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What documents do I need if I do dropshipping under the GPSR?

With dropshipping, the burden of proof differs from a regular webshop with its own inventory: this overview shows which documents you need and why the distance to your supplier is precisely the most challenging point.

What documents do I need if I do dropshipping under the GPSR?

If you do dropshipping, you typically do not purchase inventory and never physically handle the product. Yet that changes little about the documents you need: an order administration that shows what was sold and to whom, contact details of the supplier or manufacturer, proof that an EU-established responsible party has been designated, and data that allow a product to be traced after sale. Which additional documents are needed depends on the role you actually perform in practice — and that is precisely the point that is most complicated with dropshipping.

The regulation does not look at whether you ever held the product in your hands, but at who offers it to the consumer in the EU and under whose name that happens. With a classic webshop with its own warehouse, that is usually clear. With dropshipping, the chain runs through a supplier outside the EU, while the consumer only sees your webshop, your name and your contact details. That distance between what actually happens and what the consumer perceives is precisely why the documentation carries more weight here than with a normal resale.

Why dropshipping is a borderline case for documentation requirements

Whether you qualify as a manufacturer, importer or intermediary for a particular product depends on facts: who designs the product, under which brand it is sold, and from where it enters the EU. With dropshipping from a supplier outside the EU, it is conceivable that the role of importer falls to you, even without you ever packing a box — simply because you are the one bringing the product to market for the EU consumer. With dropshipping from a supplier within the EU, that is different again. These nuances are precisely why a role determination usually precedes the document list: without clarity on the role, you do not know which documents are truly necessary. Those who want to sort that out first can determine their own position in the chain in a few questions.

The core documents typically required

As a starting point, there are a number of documents that appear in virtually every dropshipping arrangement. First, an agreement or clear arrangement with the supplier about who bears which obligation, including who acts as the responsible party in the EU and how that is made visible on the product or the accompanying documentation. Second, identification details of the manufacturer: name, address and, where applicable, a postal address within the EU where supervisory authorities can reach out. Third, the purchase and order administration for each unit sold, so that a product can be traced back to a specific delivery and a specific consumer in case of inquiry or complaint. Fourth, where relevant, the technical documentation or declaration of conformity that belongs to the product category — you do not need to prepare it yourself, but must be able to demonstrate that you have requested and received it. What exactly must be requested from a supplier for this varies by product group and is described in more detail in the knowledge base by topic.

The detail that matters most with dropshipping

The point where dropshippers most often run into trouble is that the consumer has no knowledge of the supplier behind the scenes. For that consumer, there is only one point of contact: the webshop that took the order. This means that complaints, questions about safety, and requests for documentation in practice first reach you, even if you yourself have not designed or packaged any part of the product. Without a clear agreement with the supplier about which documents each party holds and who is responsible for what, there is a risk that you remain the only accountable party when it matters — while the underlying technical documentation is held by a party beyond your reach. This is why in dropshipping, the agreements made beforehand carry as much weight as the documents themselves.

Document what you cannot demonstrate yourself

Because the burden of proof in an inspection often lies with the party that the consumer sees as the point of contact, it is worthwhile to record internally what you do and do not have in your possession: which documents are held by the supplier, what agreements have been made about them, and how a consumer complaint reaches you and is followed up. A fixed system for this — with risk analysis, document storage and complaint register per product — prevents this type of information from becoming scattered across loose emails. What such a system entails and what it costs is explained on the subscription structure page.

Do you want to first know which role belongs to your own dropshipping arrangement before you start compiling a document list? The free role check provides a first indication for this, without requiring you to create an account.

This article is general information and not legal advice.