What is a Seller of Record in Europe?

A Seller of Record is responsible for VAT, compliance, invoicing, and consumer obligations for sales within the European Union. EuroSOR acts as the official seller for non-EU brands so they can enter Europe without forming a local company.

Do I need a European company to start selling in the EU?

No. A non-EU brand can operate in the EU without opening a BV or GmbH by using a compliant Seller of Record model. EuroSOR provides the regulatory layer while the brand continues to own the customer and pricing.

How does EuroSOR handle VAT across Europe?

EuroSOR manages VAT registrations, filings, invoice compliance, and audit support. The objective is to give one consistent VAT framework for selling across multiple EU markets.

How does EuroSOR handle VAT deferment for imports into Europe?

EuroSOR uses the Dutch Article 23 VAT deferment scheme. This allows VAT to be postponed at import and settled later through VAT returns instead of paying it at the border.

Can EuroSOR support Importer of Record requirements?

Yes. EuroSOR works with an Importer of Record partner to manage customs clearance, duty calculation, and compliant entry of goods into the EU.

What delivery timelines can brands expect?

From our Netherlands hub, EU deliveries follow standard European timelines through integrated carrier networks, providing fast access to major markets across the EU.

Who controls pricing, brand, and customer experience?

The brand controls pricing, marketing, customer relationships, and product strategy. EuroSOR manages compliance, VAT, import coordination, and fulfilment.

Does EuroSOR support both B2C and B2B shipments?

Yes. EuroSOR supports both direct-to-consumer deliveries and wholesale shipments to retailers or distributors.

Selling Electronics in the EU: What Essentials Non-EU Brands Must Have Before First Shipment

EuroSOR · Consumer Electronics Series

Selling Electronics in the EU:
What Non-EU Brands Must Have
in Place Before First Shipment

December 2024 forced the issue. The new General Product Safety Regulation made a GPSR contact on every product non-negotiable for non-EU brands. But that obligation landed on top of CE marking and WEEE registration requirements that were already there. Most electronics brands on Amazon EU are still carrying at least one gap.

13Dec

2024: the date GPSR became mandatory and Amazon started suspending listings

EU directives that can apply to a single electronics product simultaneously

EU countries each requiring separate WEEE producer registration

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EU entity capital required with a Seller of Record structure

Consumer Electronics GPSR Responsible Person Seller of Record CE Marking WEEE REACH

Most non-EU electronics brands on Amazon EU were already non-compliant before December 2024. The GPSR deadline made it visible. But fixing only the GPSR contact to get listings back live does not close the CE marking documentation gaps or the WEEE registrations that were missing before. All three need to be in place. This post covers each one and where they connect.

GPSR: The December 2024 Change and What It Actually Requires

Regulation (EU) 2023/988 replaced the General Product Safety Directive on 13 December 2024. Every brand selling consumer products into the EU must now appoint an EU-established contact person, with their name and address on the product or packaging. Amazon EU began suspending listings for non-compliant ASINs from the enforcement date.

This contact person is not the same role as the CE marking Authorised Representative or a WEEE producer representative — though the same EU entity can hold all three. Each carries its own obligations under separate legislation.

On the Product

What must be visible

The EU contact's name, registered trade name, postal address, and email or website. A website address alone is not sufficient — physical contact details are required. Must appear on the product, its packaging, or an attached document.

Behind the Contact

What the EU contact must be able to do

Hold the product's technical documentation and produce it to market surveillance authorities on request. Register products on the EU Safety Gate portal where required. Cooperate with authorities on any safety issue, withdrawal, or recall. An address forwarding service does not meet this standard.

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Fixing the Amazon listing does not mean the compliance gap is closed Many brands added an EU address to their product detail page to reinstate suspended listings. That satisfies Amazon's surface-level check. It does not satisfy the regulation if the entity listed cannot hold technical documentation or respond to a market surveillance authority request.

CE Marking: Which Rules Apply to Your Product Category

CE marking is a self-declaration that a product meets EU safety requirements. The manufacturer or their EU-based representative prepares a technical file, signs a Declaration of Conformity, and applies the CE mark. For many products sold on Amazon EU by non-EU brands, the documentation behind the mark does not exist or is incomplete.

Directive	Applies To	What It Requires
LVD (2014/35/EU)	Electrical equipment at 50–1000V AC or 75–1500V DC. Chargers, power tools, kitchen appliances, lighting.	Technical file proving electrical safety. Declaration of Conformity. CE mark.
RED (2014/53/EU)	Any product that emits or receives radio signals. Bluetooth, WiFi, smart home devices, wearables, remote controls.	Technical file with radio test reports. Third-party lab reports required for most categories. DoC. CE mark.
EMC (2014/30/EU)	Electronics that generate or are affected by electromagnetic interference.	EMC test reports. Technical file. Declaration of Conformity. CE mark.
RoHS (2011/65/EU)	All electrical and electronic equipment.	Supplier declarations confirming restricted substance levels (lead, mercury, cadmium, hexavalent chromium, phthalates). RoHS compliance stated in the DoC.

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A CE mark printed on packaging is not the same as having a valid technical file Electronics manufactured in China frequently carry a CE mark applied by the factory. This is not a legally valid EU Declaration of Conformity unless an EU-based representative has prepared the technical file to EU standards and signed the DoC. Market surveillance authorities in Germany and France regularly pull products from sale after finding CE marks with no documentation behind them.

WEEE: The Electronics Recycling Registration Most Brands Skip

Any brand placing electrical or electronic equipment on an EU market must register as a producer in each country of sale and contribute to the national WEEE collection scheme. Registration is per country and per product category. A brand selling two product categories across five EU markets can need up to ten separate registrations, each with its own number that Amazon EU and major retailers check before approving a listing.

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Amazon EU requires WEEE numbers per country before listings go live Amazon's seller portal requires valid WEEE registration numbers for electrical and electronic products in each country marketplace. A product can have a valid GPSR contact and a CE mark and still be blocked from listing if the WEEE number for that country is missing.

Country	Registration Body	Key Note
🇩🇪 Germany	EAR (Stiftung Elektro-Altgeräte Register)	Mandatory pre-market. One of the strictest enforcement regimes in the EU. EAR number required on Amazon DE listings.
🇫🇷 France	ADEME via Ecologic or ecosystem	Registration with an approved eco-organisation. Unique ID number must appear on product or packaging.
🇮🇹 Italy	CdC RAEE	Required before market placement. Fees based on weight of equipment placed on market.
🇪🇸 Spain	MITECO via SIGREP	Producer registration and annual quantity reporting required.
🇳🇱 Netherlands	Wecycle (via RVO)	RVO registration required. Collective scheme participation standard for most categories.

REACH: Restricted Substances in Components and Casings

Regulation (EC) 1907/2006 restricts substances of very high concern in products sold in the EU. For electronics brands, the most relevant restrictions cover components, cables, plastic casings, and coatings. The SVHC candidate list is updated twice a year by ECHA and currently contains over 240 substances.

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REACH and RoHS cover different substances RoHS restricts ten specific substances in electronics and is addressed through the CE Declaration of Conformity. REACH covers a much larger and evolving list of SVHCs across all articles. A product can be RoHS-compliant and still have a REACH gap if a component contains an SVHC not on the RoHS list. Both need active supplier documentation.

Request REACH SVHC declarations from all component and casing suppliers covering the current ECHA candidate list
Treat these as live documents — they go stale when ECHA updates the list in January and July each year
Ensure the EU contact can respond to consumer SVHC queries within 45 days
For B2B sales, SVHC notification to ECHA's SCIP database is mandatory where articles contain SVHCs above 0.1%

What Needs to Be in Place Before Stock Ships

Requirement	What It Involves	Timing
GPSR EU contact	EU-established entity with name, address, and contact details on the product or packaging. Holds technical documentation. Mandatory since 13 December 2024. Amazon EU enforces at listing creation.	Before first sale
CE marking and technical file	Conformity assessment under applicable directives (LVD, RED, EMC, RoHS). Full technical file held by the EU Authorised Representative. Declaration of Conformity signed. CE mark on product and packaging.	Before first sale
WEEE registration (per country)	Producer registration with the national WEEE scheme in each country of sale. Registration number required for Amazon EU listings and retail onboarding. Annual quantity reporting and fee contributions.	Before first sale
REACH documentation	SVHC declarations from component and casing suppliers. SCIP database notification where required. Documentation available for consumer queries within 45 days.	Before first sale
Importer of Record	EU-based entity with EORI number and VAT registration to file customs declarations and pay import duties.	Before first inbound
EU VAT registration	Storing inventory in the EU creates a VAT obligation. Non-EU companies must appoint a fiscal representative jointly liable for VAT filings.	Before stock ships
EPR — packaging	Registration with the national packaging EPR scheme in each country of sale. Separate from WEEE. Annual contributions based on packaging weight and material.	Before first sale

GPSR contact appointment unblocks Amazon listing setup. CE marking, WEEE registration, and operational setup can then run concurrently.

How EuroSOR Handles This as One Structure

GPSR, CE marking, WEEE, REACH, IoR, VAT, and EPR are each handled by a different type of provider. Compliance consultancies handle CE. WEEE scheme administrators handle recycling registration. Customs brokers handle IoR. None of them coordinate with each other, and none take accountability for the full picture.

EuroSOR acts as the EU operating layer: holding the GPSR contact role, acting as CE Authorised Representative with the technical file, coordinating WEEE registrations per country, and handling IoR, VAT, EPR, and REACH documentation under one contract. When Amazon suspends a listing or a market surveillance authority asks a question, EuroSOR is the entity that responds.

One EuroSOR contract covers GPSR contact, CE documentation, WEEE registration, REACH, IoR, VAT, and EPR. One entity accountable when authorities or Amazon ask questions.

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In practice: a Chinese smart home brand on Amazon DE, FR, IT, ES, and NL Six WiFi-enabled SKUs across five marketplaces means a GPSR contact on every label, CE documentation including RED test reports held by an EU representative, WEEE registration in five countries, REACH SVHC declarations from component suppliers, an IoR for inbound stock, and EPR packaging registration in each country. EuroSOR coordinates all of it under one contract.

Book an intro call with EuroSOR →

Frequently Asked Questions

What changed for non-EU electronics brands in December 2024?

The General Product Safety Regulation (GPSR) came into force on 13 December 2024 and made it mandatory for every non-EU brand selling consumer products in the EU to appoint an EU-established contact person. Their name, address, and electronic contact details must appear on the product or packaging. Amazon EU began enforcing this at listing level from the enforcement date, suspending non-compliant ASINs.

Does the GPSR contact replace the CE marking requirements?

No. They are separate obligations under separate legislation. The CE marking Authorised Representative signs the Declaration of Conformity and holds the technical file under applicable EU directives (LVD, RED, EMC). The GPSR contact is appointed under the General Product Safety Regulation and holds different obligations. The same EU entity can fill both roles — but getting GPSR compliance in place does not address CE marking gaps.

What is WEEE registration and does my product need it?

Any brand placing electrical or electronic equipment on an EU market must register as a producer in each country of sale and contribute to the national WEEE recycling scheme. Amazon EU requires WEEE registration numbers for EEE product listings. A brand selling across five EU countries with two product categories can need up to ten separate registrations.

My product already has a CE mark. Does that mean it is compliant?

Not necessarily. The CE mark on packaging is only valid if the technical file behind it was properly prepared by a qualified EU-based Authorised Representative and the conformity assessment was actually conducted. Electronics manufactured in Asia frequently carry CE marks applied by the manufacturer without an underlying compliant technical file.

How is EuroSOR different from a compliance consultancy or GPSR service?

A compliance consultancy advises on what needs to be done. A GPSR service puts an address on your label. EuroSOR acts as the operating layer: EU contact on the label, CE Authorised Representative holding the technical file, WEEE registrations per country, IoR at the border, VAT and EPR handled under one contract. One entity accountable when Amazon or a market surveillance authority asks a question.

This page is updated periodically. Verify all compliance requirements with a qualified EU regulatory, legal, and tax adviser before entering the EU market. Nothing here constitutes legal, regulatory, or tax advice. GPSR obligations, CE marking conformity assessment requirements, WEEE registration procedures, REACH SVHC thresholds, and EPR contribution rates should be confirmed against current official guidance for each target member state before acting.

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Selling Electronics in the EU:What Non-EU Brands Must Havein Place Before First Shipment