Selling physical products into the EU from outside: GPSR responsible person, EPR, LUCID and packaging

If you sell physical consumer products to people in the EU from outside it, you need three things in place: an economic operator established in the EU who is responsible for each product, that person's details (and yours) on the product or parcel and in your listing, and packaging registration in each EU country you sell into. The product safety rules have applied since 13 December 2024 under the General Product Safety Regulation (GPSR). The EU packaging regulation has applied since 12 August 2026, and in Germany that means the LUCID register. Northern Ireland follows the EU safety rules; Great Britain doesn't.

Everything here comes from the regulations themselves, the German register, GOV.UK and Etsy, checked on 28 October 2026. Product-specific laws such as toys or electronics add more on top.

What applies when (checked 28 Oct 2026)

The GPSR responsible person

The core rule is in Article 16(1) of the GPSR: a product "shall not be placed on the market unless there is an economic operator established in the Union who is responsible" for certain tasks. The GPSR covers products intended for consumers, or likely to be used by them, so this catches most things sold in an online store.

You're caught even if you never ship stock to a European warehouse. The market surveillance regulation says an online offer counts as targeted at EU end users "if the relevant economic operator directs, by any means, its activities to a Member State." If your store ships to EU addresses, plan as if that test catches you.

Who can be your responsible person

Article 16 borrows the list from Article 4(2) of Regulation (EU) 2019/1020. The responsible person can be:

• a manufacturer established in the EU;
• an importer, where the manufacturer isn't established in the EU;
• an authorised representative "who has a written mandate from the manufacturer";
• an EU fulfilment service provider, for the products it handles, but only where none of the others is established in the EU.

If you ship direct from outside the EU, that usually means an authorised representative you appoint in writing.

What they actually do

The responsible person has to check that your technical documentation exists and can be handed to authorities on request, answer reasoned requests from market surveillance authorities, tell authorities when they have reason to believe a product presents a risk, and cooperate on recalls and fixes. Article 16(2) adds that they must "regularly check" the product against your technical documentation and labelling, and give documented evidence of those checks when asked. If the manufacturer is outside the EU, Article 20(4) makes them responsible for making sure a serious accident is notified through the Safety Business Gateway.

We didn't find a published price for this service on any primary page we opened, so we haven't quoted one. Get written quotes and check what they'll actually do.

What goes on the product

Three sets of details have to travel with the product:

• Your details as manufacturer: name, registered trade name or trade mark, and postal and email address, on the product or, if that's not possible, on the packaging or an accompanying document (Article 9(6)).
• The responsible person's details: name, registered trade name or trade mark, and contact details including postal and email address, on the product, its packaging, the parcel or an accompanying document (Article 16(3)).
• A type, batch or serial number that consumers can see and read (Article 9(5)), plus clear instructions and safety information in a language consumers in that country can easily understand (Article 9(7)).

Keep your technical documentation for 10 years after the product goes on the market (Article 9(3)).

What your listing has to show

Article 19 applies to anyone selling online. Each offer must "clearly and visibly" show at least:

1. The manufacturer's name, registered trade name or trade mark, and postal and email address.
2. Where the manufacturer isn't established in the EU, the responsible person's name and postal and email address.
3. Information that identifies the product, "including a picture of it, its type and any other product identifier".
4. Any warning or safety information, in a language consumers in that country can easily understand.

Marketplaces have their own duties under Article 22. They must build their listing forms so traders can enter that information for each product, and they must suspend traders "that frequently offer products which are non-compliant", after a prior warning. When an authority orders a dangerous listing down, the marketplace must act within two working days. So expect marketplaces to ask for these fields and to hide listings that don't have them.

What Etsy and Amazon say

Etsy's help page says products "can't be placed on the EU market unless they have an EU-based" economic operator, and asks you to add an Economic Operator to your account, fill in the Manufacturers field and add "Product safety info" to your listings. It names two providers, Cert-Rep and International Associates, without prices. You can also opt out: in Shop Manager, go to Settings, then Options, and once you opt out, "buyers in EEA States and Northern Ireland won't be able to purchase items from your shop."

We couldn't open Amazon's own GPSR help pages on 28 October 2026, because Seller Central help sits behind a seller login, so we haven't quoted Amazon's rules. Check the compliance section in your own Seller Central account before you list in an EU store.

Packaging: EPR, LUCID and the PPWR

Packaging is a separate regime with separate registrations. Under extended producer responsibility (EPR), producers pay towards collecting and recycling the packaging they put on a country's market.

The EU packaging regulation

Regulation (EU) 2025/40 has applied since 12 August 2026. Its definition of producer includes a manufacturer, importer or distributor "established in a Member State or in a third country" that makes packaged products available for the first time in another Member State "directly to end users". In plain terms, if you ship orders from outside the EU straight to customers, you're the producer.

What that means:

• Register in each country you sell into. Article 44 says producers register in each Member State where they first make packaged products available, and can't sell there until they (or their authorised representative) are registered. Registers may charge "cost-based and proportionate fees".
• Report each year. Producers report packaging data "by 1 June for each full preceding calendar year", with a different set of information if you put less than 10 tonnes on that market in a year.
• Check each country's current process. Article 44(1) gives each Member State 18 months from the Commission's first implementing act to set up its national register, so the route can differ by country for now.
• Appoint an authorised representative where required. Article 45(3) says producers selling directly to end users in another Member State "shall appoint, by written mandate, an authorised representative for the extended producer responsibility" there, and lets each Member State require one from producers established in third countries.
• Expect platforms and 3PLs to check. Online platforms must get your registration number and a self-certification before letting you sell packaged products to EU consumers, and fulfilment service providers must suspend service if your information isn't corrected (Article 45(4) to (8)).

Germany's LUCID register

Germany is where the register is easiest to see. The ZSVR's home page says: "If you are distributing packaged goods in Germany, you have to be registered with the LUCID Packaging Register." Its first-steps menu links a page called "I want to know what changed on 12 August 2026". That page says the PPWR and a new national act "replaced the existing German Verpackungsgesetz (Packaging Act)", while the basic duties of registration, system participation and data reporting remain.

For a foreign online seller, the ZSVR's knowledge base says:

• Register yourself. Registration "remains the manufacturer's personal responsibility", and your authorised representative can't do it for you.
• Join a system for shipping packaging. "Packaging intended for shipment is always subject to system participation, without exception." That means a contract with a system operator to fund recycling.
• Appoint an authorised representative. Foreign companies selling directly to end users in Germany with no German branch must appoint one from 12 August 2026. The ZSVR's representative page says it can be "any natural or legal person with a registered office or branch in Germany", with a written agreement in German, and you can appoint only one.
• Expect checks. Platforms must get confirmation that you're registered in LUCID and a self-certification, or "the packaged products may not be offered on the online platform", and a fulfilment service provider "is required to stop providing services to you" if you don't respond in time.

Other EU countries run their own registers. We've only covered Germany's here.

Great Britain vs Northern Ireland

The UK is split. GOV.UK says the EU GPSR "superseded the General Product Safety Regulations 2005 in NI on 13 December 2024", while "The General Product Safety Regulations 2005 continue to apply in Great Britain."

For Northern Ireland, the detailed guidance says you need a responsible economic operator "established in either NI or the EU". Being established means having a presence there, and a PO Box isn't enough. The useful part: "A single responsible economic operator can be used for supply of products in both the EU and NI." Etsy's opt-out also groups Northern Ireland with the EEA.

For Great Britain, the 2005 regulations require consumer products to be safe in normal or reasonably foreseeable use. The same guidance says the EU GPSR "does not apply to products being placed on, or made available to, the GB market", and goods that can be sold in NI can be sold across the rest of the UK. We haven't covered UK packaging EPR here.

Common mistakes

• Thinking a marketplace makes you exempt. The marketplace has its own duties, but the responsible person, the product labels and the listing details are still on you.
• Naming a UK or US company as your responsible person. The role needs an operator established in the EU (or, for NI, in the EU or NI).
• Using a PO Box or a virtual address. GOV.UK's guidance says a PO Box doesn't count as being established.
• Expecting your German representative to register you in LUCID. The ZSVR says registration is your own duty.
• Forgetting shipping cartons. They're packaging too, and in Germany they always need system participation.
• Designing new packaging to the old rules. Labelling and empty space rules start between 2028 and 2030, so new packaging you design today should plan for them.

Checklist

1. List every EU country you ship to, plus Northern Ireland if you sell to the UK.
2. Appoint an EU responsible person by written mandate, or confirm your EU importer or EU fulfilment provider takes the role, and keep the mandate.
3. Add your details, the responsible person's details and a type, batch or serial number to each product, its packaging, the parcel or an insert, with safety information in each country's language.
4. Update every EU listing with the four Article 19 items, and fill in Etsy's or Amazon's compliance fields.
5. Keep technical documentation for each product, with a dated risk analysis, for at least 10 years.
6. If you ship to Germany, register in LUCID yourself, sign a system participation contract, and appoint a German authorised representative.
7. Check the packaging register in each other EU country you sell into.
8. Put the 2028 and 2030 packaging dates in your calendar and review your packaging designs against them.

Where to go next

If you're also selling to American customers, read shipping to the US after de minimis, then sales tax and VAT for online stores, because VAT is a separate registration again. If you'd rather hold stock in Europe, our guide to choosing a 3PL covers what to ask a warehouse, and selling on Amazon as a non-US resident covers the marketplace side. If you'd like to compare notes with other founders shipping products across borders, you can join Remote Builders: it's free, and you're in straight away.