What are my obligations if I import products from China?

Importing from China usually places you in the importer role

Whoever first places products from China on the EU market is considered an importer under the GPSR, and that role carries its own set of obligations. The importer verifies that the manufacturer outside the EU has drawn up the required technical documentation and risk assessment, checks whether the product bears the required markings and instructions, and ensures that warnings appear in the consumer's language on the product page. Contact details must also appear on the product or packaging so that a supervisory authority can reach the importer, and traceability records must be maintained. Because imports from China typically involve no manufacturer within the EU, the importer fulfils the first link in the chain of responsibility that the regulation requires — without that link, a product may not be offered.

There is an exception that many entrepreneurs overlook: whoever sells the purchased product under their own name or brand — even if that is only their own logo on a ready-made product, or if the product has been substantially modified — is not considered an importer but a manufacturer, with the more stringent obligations that entails, such as drawing up the risk assessment and technical documentation themselves. A distributor, who resells a product unchanged without being the first to import it into the EU, carries a lighter role: they do not need to verify the manufacturer's obligations, but they do check whether the importer or manufacturer has done their part.

Basis: Article 11 and the manufacturer provisions

The importer's obligations are set out in Article 11 of Regulation (EU) 2023/988; those who instead qualify as a manufacturer fall under the manufacturer provisions of the same regulation. The language requirement for warnings varies by country: in the Netherlands it is Dutch, in Germany German, in Belgium Dutch, French or German depending on the language area being served. Traceability records and technical documentation must be kept for six years.