Your own EU importer company, for products made outside the EU
A maker outside the EU that sells products in Europe needs a company in the EU that imports the goods, puts its name on the product and answers the authorities. From 9 December 2026 that company is also liable for a defective product, together with the maker. Many makers with a turnover of EUR 10 to 500 million therefore want that company inside their own group. We set up that Dutch importer company, arrange its registrations and partners, and do its administration for the years in which claims can come.
Ask about your situationYour own Dutch company imports your goods in its own name, is the responsible operator for product safety and the packaging producer for the Netherlands, and, when you sell direct, your authorised representative. One company holds these roles for the whole EU, with its own customs number (EORI), VAT number and Article 23 licence that keeps import VAT out of the border.
For products placed on the market after 9 December 2026, that importer company is liable for a defective product together with you, under Directive (EU) 2024/2853. The company holds the insurance and keeps the product records for the ten years in which a claim can be brought, and your group keeps the European liability in one place it controls.
We set up the company, request its registrations, keep its books, file its returns and annual accounts and keep the calendar of registrations and renewals. A compliance partner checks your technical file first, and partners take the physical and licensed work. You appoint the directors and see every price first.
Tell us what you make or sell, where your company is and what you plan in Europe. Our team looks at it and replies with the steps and the dates that apply to you.
Who does what
You own the products and the technical file, we set up and administer the importer company, and partners take the licensed and physical work.
Your company
- Design, production, tests and the technical file
- Markets, prices, distributors and the sales channels
- The directors of the Dutch company and its business address
The Dutch company
- The Dutch BV as your importer and responsible operator, by power of attorney
- EORI, VAT, the Article 23 licence, eHerkenning and the Dutch packaging, battery and electronics registrations
- Bookkeeping, VAT returns, annual accounts and the calendar of registrations and renewals
Compliance, customs, warehouse, insurance
- Compliance specialist that checks the technical file before the company takes a role
- Customs broker, warehouse and fulfilment with the name of your company on the contract
- Packaging, battery and electronics representatives in other EU countries
- Insurance broker for product liability
Step by step
From a maker that sells to EU distributors to a maker with its own EU importer.
- Your products and your buyers. You share your product types, your EU turnover and how your goods enter the EU today, and we send a written proposal with the roles and the partners.
- The file check. A compliance partner checks the technical file, the labels and the declarations of conformity of a sample of your products.
- The company. The notary sets up the Dutch BV by power of attorney.
- The numbers and the registrations. We request EORI, VAT, the Article 23 licence and eHerkenning, and we register your company as packaging, battery and electronics producer in the Netherlands.
- Insurance and contracts. Our partner arranges the product liability cover, and your factory and the Dutch company sign the supply terms.
- The label. The product or its packaging shows the name and address of your Dutch company.
- Every year. We keep the books, file the annual accounts and renew the registrations, and you receive the figures each quarter.
The roles your importer company holds
One Dutch company can hold the roles below for the whole EU. The packaging, battery and electronics registrations work per country, and for sales direct to consumers in other EU countries a representative in each of those countries comes from our partners.
| Role | Law | Since | What your company does |
|---|---|---|---|
| Importer at customs | Union Customs Code, Regulation (EU) 952/2013, Article 170; from 21 September 2027 Regulation (EU) 2026/2108, Article 27 | In force | Declares the goods in its own name, pays the duty once per shipment and keeps the records |
| Responsible operator for product safety | GPSR, Regulation (EU) 2023/988, Article 16, and Regulation (EU) 2019/1020, Article 4 | 13 December 2024 and 16 July 2021 | Checks the technical file, keeps it for ten years, puts its name and address on the product and answers the authorities |
| Importer of machinery and CE products | Machinery Regulation (EU) 2023/1230, Article 13 | 20 January 2027 | Checks the conformity assessment, the CE marking and the documents, and puts its name and a digital contact on the product |
| Importer of connected products | Cyber Resilience Act, Regulation (EU) 2024/2847, Article 19 | Full application 11 December 2027 | Checks the conformity assessment, the technical documentation and the CE marking, puts its name and contact details on the product, and passes any vulnerability it learns of to the maker and the authorities |
| Packaging producer for the Netherlands | PPWR, Regulation (EU) 2025/40, Articles 44 and 45 | 12 August 2026 | Registers with the Dutch scheme (Verpact), reports the packaging and pays the fees; a representative in each other country for direct sales there |
| Battery and electronics producer for the Netherlands | Batteries Regulation (EU) 2023/1542, Articles 55 and 56; WEEE Directive 2012/19/EU, Article 17 | In force | Registers as producer in the Netherlands; a representative in each other country where you sell direct to end users |
| Liable importer or authorised representative | Directive (EU) 2024/2853, Articles 8 and 15 | Products placed on the market after 9 December 2026 | Is liable with the maker for a defective product, holds the insurance and keeps the product records |
The full list of EU roles, with the specialist roles that come through partners, is on the page EU representative requirements.
What changes on 9 December 2026
Directive (EU) 2024/2853 applies to products placed on the market after 9 December 2026. For a maker established outside the EU, the importer of the product and the authorised representative of the maker are liable for a defective product, together with the maker. When both are missing in the EU, the fulfilment service provider that stores, packs or ships the goods is liable (Article 8). Several liable companies are liable jointly and severally (Article 12), and a contract clause that limits the liability towards the injured person is void (Article 15). A company that pays can recover from the others under national law (Article 14).
Our page on the EU product liability directive 2026 explains the rules and the state of the national laws, and the free product liability check shows who pays for your product.
Tell us what you make or sell, where your company is and what you plan in Europe. Our team looks at it and replies with the steps and the dates that apply to you.
What warehouses, distributors and marketplaces ask
A fulfilment company is liable for the goods on its shelves whenever the seller outside the EU has neither an importer nor an authorised representative in the EU. Warehouses therefore ask for the name and address of the importer or representative before they accept a pallet, and they add indemnity and insurance clauses to their contracts. A seller that can give the name of its own EU company keeps its place in the warehouse.
An EU distributor that buys at your factory and brings the goods into the EU is the importer itself, and shares the liability. Distributors answer with contracts, indemnities and insurance demands, and some of them prefer a supplier with its own EU importer, so that the liable company is in the group of the maker and the distributor stays a distributor. Our page losing your EU distributor describes what happens when a distributor withdraws.
Marketplaces check that a listing shows the maker, the EU responsible person and the product identification. In the product safety sweep of the European Commission of 2026, 58% of the screened listings showed all three, and the authorities sent 560 removal orders.
A service representative or your own company
| A service representative | Your own Dutch company | |
|---|---|---|
| Who is liable from 9 December 2026 | The service company, which asks for indemnities and insurance | Your Dutch company, with your group behind it |
| Whose name is on the product | The service company | Your Dutch company |
| Import VAT at the border | Paid or deferred through a fiscal representative | €0 with the Article 23 licence in the name of your company |
| Who keeps the records and the calendar | The service company, within its mandate | Your company, with our administration and our calendar of filings |
| Suits | A market test, a narrow range, a small share of turnover in Europe | Steady EU sales, several roles, contracts with European buyers |
The choice in more detail is on the page EU responsible person or your own entity.
Why a partner that stays
An importer company is judged years after a sale. A claim can be brought three years after the injured person knew of the damage, and the right to claim ends ten years after the product was placed on the market, or 25 years for personal injury that appears later. The company must therefore keep the technical file, the batch records and the declarations of conformity in order for a decade, file its annual accounts on time every year and renew its registrations in every country where it sells.
We keep the books, file the returns and the annual accounts, keep the calendar of registrations and renewals, and remind your board when a date comes up. The specialist checks of the technical file, the labels and the insurance cover are done by the partners your company contracts for that work, and your board decides. Our page your own EU company with a partner that stays describes the whole set-up.
The dates for product makers
| Date | What applies |
|---|---|
| 1 July 2026 | A customs duty of €3 per item type on parcels up to €150 sold to EU consumers from outside the EU, until 1 July 2028 (Council Regulation (EU) 2026/382); a bulk import into your own stock pays the normal duty once |
| 12 August 2026 | Packaging registration in each EU country where you sell direct to end users, with a representative in each of them (PPWR, Article 45); the Council position of 21 October 2026 on a pause covers EU producers only |
| 11 September 2026 | Makers report exploited vulnerabilities and severe incidents in products with digital elements (Cyber Resilience Act, Article 14) |
| 1 November 2026 | An EU handling fee of €2 per item type on parcels sold to EU consumers from outside the EU (Delegated Regulation (EU) 2026/2152) |
| 9 December 2026 | The importer and the authorised representative are liable for defective products placed on the market after this date (Directive (EU) 2024/2853) |
| 20 January 2027 | The Machinery Regulation applies in full, with the importer’s name and digital contact on the machine |
| 18 February 2027 | The battery passport for electric vehicle and industrial batteries (Batteries Regulation) |
| 21 September 2027 | The new Union Customs Code applies, and every importer is established in the EU or represented by a customs broker who counts as the importer (Regulation (EU) 2026/2108, Articles 27 and 33) |
| 11 December 2027 | The Cyber Resilience Act applies in full |
| 17 April 2028 | Producer responsibility for textiles and footwear in every EU country, with a representative per country for direct sales (Directive (EU) 2025/1892) |
| 1 July 2028 | The seller or platform becomes the importer for distance sales to EU consumers, established in the EU or represented by a customs broker with AEO or Trust and Check status |
All dates per rule, with their sources, are in our EU compliance calendar.
Sources: Directive (EU) 2024/2853, Articles 2, 8, 12, 14, 15, 16 and 17; Regulation (EU) 2023/988 (GPSR), Article 16; Regulation (EU) 2019/1020, Article 4; Regulation (EU) 2023/1230, Articles 13 and 54; Regulation (EU) 2024/2847 (Cyber Resilience Act), Articles 14 and 19, and ENISA, 11 September 2026; Regulation (EU) 2025/40 (PPWR), Articles 44 and 45, and Council press release 841/26, 21 October 2026; Regulation (EU) 2023/1542, Articles 55 and 56; Directive (EU) 2025/1892; Regulation (EU) 2026/2108, Articles 27, 33 and 287; Council Regulation (EU) 2026/382; Delegated Regulation (EU) 2026/2152; European Commission, product safety sweep 2026, 7 September 2026. Checked on 29 October 2026.
Common questions
Ask about your own situation
Tell us what you make or sell, where your company is and which countries you want to sell in. Our team replies with advice.
Related guides
The rules per product group and the set-up.