CE marking

What EU Compliance Do I Need to Sell My Product? (2026 Guide)

Work out which EU obligations apply to your product: a decision tree by product type and sales channel, the nine obligation areas, and where a general guide stops.

Table of Contents

Almost every physical product sold in the EU carries obligations in at least three areas: product safety, packaging, and an economic operator role. Which specific rules apply depends on four things — what the product is, what is inside it, how it is packaged, and how you sell it. Most manufacturers get the first one right and are caught out by the other three.

This guide walks the decision in the order a compliance engineer would, so you finish with a shortlist rather than a vague sense of dread. It also tells you plainly where a general guide stops being useful.

The nine obligation areas

Product compliance is not one requirement. It is nine separate areas, each with its own trigger, and you can be fully compliant in eight and blocked at a border by the ninth.

#Obligation areaTriggered when
1Product safety and CE markingYour product falls under one or more EU harmonisation acts
2Testing and conformity assessmentApplicable standards require evidence; some routes require a Notified Body
3Technical documentation and Declaration of ConformityAlways, for any CE-marked product
4Labelling and user instructionsAlways; language obligations apply per market
5Substance restrictionsElectronics (RoHS), articles containing SVHCs (REACH, SCIP), PFAS
6Extended Producer ResponsibilityElectricals, batteries, textiles placed on a national market
7PackagingAny product that reaches an EU customer in packaging
8Economic operator roleYou are established outside the EU
9Border and market accessCarbon-intensive imports (CBAM), marketplace verification, customs

Step 1: Are you established in the EU?

Answer this first, because it changes who is legally responsible for everything that follows.

If you are established outside the EU and you place products on the EU market, you generally need an EU-based economic operator. In practice this is usually two separate appointments that people confuse constantly:

  • A product-safety Authorised Representative or GPSR Responsible Person, who holds the technical file and answers to market surveillance authorities.
  • An EPR authorised representative in each member state where you have extended producer responsibility obligations, under Article 45 of the packaging regulation and its equivalents for other streams.

One does not cover the other. They are different appointments under different legislation, often in different countries. The difference is explained here.

If you are established in the EU, you carry the manufacturer or importer obligations directly and do not need a representative — but if you import from outside the EU, you inherit manufacturer-level duties as the importer.

Step 2: What is the product?

This determines your CE marking route. Work down this list and note everything that matches, because products routinely fall under several acts at once.

  • Mains-powered or operates between 50–1000V AC: Low Voltage Directive 2014/35/EU
  • Any electrical or electronic product: EMC Directive 2014/30/EU and RoHS Directive 2011/65/EU
  • Contains a radio module — Wi-Fi, Bluetooth, cellular, RFID: Radio Equipment Directive 2014/53/EU. This one is missed more than any other, because the module feels like a component rather than a regulatory trigger.
  • Contains a battery of any kind: Battery Regulation (EU) 2023/1542
  • Has moving parts driven by power: Machinery Regulation (EU) 2023/1230, applying from 20 January 2027
  • Intended for children under 14: Toy Safety Regulation (EU) 2025/2509
  • Protective equipment: PPE Regulation (EU) 2016/425
  • Medical purpose: Medical Devices Regulation (EU) 2017/745 — a substantially heavier regime than anything else on this list
  • None of the above, but a consumer product: General Product Safety Regulation (EU) 2023/988, which applies as a backstop and has been enforced since December 2024

If you matched more than one, that is normal and expected. You issue one Declaration of Conformity listing every act that applies, not one per directive.

Step 3: What is inside it and around it?

Two areas that have nothing to do with whether the product is safe, and stop shipments anyway.

Substances. Electronics need RoHS compliance. Any article containing a Substance of Very High Concern above 0.1% by weight needs a SCIP database notification. PFAS restrictions are tightening across multiple product categories.

Packaging. This is the one almost everyone underestimates. If your product reaches an EU customer in packaging — which it does — you have packaging obligations in every member state where you sell, regardless of what the product is. There is no CE marking involved and no product safety question. PPWR has applied since 12 August 2026.

Sellers of non-regulated goods often conclude they have no EU compliance obligations at all. They almost always have packaging obligations.

Step 4: How do you sell it?

The sales channel changes who is liable and what gets checked, even when the product is identical.

  • Online marketplaces (Amazon, Cdiscount, Bol, Otto). The marketplace verifies your EPR registration numbers before it will let you list, and will suspend listings without them. In practice, marketplaces enforce compliance faster and more bluntly than regulators do.
  • Through an EU distributor or importer. Your EU-based partner takes on importer obligations, but that does not remove your manufacturer duties, and it does not remove your EPR obligations if you are the one placing goods on the market.
  • Direct to consumer from outside the EU. You are the one placing the product on the market. All obligations sit with you, including the economic operator appointments in Step 1.
  • B2B only. The General Product Safety Regulation is consumer-focused, but CE marking, EPR and packaging obligations still apply.

Step 5: What do you import?

If you import cement, iron and steel, aluminium, fertilisers, hydrogen or electricity into the EU, the Carbon Border Adjustment Mechanism applies above a 50-tonne annual threshold. It is unrelated to product safety and is enforced at customs: without Authorised CBAM Declarant status, covered goods do not clear.

A worked example

A manufacturer in Shenzhen makes a Bluetooth speaker with a rechargeable battery, ships it in a printed cardboard box, and sells on Amazon in Germany and France.

  1. Economic operator: not EU-established, so an EU authorised representative for product safety, plus EPR representatives in Germany and France.
  2. CE marking: RED (Bluetooth), EMC, RoHS, Battery Regulation, and LVD if it ships with a mains adapter. One Declaration of Conformity listing all of them.
  3. Documentation: user manual and safety warnings in German and French, plus label specifications including the WEEE crossed-out bin and battery symbols.
  4. EPR: three streams — electricals, batteries and packaging — registered in both countries.
  5. Marketplace: Amazon will demand the EPR registration numbers for both countries before the listing goes live.

Five of the nine areas, two countries, three waste streams. None of it is exotic, and none of it is optional.

Where this guide stops

Being straight about this matters more than sounding comprehensive.

A guide can narrow your obligations to a shortlist. It cannot finish the job, because the final answer depends on your specific bill of materials, your packaging composition by weight and material, your exact target markets, and the conformity assessment route your product type requires. Two speakers that look identical can have different obligations because one has a mains adapter and the other does not.

This guide also does not cover several regimes with their own logic entirely: food contact materials, cosmetics, pharmaceuticals, vehicles and chemicals placed on the market as substances. Medical devices and toys are named above but are substantially heavier than this overview suggests. And national rules sit on top of EU rules in several member states.

If you have read this far and are not certain, that is the correct conclusion to reach — not a failure of the guide.

Frequently asked questions

What EU regulations apply to my product?

It depends on four things: what the product is, what is inside it, how it is packaged, and how you sell it. Most physical products carry obligations in at least three of the nine areas — product safety and CE marking, packaging, and an economic operator role if you are not EU-established. Work through the steps above to reach a shortlist.

Do I need CE marking for my product?

If your product falls under one or more EU harmonisation acts — Low Voltage, EMC, Radio Equipment, Machinery, Toys, PPE, Medical Devices among others — then yes, CE marking is mandatory. If none applies but it is a consumer product, the General Product Safety Regulation applies instead, which does not involve a CE mark but does impose safety and traceability duties.

I only sell packaged goods, no electronics. Do I have EU obligations?

Yes. Packaging obligations apply to anyone placing packaged products on an EU market, per country, regardless of what the product is. This is the most commonly missed obligation among sellers of non-regulated goods.

Does my EU distributor handle compliance for me?

Partly. An EU-based importer or distributor takes on their own obligations, but manufacturer duties remain with you, and extended producer responsibility follows whoever places the goods on the market. Assuming a distributor covers everything is a common and expensive error.

Do I need one Declaration of Conformity per directive?

No. You issue a single Declaration of Conformity listing every applicable act. A product covered by the Radio Equipment Directive, RoHS and the Battery Regulation has one declaration naming all three.

What is the difference between a product-safety authorised representative and an EPR authorised representative?

They are separate appointments under separate legislation. The product-safety representative holds your technical file and answers to market surveillance authorities. The EPR representative registers you with waste schemes in a specific member state. Appointing one does not satisfy the other.

How do I find out exactly what applies to my product?

A product compliance assessment maps every applicable directive, regulation and scheme against your actual product and target markets. EcoComply returns this in 48 hours for a fixed €399, covering all nine obligation areas with a prioritised action plan and a cost estimate.

Get the definitive answer for your product

The steps above will get you to a shortlist. Turning that into a decision requires someone to look at your bill of materials, your packaging and your markets.

A €399 product compliance assessment does that in 48 hours: every applicable obligation across the nine areas, what is currently missing, what it costs to fix, and in what order. It is deliberately priced below the cost of a day of engineering time, because the expensive outcome is not the assessment — it is discovering the gap after your goods have shipped.

See also: what EU compliance actually costs, and the free Declaration of Conformity template.

Frequently Asked Questions

Everything you need to know about EU compliance

No items found.

John Iwueke

Cofounder & CEO EcoComply

John is a seasoned product compliance expert across EU AR, EPR, REACH, RoHS, CSRD. Former compliance lead at Zwilling and Landbell.

Not sure which of the nine areas apply to you?

A guide gets you to a shortlist. An assessment gets you to an answer.

  • All nine obligation areas checked against your product
  • What is missing, in priority order, with costs
  • 48 hours, fixed €399

Launch in the EU without compliance guesswork

Get a clear view of what documents you need, what’s missing, and how to avoid market access blockers, built for electronics & IoT manufacturers.

  • Identify missing CE deliverables (DoC, test reports, technical file)
  • Plausibility checks aligned with market surveillance expectations
  • Expert validation for edge cases