If your business purchases products from outside the EU and then places them on the European market, you are in many cases the importer under GPSR — a role with its own, explicit obligations. You must, among other things, check whether the manufacturer has complied with their part of the rules, whether technical documentation exists, and whether the product carries the required information before you sell it in the EU. Under the older product safety rules, this was less sharply defined; GPSR now establishes the importer role as an independent link in the chain with its own control obligation, separate from the manufacturer.
Whether this changes for your business depends on where your supplier is established. If you purchase from a supplier within the EU, you are generally not an importer, even if the product originally comes from elsewhere. If you source goods directly from a manufacturer or trader outside the EU, the importer role typically rests with you, even if you sell the product under a different brand.
Who GPSR considers an importer
GPSR distinguishes several roles within the supply chain: manufacturer, authorised representative, importer and distributor. The importer is the party that places a product from a non-EU country on the European market for the first time. This can be a wholesaler, but equally a webshop that orders directly from a factory in Asia or the United States and has the shipment sent directly to European customers or stores it here first. The legal qualification depends on the actual role in the supply chain, not on what a business calls itself on the invoice.
This affects a group of entrepreneurs who often do not see themselves as importers: anyone who orders directly from a manufacturer outside the EU via a platform and has goods shipped to their own warehouse or to a fulfilment partner may in fact be acting as the first party in the EU. If you are unsure whether this role applies to your business, you can have that clarified in a few questions.
What concretely changes compared to earlier rules
Under the older European product safety directive, importer obligations were mostly implicit in national legislation and sometimes differed per member state. GPSR applies directly in all 27 member states and explicitly sets out the importer obligation: before a product reaches the market, the importer checks whether the manufacturer has prepared the risk analysis and technical documentation, whether the product bears a type, batch or serial number and the name and contact details of the manufacturer, and whether the instructions for use and warnings are provided in a language that the consumer in the country of sale understands.
Also new is that the importer must state their own name and address on the product, the packaging or an accompanying document. This is not a mark of approval and not an endorsement — it is a traceability requirement so that a supervisory authority or consumer knows who brought the product to the EU.
What an importer checks before sales begin
The regulation does not require the importer to conduct their own product assessment, but rather to take a critical look at what the manufacturer has delivered. This means: checking whether a risk analysis and technical documentation exist, whether the mandatory labelling is present, and whether the manufacturer's contact details are correct. If any of these documents are missing, the question lies with the manufacturer, not with the importer to draw them up — although the importer can be held accountable if they place a product without these documents on the market. Which documents are precisely needed for this and how to request them from a supplier outside the EU is further explained in the knowledge base by topic.
When the role shifts to manufacturer
The importer role and the manufacturer role do not exclude each other, but they do not automatically overlap either. If you purchase a product from a manufacturer outside the EU and resell it unchanged, you are generally an importer. If you sell the same product under your own brand or logo, you are typically considered a manufacturer — with a heavier obligation than that of an importer, because you must then prepare or adopt and bear responsibility for the risk analysis and technical documentation yourself. That distinction is precisely why the role assessment is worthwhile as a first step, before you look at labelling or documentation.
What this means in practice for your online shop
For companies that have been ordering from the same EU wholesaler for some time, little changes. For companies that order directly from manufacturers outside the EU themselves — via a platform, a trade fair or their own sourcing relationship — the importer role is a new, explicit point of attention, with its own control obligations separate from what the supplier itself already claims to have arranged. How gpsria.eu structures those control points per product category and where the information comes from EUR-Lex is explained on the page about our working method.
If you are unsure whether your company qualifies as an importer, manufacturer or distributor for a particular product, the free role check is a logical starting point, or you can first look at the answers to the most frequently asked questions about this role division.