EU product compliance for online sellers 2026 — EPREL, GPSR, CE marking, and what you can't skip
Why EU compliance turned into a delisting risk in 2025-2026
If you sell physical goods into the European Union via Shopify, Amazon EU, eBay or Etsy, the compliance environment you operated under three years ago no longer exists. Until late 2024, EU compliance for cross-border sellers meant a VAT registration, an OSS return and a CE-marked product sheet from your supplier. The General Product Safety Regulation (GPSR) became applicable on 13 December 2024, and the European Product Registry for Energy Labelling (EPREL) shifted from "publish a label PDF" to "register every model SKU before listing". Amazon began mass-delisting non-compliant ASINs in early 2025; Bol.nl, Cdiscount and Otto followed. Shopify enabled GPSR fields in March 2025. Penalties stack: in Germany alone, energy-labelling breaches are administrative offences with fines of up to €50,000 per case under § 15 EnVKG. A missing GPSR EU representative can pull every SKU into involuntary withdrawal. This guide walks the four obligations you cannot skip — EPREL, GPSR, CE marking, and the EPR triumvirate (WEEE, batteries, packaging) — with deadlines, registries and penalties current to 2026-06-12. See our EPREL GTIN finder and the companion guides: EPREL registration walk-through, GPSR EU representative requirement, and Amazon Compliance Reference decoded.
What changed in 2025-2026
Four shifts moved EU seller compliance from background paperwork to front-of-funnel gating.
First, Regulation (EU) 2023/988 — the General Product Safety Regulation (GPSR) — replaced Directive 2001/95/EC on 13 December 2024. Unlike its predecessor it applies uniformly across all 27 member states without transposition. The two material changes: (a) every non-EU manufacturer must designate an EU-based responsible economic operator under Article 4, whose name and address appears on the product or its packaging, and (b) marketplaces under Article 22 are jointly responsible for ensuring listings carry the safety information GPSR mandates. Amazon's Compliance Reference dashboard, eBay GPSR fields, and Shopify's "responsible person" attribute are direct consequences.
Second, Regulation (EU) 2017/1369 — the Energy Labelling Framework Regulation — and its delegated acts now require EPREL pre-registration before any product subject to an energy label is placed on the EU market. The Commission's portal at eprel.ec.europa.eu is the single registry. Products covered include lighting, refrigerators, washing machines, dishwashers, displays, tumble dryers, air conditioners — and, since 20 June 2025, smartphones and slate tablets under Delegated Regulation (EU) 2023/1669. Listing without a valid EPREL ID is a market-surveillance violation, enforced in Germany by the Länder market-surveillance authorities under the EnVKG/EnVKV regime, in France by the DGCCRF and in the Netherlands by the ILT.
Third, the Digital Services Act (DSA), Regulation (EU) 2022/2065, applies to all online platforms from 17 February 2024. Article 30's traceability of traders obliges marketplaces to collect and verify business name, address, VAT ID, bank account and contact details before you can list. The verify-business-information flow on Amazon EU in 2024-2025 was Article 30 in practice.
Fourth, marketplace EPR responsibility. The German Verpackungsgesetz, the French AGEC law and the Spanish Ley 7/2022 de Residuos make marketplaces verify sellers' Extended Producer Responsibility registrations. Amazon EU has suspended listings without a German LUCID since July 2022 and tightened enforcement for French UIN and Spanish RAEE-AP through 2024-2025.
EPREL energy labels — who needs to register
EPREL is the single mandatory registry for any product carrying an EU energy label. The legal basis is Regulation (EU) 2017/1369 plus delegated regulations (2019/2015 light sources, 2019/2016 refrigeration, 2019/2017 dishwashers, 2019/2014 washing machines, 2019/2013 electronic displays, 2020/740 tyres, and — since 20 June 2025 — 2023/1669 smartphones and slate tablets). If your SKU falls in any of those you must register before placing it on the EU market.
What "register" means: as the supplier — manufacturer, importer or authorised representative, but not a distributor — you create an account at eprel.ec.europa.eu/screen/home, log in via EU Login, then submit per model the GTIN, the supplier model identifier, the technical documentation (a single PDF/ZIP upload), the energy label PDF and the product information sheet. EPREL issues an EPREL ID and a QR-coded label that must appear on the product and the listing.
Two traps. First, the GTIN must match exactly the box and the marketplace listing — Amazon cross-checks the ASIN GTIN against EPREL and a mismatch produces a non-compliant flag. Second, distributors cannot register; if you resell a manufacturer's product and the manufacturer never registered it, you cannot ship it. Pressure the manufacturer, or become the importer-of-record.
Fines vary by member state. In Germany, breaches of the labelling obligations are administrative offences under § 8 EnVKV in conjunction with § 15 EnVKG, with fines of up to €50,000 per case, enforced by the Länder market-surveillance authorities. France's DGCCRF applies administrative fines per product for legal persons, and the Spanish and Dutch regimes likewise provide five- to six-figure administrative penalties for catalogue-wide breaches. Our EPREL GTIN finder cross-references your GTIN against the live EPREL database.
GPSR — the 2024 marketplace shake-up
GPSR (Regulation (EU) 2023/988) changed the cross-border seller workflow. It applies to all non-food consumer products placed on the EU market, including via distance sales (Article 1). Five obligations matter.
First, the EU responsible economic operator (Article 4). A non-EU manufacturer or non-EU brand must designate an EU-established person — manufacturer, importer, authorised representative or fulfilment service provider — whose name and contact address appears on the product, packaging or accompanying document. Amazon's GPSR field on each EU ASIN requires this; a missing responsible person is the single most common reason for Amazon EU delistings in 2025.
Second, technical documentation (Article 9, Annex II). You must hold per product a risk analysis covering foreseeable use and misuse, the harmonised EN standards applied (those in the Official Journal), evidence of testing or self-assessment, instructions, safety information and traceability data. The file is not submitted to a registry, but you must produce it within 10 working days when a market surveillance authority asks. The GPSR EU representative guide covers who must hold this file and for how long.
Third, traceability (Article 9.5). The product, packaging or accompanying document must carry a type, batch or serial number that lets authorities trace the unit to your supply chain.
Fourth, safety information (Article 9.7). Warnings and instructions in a language understood by consumers in the member state — French for France, German for Germany and Austria, Spanish for Spain, Italian for Italy, Dutch for the Netherlands and Flemish Belgium.
Fifth, incident reporting (Article 20). If a product you placed on the market is found dangerous, report through the Safety Business Gateway within two working days.
Penalties are national. Spain reaches €601,012 for very serious infringements. France's Code de la consommation L452-5 imposes up to 10% of annual turnover. Germany's Produktsicherheitsgesetz §28 reaches €100,000 per case with criminal liability for ongoing serious cases. The companion tool GPSR listing safety check checks a listing against these obligations.
CE marking — when is it required
CE marking is not a generic EU quality stamp. It is a manufacturer declaration that a product complies with the essential requirements of the applicable Union harmonisation legislation. If no harmonisation legislation covers your product, affixing CE is itself a sanctioned offence.
The categories that do require CE marking are enumerated in roughly 20 directives and regulations. The most common for online sellers: low-voltage equipment between 50-1000 V AC or 75-1500 V DC (Directive 2014/35/EU, LVD); electromagnetic compatibility (2014/30/EU, EMC); radio equipment including Bluetooth, Wi-Fi and IoT (2014/53/EU, RED); toys (2009/48/EC); machinery (Regulation (EU) 2023/1230 from January 2027); PPE (2016/425); medical devices (2017/745); construction products (305/2011); pressure equipment (2014/68/EU).
The procedure splits by risk module. For self-declaration categories — most LVD, EMC and toys — you prepare a technical file, apply the relevant harmonised EN standards, draft an EU Declaration of Conformity and affix the CE mark. For notified-body categories — pressure equipment, certain machinery, medical devices class IIa upwards, RED on non-harmonised frequencies — a notified body must audit or test first.
A common confusion: CE vs the MAS "China Export" mark with tighter letter spacing. MAS is not a regulatory mark; products bearing only MAS without a valid CE declaration cannot lawfully circulate in the EU. Your supplier producing a CE-stamped product does not transfer compliance to you — as the EU importer or non-EU manufacturer, you are the legal responsible party.
WEEE, batteries and packaging — the three you forget
Extended Producer Responsibility is national, not EU-wide. Each member state runs its own register and collective scheme. Three categories catch most online sellers.
WEEE under Directive 2012/19/EU applies to any product with a plug, battery or electronic component. You must register as a producer in every member state where you place such products, pay an annual fee (typically €25 to €500 base plus a per-tonne or per-unit eco-contribution), and finance take-back. Germany's Stiftung EAR (stiftung-ear.de) issues a WEEE-Reg.-Nr. that Amazon EU verifies before listing. France's UIN issued by ADEME, Spain's RAEE-AP, Italy's RAEE registration via Centro di Coordinamento, and the Netherlands' Nationaal (W)EEE Register all have parallel requirements.
Batteries under Regulation (EU) 2023/1542 — applicable since 18 February 2024; it repealed Directive 2006/66/EC with effect from 18 August 2025, with transitional provisions phasing in to 2027 — imposes a separate producer registration for any product sold with or containing a battery. Thresholds and procedures mirror WEEE.
Packaging under Directive 94/62/EC, soon revised by the Packaging and Packaging Waste Regulation, requires a separate registration for the packaging you place on the market. Germany's LUCID (verpackungsregister.org), France's Citeo, Spain's Ecoembes and Italy's CONAI are the main four. Amazon, Otto and Cdiscount verify LUCID automatically; missing LUCID = no listing. Shipping to all 27 markets means 60-80 separate EPR registrations. Our WEEE producer EU registration helper and packaging EPR fees tool walk the per-country thresholds.
Marketplace-specific obligations 2026
Each marketplace has translated the underlying regulations into different dashboards and field requirements.
Amazon EU runs the Compliance Reference dashboard inside Seller Central under Sales > Compliance. For each ASIN it flags GPSR responsible-person status, EPREL ID for energy-labelled categories, CE declaration for regulated categories, German LUCID, French UIN and EU VAT registration. Non-compliant ASINs are suppressed from search; repeated non-compliance triggers account review.
Shopify added the EU markets compliance module in March 2025. Under Settings > Markets > European Union you provide your business identity, your EU responsible person and product-level compliance metadata that Shopify surfaces in checkout for EU customers. Shopify does not block listings, but generates the GPSR-compliant product page disclosure automatically.
eBay rolled out GPSR listing fields in December 2024. Listings into the EU require an EU Responsible Person attribute; missing values hide the listing from EU buyers. eBay's compliance overview lives at sellerhub.ebay.de/compliance for German accounts, with equivalent paths for FR, IT and ES.
Etsy applies GPSR to physical goods — sellers must designate an EU responsible person and disclose safety warnings. Cdiscount, Otto, Bol.nl, Allegro all run analogous flows: DSA Article 30 business verification, GPSR responsible-person field, EPR numbers in the seller back office.
Marketplaces are no longer fungible. Each wants the same five facts (EU responsible person, EPREL, CE, WEEE/LUCID, VAT) in different slots. The Amazon Compliance Reference guide lists the Amazon mapping.
Continue reading: EPREL registration walk-through · GPSR EU representative requirement · Amazon Compliance Reference decoded
Citations link directly to EUR-Lex, the European Commission, EPREL and the German federal statute portal (gesetze-im-internet.de); regulatory facts re-verified against those sources on 2026-06-12 — see the methodology page for the verification trail.