En vpis, 27 držav: Ali je sploh mogoča resnična skladnost z vseevropsko zakonodajo?
Uvod
Every cross-border seller knows the pitch. You build one product page, translate it a few times, send one shipment to a European warehouse, and suddenly you are open for business in a market of roughly 450 million consumers. The EU calls itself a single market, so it is natural to assume that a product legally sold in one member state can be sold in all twenty-seven with the same paperwork, the same label and the same shipping process.
In 2026 that assumption has become expensive. The General Product Safety Regulation has now been applicable for almost two years, and regulators are using the powers it gave them. The €150 duty exemption for low-value parcels ended on 1 July 2026. The Packaging and Packaging Waste Regulation began applying on 12 August 2026, and sellers are discovering that a regulation written for the whole union is still administered through national registers with national waiting times. A single listing now sits at the crossing point of product safety law, customs law, VAT law and environmental law, and each of those layers behaves differently once it meets a real border.
So is true pan-EU compliance even possible? Our answer, after looking at the latest rules and at how they play out in practice, is a qualified yes. It is possible to build a compliance model that covers the whole union, but it is not possible to buy it as a single certificate or solve it with a single appointment. This article breaks the problem into layers, shows which layers are genuinely harmonised and which are not, and explains where logistics decisions, which is the territory of a freight forwarder, can make compliance cheaper or considerably more painful.
The Short Answer: One Rulebook, Twenty-Seven Execution Layers
The most useful way to think about EU compliance is to separate the law from its execution. The law is increasingly harmonised. Regulation (EU) 2023/988, known as the GPSR, is a regulation rather than a directive, which means it applies directly and identically in every member state without national transposition. The customs reform and the packaging regulation follow the same pattern. On paper, this is the single rulebook that sellers have always wanted.
Execution is another matter. Fines are set nationally. Registers are run nationally. Language requirements for consumer information are set nationally. Customs authorities in each country process parcels with different levels of staffing, and some governments have layered their own small-parcel charges on top of the EU-level measures. That is why a seller can be fully compliant in Germany, trip over a registration requirement in Poland, and be hit by a national levy in France in the same week, all for one listing.
The table below summarises how the main layers compare. It is a simplified map, but it shows where the single market is real and where it still stops at the national border.
| Plast skladnosti | Harmonised at EU level? | Where it still varies by country |
| Product safety (GPSR) | Yes, one directly applicable regulation | Penalty levels, inspection priorities, language of safety information |
| Customs duty on low-value goods | Yes, €3 flat duty from 1 July 2026 | National small-parcel fees and taxes; capacity of local customs |
| DDV pri uvozu | Largely, through IOSS and OSS | Local VAT registrations if stock is held in-country |
| Packaging and EPR (PPWR) | Rules yes, administration no | National producer registers, waiting times, one authorised representative per country |
| Electrical, battery and other product-specific rules | Mostly, via sector legislation | National registers and local take-back arrangements |
| Izvrševanje in kazni | Ne | Each member state sets its own fines and procedures |
The pattern is that anything built on data and identity, such as product records, technical files and tariff classifications, can be built once and reused everywhere. Anything built on local administration, such as registers, waiting times and enforcement priorities, must be handled country by country. Pan-EU compliance therefore means centralising the first group and managing the second group deliberately.
Layer One: Product Safety Under the GPSR
What the Regulation Actually Requires
The GPSR is the baseline safety law for non-food consumer products. It applies where no product-specific EU rule, such as the toy, low-voltage or machinery legislation, already covers the same risk, and it works as a safety net underneath that sectoral law. Since 13 December 2024 it has replaced the old General Product Safety Directive, and it widened the circle of responsible parties to include manufacturers, importers, distributors, fulfilment service providers and online marketplaces.
For sellers outside the EU, the pivotal requirement is that every product must have an economic operator established in the union who answers for it. That can be the manufacturer, an importer or an authorised representative. Importers carry their own duties under Article 11: they may not place a product on the market if they know or should know that it fails the general safety requirement, and they must keep documentation and notify the authorities when a dangerous product is found. Marketplaces have separate obligations under Article 22, including a single point of kontakt, registration with the Safety Gate system and cooperation with authorities on dangerous products and recalls.
| vloga | Core duty under the GPSR |
| Proizvajalec | Safety assessment, technical documentation, labelling with name and address, accident reporting and recalls |
| uvoz | Verify the manufacturer has done its work, keep documentation available, show its own name and address, notify authorities of dangerous products |
| Authorised representative or EU responsible person | Act as the established contact point for authorities and hold the technical file |
| Distributer | Check that required labelling and information are present before supplying the product |
| Ponudnik storitev izpolnjevanja naročil | Cooperate with authorities and avoid handling products it knows to be unsafe where no other operator exists |
| Spletna tržnica | Single point of contact, Safety Gate registration, listing fields for safety data, prompt action on notices |
What Your Listing Must Show
The GPSR moved product safety out of the warehouse and onto the product page. Online offers must display the manufacturer’s identification and contact details, a product identifier such as a model, type or batch reference, details of the EU responsible person, and any safety warnings in a language that consumers in the destination country can easily understand. The same information is expected on the product or its packaging wherever that is possible. A mismatch between what the listing says and what the physical label says is one of the simplest ways for an inspector to prove a problem.
Marketplaces have turned these requirements into mandatory fields. In the first phase, platforms mostly checked whether a listing had a valid EU responsible person on file. Legal trackers now report that the focus has widened to the underlying evidence: technical documentation, risk assessments and the labelling on the physical product. Authorities are also increasingly asking sellers for those documents directly rather than relying on marketplace-level checks.
The practical consequence is that a compliance setup built in late 2024 may no longer be enough. A responsible person who exists on paper but cannot produce a technical file within days is a weak point, and so is a label that was printed in one language for a product now sold in five countries.
Penalties Are National
Because the GPSR leaves penalties to member states, the cost of a breach depends on who finds it first. Italy has circulated a draft decree with penalty tiers running from administrative fines for formal violations up to criminal sanctions for placing dangerous products on the market, and Bulgaria amended its Consumer Protection Act in February 2026 to add its own penalty tier. In practice, the outcome of a failed check in 2026 is often a delisted product plus a national fine. That uneven risk is the first place where the dream of one compliance posture meets reality.
Layer Two: Customs, Duties and VAT
The €3 Duty and How It Is Counted
From 1 July 2026 the EU abolished the duty exemption for e-commerce parcels worth less than €150 and replaced it with a temporary flat customs duty of €3 per item, assessed by tariff category, on goods ordered from non-EU countries and shipped directly to consumers. The Commission says about 5.9 billion low-value items entered the EU in 2025, four times the 2022 volume, and EU estimates suggest the measure captures around 93 percent of e-commerce parcels. The flat duty is meant to run until 2028, when the EU Customs Data Hub is scheduled to go live and standard tariff rates based on classification, origin and value take over.
How the charge is counted matters more than the headline. Trade sources describe it as €3 per item type by customs code within a parcel, so a parcel containing three identical phone cases is treated differently from a parcel containing a phone case, a charger and a cable. The table below shows how the arithmetic can run in common scenarios. These are illustrations based on published guidance, and sellers should confirm the treatment of each declaration with their customs broker.
| Scenarij | Tariff lines | Indicative customs treatment |
| One LED lamp worth €18, sent as a direct parcel | 1 | €3 flat duty, about 17 percent of the item value |
| Three identical kitchen tools worth €9 each, one parcel | 1 | €3 flat duty, about 11 percent of the order value |
| Phone case, charger and cable in one parcel | 3 | €9 flat duty, because three separate customs codes are involved |
| One item worth €200, direct to consumer | 1 | Above €150, so standard tariff rate applies rather than the flat duty |
| Twenty cartons shipped to an EU fulfilment hub in an FCL or LCL consignment | Različno | Standard import declaration, duty at tariff rates, VAT at import |
For a five-euro accessory, a €3 duty is a margin event, not a rounding error. The sellers hurt most are those with low-ticket, single-unit parcels, while sellers with higher order values or consolidated inventory feel it less. This is why the question of how goods enter the EU has become a compliance question as much as a cost question.
The Handling Fee, National Levies and Product Identifiers
A separate €2 Union handling fee on small parcels is due from 1 November 2026, intended to cover customs authorities’ rising processing costs. It should not be confused with the €3 duty, because one is a customs duty and the other is a fee. Some countries did not wait for it. Romania was the first member state to introduce a national fee, Italy introduced a €2 charge on 1 January 2026, and France began applying a small-parcels tax of €2 per item category from 1 March 2026. How these national charges will sit alongside the Union fee is something sellers should watch closely rather than assume.
Product identifiers are the third piece of the puzzle. Sellers have been encouraged to supply them since 1 July to help customs target unsafe goods, and the requirement becomes mandatory in November 2026. This is where customs and product safety quietly merge. The same product record that proves identity on a GPSR-compliant listing becomes the data customs uses to decide whether a parcel is waved through or held. Sloppy product data now produces both safety problems and clearance problems.
| Datum | Ukrep | Kdo to čuti |
| 13 december 2024 | GPSR becomes applicable | All sellers of non-food consumer products |
| 1 januar 2026 | Italy applies a €2 fee on low-value parcels | Parcels destined for Italy |
| 1 marca 2026 | France applies a €2 small-parcels tax per item category | Parcels destined for France |
| 26 marca 2026 | Parliament and Council agree the wider customs reform | Vsi uvozniki |
| 1 julij 2026 | €3 flat duty on items up to €150; product identifiers encouraged | Direct-to-consumer parcels |
| 12 avgust 2026 | PPWR applies, including the authorised representative rule | Sellers of packaged goods |
| November 1 2026 | €2 Union handling fee; product identifiers mandatory | Small parcels entering the EU |
| 1 julij 2028 | EU Customs Data Hub live; standard tariffs replace the flat duty | Uvoz iz e-trgovine |
VAT: The Quiet Constant
VAT is the layer that has been harmonised the longest. Since July 2021 VAT has applied to all business-to-consumer imports, and the Import One-Stop Shop lets sellers collect VAT at the point of sale on consignments up to €150 and report it through a single registration. The scheme covers VAT only, so it does not make the €3 duty disappear. Sellers who keep inventory in EU warehouses use different mechanics, including local VAT registrations in the countries where the stock physically sits. Of all the layers, this is the one where a single registration genuinely goes a long way, though it still does not cover every sales model.
Layer Three: Packaging and EPR Under the PPWR
If the GPSR was the compliance story of 2024 and the customs reform the story of mid-2026, the packaging regulation is the story of this autumn. Regulation (EU) 2025/40 entered into force in February 2025 and has applied since 12 August 2026. It replaces the old Packaging Directive with directly applicable rules that cover packaging across its life cycle, and it carries extended producer responsibility into a single regulation instead of leaving it to twenty-seven national transpositions.
The part that matters most for cross-border sellers is the authorised representative. Under Article 45(3), anyone who supplies packaging or packaged goods directly to end users in an EU country where they are not established must appoint an authorised representative there, and the appointment is made separately for each country. The Commission has proposed suspending that requirement until 2035 for producers established inside the union, but the proposal was not adopted as of the latest reports, and non-EU producers were deliberately left out of the relief.
Registration and representation are two different obligations, and sellers regularly confuse them. Registration with a national producer register falls under Article 44, while the authorised representative duty sits in Article 45(3). A pay-on-behalf arrangement does not replace registration, and an EPR service provider is not automatically your authorised representative. The table below sets the two side by side.
| Vprašanje | Producer registration | Pooblaščeni zastopnik |
| Pravna podlaga | Člen 44 PPWR | Article 45(3) of the PPWR |
| Kaj počne | Places the producer on the national register and sets up EPR reporting and fees | Gives a non-established seller a legal presence to carry out EPR duties |
| področje uporabe | National, one register per country | One representative per country of supply |
| Pogosta napaka | Assuming the marketplace has already registered you | Assuming the EPR provider doubles as your representative |
Execution is where the single-market promise frays again. Service providers reported that in Italy the packaging register had not opened at all in August, that sellers in Poland were facing a wait of around six months for a number in the BDO system, and that in the Netherlands a major scheme had paused registrations from non-EU entities. Marketplaces have not carried out mass delistings so far, but platforms are expected to obtain evidence of producers’ EPR compliance, and sellers who treat the lack of immediate enforcement as permission to wait are taking an unnecessary risk.
The regulation also tightens what goes into the packaging. Limits of 100 mg/kg for lead, cadmium, mercury and hexavalent chromium, and restrictions on PFAS in food-contact packaging, apply alongside documentation duties. For a seller shipping the same carton to ten countries, this means the packaging specification is no longer a purely operational detail. It is part of the compliance file.
The Local Details Nobody Harmonised
Even when the big layers line up, a long tail of national details remains. Language is the clearest example. Safety warnings and instructions must be understandable to consumers where the product is sold, which in practice means local-language versions for each destination market. A multi-country label can sometimes carry several languages, but space on small products is limited, and a listing that is correct in English but not in Polish or Italian is a weak listing.
Product-specific regimes add further layers. Electrical goods bring waste electrical equipment obligations and radio-equipment cybersecurity requirements, batteries have their own regulation with phased obligations, and many countries run separate registers for these streams. None of these is a GPSR issue, but all of them can stop a listing, and each tends to be administered nationally.
| Država | Development reported in 2026 | Why it matters to a pan-EU seller |
| Italija | €2 fee on low-value parcels from 1 January; draft GPSR penalty decree; packaging register not open in August | Higher landed cost and uncertain EPR registration |
| Francija | Small-parcels tax of €2 per item category from 1 March | Per-category charge rewards consolidation and clean tariff data |
| Romunija | First member state to introduce a national low-value parcel fee | Early example of national charges layered over EU rules |
| Bolgarija | Consumer Protection Act amended in February to add a GPSR penalty tier | Fines differ from neighbouring markets |
| Poljska | Reported waits of around six months for BDO packaging numbers | Registration lead times must be planned before launch |
| Nizozemska | A major packaging scheme reported pausing non-EU registrations | Access to registration can depend on scheme policy |
The details in this table will change, and some may already have shifted by the time you read this. That is precisely the point. A pan-EU compliance model has to assume that the national layer moves and give someone the job of watching it.
So, Is True Pan-EU Compliance Possible? A Practical Framework
Yes, if you stop treating compliance as one task and start treating it as a three-tier structure. The first tier is built once for the whole union, the second is built country by country as you enter each market, and the third lives at the level of the individual SKU and the individual shipment. Sellers who struggle usually try to solve all three with one tool, one provider or one spreadsheet.
| Tier | Kaj vsebuje | How often it changes |
| Core (build once) | Technical files, safety assessments, tariff classification, product identifiers, packaging specifications, EU responsible person | Rarely, when the product changes |
| Country (build per market) | Producer registers, authorised representatives, local VAT where needed, local-language information, national fee handling | Often, as national rules move |
| Shipment (check every time) | Label matches listing, correct customs codes, valid identifiers, correct entry route | Every consignment |
Build the Core Once
The core tier is where centralisation pays off. A single, well-maintained product record that holds the technical file reference, the tariff code, the product identifier, the packaging weights and materials, and the responsible person details feeds every other tier. When that record is wrong, the error is copied into listings, customs declarations and packaging reports at the same time.
Register Where You Sell, Not Where You Could Sell
Twenty-seven registrations on day one is neither necessary nor sensible. Most sellers should pick a first wave of markets based on demand, then check each one for fee exposure, registration lead times and local-language requirements before committing stock. Larger markets such as Germany, France, Italy, Spain, the Netherlands and Poland are common starting points, but the reported registration delays in Italy and Poland show why lead times belong in the decision alongside sales forecasts. A smaller footprint that is fully compliant beats a wide one that is exposed.
Marketplace settings help here. Restricting delivery to markets where your documentation is complete is far cheaper than discovering a gap after a regulator or platform does.
Choose the Entry Route Deliberately
The entry route decides which customs rules apply. Direct-to-consumer parcels fall under the new €3 duty and the handling fee, while consolidated stock shipped to an EU fulfilment hub is cleared through a standard import declaration, with duty based on tariff rates and VAT paid at import. Neither is universally better. Direct shipping keeps inventory risk low, and bulk shipping brings costs and compliance tasks forward into a single event that is easier to control.
| Model | Carinska obravnava | Compliance profile | Najbolj primeren za |
| Direct parcels from China to consumers | Flat €3 duty, €2 handling fee, national levies, IOSS for VAT | Per-parcel exposure, heavy dependence on data quality at dispatch | Test products and very long-tail catalogues |
| Bulk shipment to an EU warehouse (FCL or LCL) | Standard declaration, tariff-based duty, VAT at import | Compliance concentrated in one import event, local VAT registration likely | Proven sellers with predictable demand |
| Hybrid | Bulk for best sellers, direct for the long tail | Two sets of procedures to maintain | Growing catalogues with a clear top tier |
Treat the SKU as the Unit of Compliance
Compliance failures rarely happen at company level. They happen at the product level, when a particular model ships with an outdated label, when a variant has the wrong tariff code, or when a new carton design changes the packaging weight. Managing compliance by SKU, with an owner and a review trigger for every change in product, packaging or destination, turns a vague worry into a checklist someone can actually finish.
Where the Freight Forwarder Fits In: Topway Shipping
Freight forwarders do not issue safety certificates or appoint authorised representatives, and a seller should be wary of any forwarder that claims otherwise. What a forwarder controls is the physical and documentary path of the goods, and that path is where most compliance mistakes become visible, whether through a held container, a rejected parcel or a failed inspection.
Topway Shipping has worked in this space since 2010. Headquartered in Shenzhen, China, the company provides cross-border e-commerce logistics solutions, and its founding team brings more than 15 years of experience in international logistics and customs clearance, with a particular focus on China to U.S. transportation. That background in a heavily scrutinised trade lane is relevant to Europe, because the discipline that US customs clearance demands, namely accurate descriptions, consistent classification and documents that match the cargo, is exactly what the EU’s new low-value regime now rewards.
The service range follows the whole logistics chain: first-leg transportation, overseas skladiščenje, customs clearance and last-mile delivery. Topway also offers flexible full-container-load and less-than-container-load ocean freight from China to major ports worldwide. For a seller facing the choices described above, that range matters in practical ways. Moving best-selling SKUs by FCL or LCL to a regional warehouse shifts them out of the per-parcel regime and into a single, planned import. Warehousing gives a point where labels, language versions and packaging can be checked against the listing before goods reach a consumer. Customs clearance expertise helps keep tariff codes and declared values consistent from one shipment to the next.
The working relationship is straightforward. The seller or its compliance partner supplies the product data, the technical file and the EPR arrangements, and the forwarder builds shipments, documentation and delivery around that data. Sellers planning their EU routes can discuss lane options, container or consolidation choices and clearance requirements with Topway Shipping before the first booking rather than after the first problem.
90-dnevni akcijski načrt
With the handling fee and mandatory product identifiers due on 1 November, the next three months are crowded. The plan below is deliberately sequenced so that the cheapest, highest-leverage work comes first.
| Časovni okvir | Ukrep | Rezultat |
| 1. do 14. dan | Audit every active SKU for responsible person, label content, tariff code and product identifier | A clean product record and a list of gaps |
| 1. do 14. dan | Pull sales by destination country and parcel value | Evidence for choosing priority markets and entry routes |
| 15. do 30. dan | Model landed cost with the €3 duty, the €2 handling fee and national levies | Updated pricing and a view on which SKUs to consolidate |
| 15. do 45. dan | Appoint authorised representatives and start producer registrations in priority countries | Registrations in progress before lead times bite |
| 30. do 60. dan | Update local-language information and check physical labels against listings | Matching labels, listings and technical files |
| 45. do 90. dan | Move proven SKUs to bulk shipping to an EU warehouse where the numbers support it | Lower duty exposure and a controlled import event |
| V teku | Assign an owner to watch national rule changes monthly | Early warning instead of surprise penalties |
zaključek
True pan-EU compliance is possible, but not in the form most sellers imagine. There is no single act that makes a listing compliant in twenty-seven countries. There is a core that can be built once, a country layer that must be assembled market by market, and a shipment layer that has to be right every time. The EU has genuinely harmonised the rules, but it has not harmonised the registers, the penalties, the waiting times or the national charges that sit on top of them.
The sellers who will cope best in the coming year are the ones who treat data as the foundation, enter markets in waves instead of all at once, and choose their entry route with both cost and compliance in mind. The €3 duty, the Union handling fee and the packaging regulation all push in the same direction: toward accurate product records, consolidated imports and clear accountability inside the union.
If you are rethinking how your goods reach European customers, Topway Shipping can help you plan the logistics side, from first-leg transport and FCL or LCL ocean freight to overseas warehousing, customs clearance and last-mile delivery, so that your compliance work and your freight plan support each other.
Pogosta vprašanja
Q: Does the €3 duty apply to stock I ship in bulk to an EU warehouse?
A: The flat duty is aimed at low-value e-commerce items ordered from outside the EU and shipped directly to consumers. Bulk stock shipped to a warehouse is cleared through a standard import declaration with duty based on the tariff, so it is treated differently. Confirm the details of your own consignments with your customs broker.
Q: Is one EU responsible person enough for the whole union under the GPSR?
A: Under the GPSR, one economic operator established in the union can act as the responsible person for a product across the market. The packaging regulation works differently, because it requires a separate authorised representative in each country where you supply end users and are not established.
Q: Can I rely on Amazon or another marketplace to handle my EPR obligations?
A: No. Marketplaces are expected to check evidence of compliance, but registration and representation remain the producer’s responsibility. Being listed on a platform does not transfer those duties.
Q: Which markets should I enter first?
A: Choose based on demand, then test each candidate for fee exposure, registration lead times and language requirements. Reported delays in Italy and Poland show why lead times matter as much as sales potential.
Q: What happens if my label and my listing do not match?
A: A mismatch is an easy basis for a market surveillance authority or marketplace to find a problem. Possible outcomes include delisting, product withdrawal and a national fine, and the amount depends on the country that acts first.
