EU representative requirements: which roles your products need

The EU roles, the laws and who can take them

From 14 December 2027, products made with forced labour are banned from the EU market, whatever their origin (Regulation (EU) 2024/3015), and the authorities focus their checks mainly on importers.

For packaging, the Council of the EU agreed its position on a pause for small volumes on 21 October 2026. Under the Council text, a producer established in an EU member state that places less than 1 tonne of packaging a year in another member state needs a packaging representative there only from 1 January 2032. Producers established outside the EU keep the duty in every member state. The pause becomes law once Parliament and Council agree, and because your own Dutch company is a producer established in the EU, it can then use the pause. See packaging rules after 12 August 2026.

Check which EU rules apply to your products by answering a few questions, and see your EU roles, registrations and dates.

Importers of steel, aluminium, cement or fertilisers can work out their yearly cost under the EU carbon border tax (CBAM) with the CBAM cost calculator.

One Dutch company, many roles

A service company takes one role for your product, while your own Dutch company can take several roles at once for the whole EU. It imports your goods, keeps your stock, sells to your customers and appears on your label, and it has its VAT number, EORI number and Article 23 licence in its own name.

A company that takes a role also takes on its legal duties, such as product safety and record keeping, so a partner checks the technical file of your product before your company takes the role. We arrange this check.

Your own Dutch private limited company (BV) costs from €2,950 excl. VAT, and a holding with an operating company from €4,950 excl. VAT. Partner work has its own price, which you see in advance. We are an independent Dutch firm, and our page on company formation in the Netherlands gives the details.

Who does what

• You own the product, the technical file and the brand. You decide the countries, the channels and the price. You sign the mandates and see every price first.
• We set up your Dutch company and arrange its VAT number, EORI number, Article 23 licence, bookkeeping and VAT returns. We are your contact for every partner.
• Partners check the technical file and take the specialist roles, such as packaging representative in other countries and the roles for medical devices, cosmetics, chemicals, personal data and customs work. We choose the partner with you for each assignment, after you ask for it.

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Sources

• Regulation (EU) 2023/988 on general product safety (GPSR), Articles 16 and 19, EUR-Lex (2023).
• Regulation (EU) 2019/1020 on market surveillance, Article 4, EUR-Lex (2019).
• GOV.UK, General product safety regulations: Northern Ireland (updated November 2025).
• Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), recitals 123 and 132 and Article 45, EUR-Lex (2025).
• WKO, PPWR in Deutschland (October 2026): the representative in Germany.
• Regulation (EU) 2023/1542 on batteries and waste batteries, EUR-Lex (2023).
• Swedish Environmental Protection Agency, producer responsibility for battery producers (September 2025): the rules since 18 August 2025.
• Directive (EU) 2025/1892 amending the Waste Framework Directive, Articles 3 and 22a, EUR-Lex (2025): schemes for textiles and footwear by 17 April 2028.
• European Parliament, deal on the Union Customs Code reform (March 2026).
• European Commission, press release IP/26/1178 on the Temu fine (28 May 2026).
• Irish Revenue, Union Customs Code: applies across the EU since 1 May 2016.
• Regulation (EU) 1169/2011 on food information to consumers, EUR-Lex (2011): applies since 13 December 2014.

Last reviewed: October 2026. Based on the laws named in the table, as they apply in October 2026.

Common questions