Why is customs blocking my shipment without a responsible person?

Without a designated responsible party, a product cannot be placed on the market

Customs is holding a shipment because no one is designated as responsible for the product within the European Union — and that is not a missing piece of paperwork to be sent later, but a prerequisite for being allowed to offer the product here at all. GPSR establishes a fixed order for this: first the EU manufacturer, if that does not exist then the importer, if that does not exist then an authorized representative, and only if none of these three can be identified does the role fall to the fulfilment service provider. Without a name and address from that chain on the shipment or accompanying documents, customs cannot determine who is accountable if something goes wrong — and that is precisely what is being checked.

Who often ends up here unexpectedly is the online retailer that purchases from a factory outside the EU and has its own name or logo placed on it. That party is itself considered a manufacturer under the regulation, even if no production activity has been carried out — and thus bears the associated obligations, including the ability to designate a responsible market participant. A distributor — who purchases and resells without having their own brand placed on it — does not need to take on this role; that obligation lies with the preceding links in the chain. A fulfilment service provider who cannot demonstrate which party in the chain actually fulfils that role becomes responsible themselves under the cascade.

What this is based on: Article 16 GPSR

Article 16 of Regulation (EU) 2023/988 determines that a product may not be placed on the market without a market participant designated as responsible within the Union. That article is the basis for the border blockade: customs does not assess the quality of the product itself, but whether this designation is present and traceable.