Consumer products in Europe: one company for all the duties

The responsible person under the product safety rules

The GPSR replaced the old product safety directive and covers consumer products that lack EU safety rules of their own, such as furniture, textiles, sports goods, kitchenware, decoration, tools for home use and everything sold on marketplaces. Medicines, food, animal feed, living plants and antiques are excluded (Article 2). A product may be sold in the EU only if it has a responsible person established in the EU. A manufacturer based in the EU takes that role itself; otherwise the importer or an authorised representative appointed by written mandate takes it, and when all of them are outside the EU, a fulfilment service provider in the EU is responsible by law.

The responsible person checks that the technical documentation and the safety information exist, works with the authorities, reports accidents and dangerous products through the EU reporting portal, the Safety Business Gateway, and takes part in recalls. The manufacturer and the importer keep the documents for ten years. The name, address and an electronic contact of the responsible person appear on the product, on its packaging or in a document supplied with it, and online marketplaces show these details to buyers.

The importer and the economic operator for CE-marked products

Toys, electronics, radio equipment, personal protective equipment, machinery for home use and several other product groups have their own EU rules and bear the CE marking. Under the market surveillance regulation, these products have needed an economic operator established in the EU since 16 July 2021, which can be the manufacturer, an importer or an authorised representative, and when all of them are outside the EU a fulfilment service provider in the EU takes the role by law (Regulation 2019/1020, Article 4(2)(d)). The importer has extra duties. It checks that the product went through the required safety assessment (conformity assessment), that the declaration of conformity and the technical documentation exist and that the product is labelled correctly, and it puts its own name and address on the product.

Electronics and connected products face further rules. Under the radio equipment directive, 13 types of portable devices have needed a USB-C charging port since 28 December 2024, and laptops since 28 April 2026. The EU law on cybersecurity for connected products, the Cyber Resilience Act, covers every product with digital elements, and since 11 September 2026 manufacturers must report security weaknesses that attackers actively exploit, as well as severe incidents. The full requirements apply from 11 December 2027, as set out in machinery, electronics and connected products.

Producer registrations for packaging, batteries, electronics and textiles

The company that first places a packaged product on the market in an EU country pays for the collection and recycling of that packaging, which in the Netherlands is organised through the Verpact scheme. A company with more than 50,000 kg of packaging a year reports the kilos per material and pays a fee per kilo, and cans, plastic bottles and single-use plastic are always registered. Since 12 August 2026, the EU packaging regulation, the Packaging and Packaging Waste Regulation (PPWR), has required a company that sells directly to end users in another country to appoint an authorised representative there (Article 45(3)).

The same principle applies to batteries and to electrical and electronic equipment, where the producer registers in each country of sale and appoints an authorised representative in any other country where it sells at a distance to end users. Since 1 July 2023 the Netherlands has also made producers responsible for the waste from textiles (extended producer responsibility), so a company that first sells clothing or household textiles in the Netherlands registers and reports.

Your Dutch company acts as the producer for the Netherlands and has the registrations in its own name. For Germany, France and the other countries where you sell directly to end users, it appoints a representative in each country through our partner, and every scheme lists your company under the same name and address.

Why the Netherlands for consumer goods

Rotterdam is the largest port in Europe and Schiphol one of the largest cargo airports in Europe, and 170 million consumers live within 500 km of the Netherlands. With the Article 23 licence, your company reports import VAT in its VAT return and the VAT payment at the border falls away, although any customs duty remains due at import. Once sales to consumers in other EU countries exceed €10,000 a year, you can report the VAT of those countries in one return, the EU VAT return for cross-border sales (OSS).

The Netherlands Food and Consumer Product Safety Authority (NVWA) supervises consumer products on the Dutch market, including their electrical safety, while the Dutch Authority for Digital Infrastructure (RDI) supervises radio equipment such as wifi and bluetooth devices. A Dutch company pays 19% corporate tax on the first €200,000 of profit and 25.8% on profit over that amount. More background is in entering the EU market and setting up a subsidiary in Europe.

Based on Regulation (EU) 2023/988 (GPSR), Regulation (EU) 2019/1020 (market surveillance), Regulation (EU) 2025/40 (PPWR) and Regulation (EU) 2023/1542 (batteries). Also based on Directive 2012/19/EU (WEEE), the Dutch extended producer responsibility decrees and the guidance of the NVWA and the RDI. All as applied in September 2026. Product files are prepared by specialised partners; we coordinate.