe the product and its intended use. Keep technical specifications, photographs, variants, instructions and composition information. A different battery, material or radio function can change the applicable regime.
  2. Identify sector-specific legislation. Check whether the item is a toy, cosmetic, electrical product, radio equipment or textile. Also review the general safety requirements applying to the finished product.
  3. Request evidence from the manufacturer. Depending on the category, this may include test reports, a risk assessment, technical documentation, an EU declaration of conformity, a cosmetic product safety report or a product information file.
  4. Check visible information. The name and address of the relevant operator, product identification, warnings, instructions and languages suitable for the target market must match the product actually being shipped.
  5. Prepare the import flow. If you import from China, the United States or another non-EU country, the relevant operator will generally need an EORI number for customs formalities. The European Commission explains the purpose of EORI.
  6. Review the sales listing. Safety and traceability information must also be available in distance sales where the GPSR requires it. Before publishing on a marketplace, the Marketplace Product Compliance Scanner can flag information that needs checking.

Launch checklist

  • I have identified the product’s intended use, variants and functions.
  • I have determined the sector-specific rules and GPSR requirements to review.
  • I have received and checked documents for the exact product and version being sold.
  • I have checked CE marking only where it is required for this category.
  • I have prepared warnings, instructions and traceability information in the necessary languages.
  • I have identified the manufacturer, importer and, where needed, the EU-established operator.
  • I have checked VAT, customs, packaging, WEEE and battery obligations for my storage and sales countries.

Imagine a US manufacturer shipping stock to an Amazon FBA warehouse in Germany. The review does not stop at the Amazon listing: you must also prepare the import, VAT position, product obligations and, depending on the item, waste-stream requirements. The EU stock import guide for ecommerce sellers explains how these workstreams fit together.

What does EU product compliance by product category require for toys and cosmetics?

Toys require a safety assessment and CE marking, while cosmetics require, among other things, an EU responsible person, a product information file and notification before market placement. The evidence required for these two categories is therefore very different.

Toys: safety, CE marking and warnings

Toy Safety Directive 2009/48/EC covers products designed or intended for use in play by children under 14. The manufacturer must assess hazards and establish conformity before placing a toy on the market. CE marking is required for toys that meet the applicable requirements.

Check that warnings reflect a genuine risk and the intended age group. A warning does not cure an unsafe design. For example, stating “not suitable for children under 36 months” is not enough where the product is clearly intended for very young children or presents an unmanaged risk.

Ask the manufacturer for the technical file, safety assessment, relevant test reports, EU declaration of conformity and traceability information. For a detailed working method, see the guide to selling toys in the European Union.

Cosmetics: responsible person, PIF and CPNP

Regulation (EC) No 1223/2009 on cosmetic products provides that a cosmetic product may be placed on the EU market only where an EU-based responsible person has been designated. That person is responsible, among other things, for ensuring the availability of the product information file, commonly called the PIF, and notification through the CPNP before market placement.

A cosmetic is not simply any “beauty product”. Classification depends on its intended purpose: cleaning, perfuming, changing appearance, protecting, keeping in good condition or correcting body odours. A therapeutic claim can move the assessment into another regulatory regime, so have the classification checked before selling.

Labelling must be consistent with the formula, function, precautions for use and required information. Follow the operational sequence in the CPNP and cosmetics guide for Europe.

Which rules apply to electronics and textiles?

Electronics can fall under several CE directives according to their characteristics. Textiles must at least meet fibre-name and fibre-labelling rules, alongside applicable product-safety requirements. The presence of a plug or battery alone is not enough to reach a conclusion.

Electronics: RED, EMC, low voltage, WEEE and batteries

A device connected through Wi-Fi, Bluetooth or a mobile network will generally fall under Directive 2014/53/EU on radio equipment, known as RED. Electrical equipment may also fall under Directive 2014/30/EU on electromagnetic compatibility and, depending on its electrical characteristics, Directive 2014/35/EU on low-voltage electrical equipment.

CE marking is valid only where the manufacturer has followed the applicable procedure for that exact device, compiled the technical documentation and signed an EU declaration of conformity where required. A generic supplier declaration that does not identify the model, relevant directives and supporting tests is a warning sign.

Electronics can also create waste electrical and electronic equipment obligations. Directive 2012/19/EU on WEEE sets the EU framework for collection and treatment of such equipment, while registration arrangements are national. If the device contains a cell or battery, review the corresponding rules in every country where you sell. The RED, low-voltage and EMC guide for electronics sellers sets out the main checks.

Textiles: fibre composition and safety

Regulation (EU) No 1007/2011 on textile fibre names and labelling sets rules for fibre descriptions and fibre-composition indications. The names used must be those provided by the Regulation; marketing terms do not replace a regulated textile composition.

An ordinary garment does not automatically carry CE marking. It must, however, be safe under the GPSR, and composition information must be suitable for the markets concerned. If you sell in France, Germany and Spain, plan for language requirements and national packaging obligations. The EU textile labelling guide helps you check composition, languages and common errors.

Which EU operator must you appoint, and which documents should you retain?

The operator you need depends on the applicable legislation and your place in the supply chain. Manufacturer, importer, distributor, GPSR responsible person and CE authorised representative are not interchangeable roles. Keep documents for the period required by the applicable legislation and make them available if an authority requests them.

For consumer products sold by a manufacturer established outside the Union, the GPSR requires an EU-established economic operator to be associated with the product. Information about that operator must be available under the applicable framework, including for distance sales. The GPSR responsible person guide explains the roles and the information expected on online offers.

A CE authorised representative acts under a written mandate where the applicable CE legislation permits it. This does not replace the manufacturer: the manufacturer remains responsible for conformity assessment, testing, technical documentation and the EU declaration of conformity. Read about the role and limits of a CE authorised representative before choosing this arrangement.

Your compliance file will vary by product, but it should generally allow you to retrieve:

  • the model and variant identification;
  • contact details for the manufacturer, importer and EU-established operator where required;
  • relevant risk assessments, tests and certificates;
  • the EU declaration of conformity where the product falls under CE legislation;
  • approved versions of labels, instructions and warnings;
  • invoices, shipping documents and batch-traceability records.

A common mistake is to assume that a software subscription automatically appoints a responsible person or authorised representative. It does not. These services become active only after acceptance, entity assignment, a signed mandate and active payment. If you need an EU-established GPSR operator, review the GPSR Responsible Person service. For a CE mandate where the legislation allows it, see the CE Authorised Representative service.

Tools and services to take action

  • EU Market Entry Compliance Assessment — use it before a first shipment to organise the CE, GPSR, VAT, customs, packaging, WEEE, battery and product-data checks that apply to your plan.
  • Marketplace Product Compliance Scanner — use it before publishing on Amazon, eBay, Etsy, Shopify or another marketplace to identify safety and traceability information that needs review.
  • GPSR Responsible Person — consider this service where a non-EU seller or manufacturer needs an EU-established economic operator for consumer products; activation remains subject to review, entity assignment, a signed mandate and active payment.
  • CE Authorised Representative — use it where a non-EU manufacturer of CE-marked products needs a written mandate permitted by the applicable legislation, without transferring its own conformity obligations.
  • Pricing and plans — review SaaS plans and add-on services according to your situation.

Official sources

This content provides general information and is not legal advice.