Sellers from Hong Kong, mainland China and the rest of Asia often build the EU business case first and look at compliance later. In practice the order should be reversed. Several EU rules determine whether a product can be sold at all, who must be named on it, and what it costs to land. They belong in the first spreadsheet, not the last.
1. Product safety: a responsible person inside the EU
The General Product Safety Regulation, Regulation (EU) 2023/988, has applied since 13 December 2024 and replaced the earlier General Product Safety Directive. A central requirement for non-EU sellers is that a product covered by the regulation needs an economic operator established in the EU who is responsible for it, and that operator’s details must appear on the product, its packaging, the parcel or an accompanying document. Online marketplaces have their own duties, including a single point of contact for market surveillance authorities and cooperation on recalls.
Business-case impact: the cost of an EU responsible person or importer, updated labels and listings, and the documentation needed to answer an authority’s request.
2. VAT: no exemption for low-value imports
Since 1 July 2021 the EU’s e-commerce VAT rules have removed the VAT exemption for imported goods worth up to €22. VAT is due on all imports, and an import declaration is required regardless of value. For consignments with an intrinsic value up to €150, sellers and marketplaces can use the Import One-Stop Shop (IOSS) to declare and pay VAT.
Business-case impact: prices must be modelled VAT-inclusive for consumers in each destination country, and the choice between IOSS, local stock with VAT registration, or marketplace collection changes both cash flow and administration.
3. Customs duty on low-value parcels: changing now
Low-value consignments have also benefited from a customs duty exemption up to €150. In November 2025 EU Member States agreed to remove that threshold, with application brought forward to 2026, and in December 2025 the Council decided on a temporary fixed duty on low-value consignments from July 2026, ahead of a fuller reform. An e-commerce handling fee has also been under discussion.
Business-case impact: duty can no longer be assumed to be zero for small parcels sent directly to consumers. Compare direct shipping with bulk import into an EU warehouse, where duty is paid once on the consignment and products ship locally.
4. Packaging: producer responsibility country by country
Packaging rules are set nationally. In Germany, for example, sellers who place packaged goods on the market must be registered in the LUCID packaging register and take part in a recycling scheme before the goods are made available, and online marketplaces must check that registration before allowing the products to be offered. France, Spain and other countries run their own producer-responsibility systems with separate registrations.
Business-case impact: registration and scheme fees for each country, packaging data by material and weight, and lead time before the first sale.
The order we check
| Step | Question | If the answer is no |
|---|---|---|
| 1 | Is the product allowed, and can we document its safety? | Stop or redesign before any market work. |
| 2 | Who is our EU responsible person? | Budget for a service provider or importer. |
| 3 | Direct parcels or bulk import? | Model both: VAT route, duty and delivery time. |
| 4 | Which countries first, given packaging registrations? | Start with fewer countries. |
| 5 | What is the contribution margin after all of the above? | Do not launch until it is positive. |
Takeaway. In the EU, compliance is not an overhead added after the business case. It changes the landed cost, the route to market and the launch date, so it belongs in the first model.
Sources (checked 11 October 2026). Baker McKenzie: General Product Safety Regulation (EU) 2023/988 · European Commission: customs formalities for low-value consignments · European Commission: €150 customs duty threshold to be removed in 2026 (13 November 2025) · Baker McKenzie: EU €150 customs duty exemption to end in 2026 · Stiftung Zentrale Stelle Verpackungsregister: mail-order companies and online retailers
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