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 Clothing in the EU as a Non-EU Brand: Proven Compliance Steps Most Brands Miss

EuroSOR · Apparel & Fashion Series

Selling Clothing in the EU
as a Non-EU Brand: Refashion,
GPSR, and What Most Brands Miss

Most non-EU fashion brands entering Europe have researched EU labelling and VAT. Very few have heard of Refashion before signing a French 3PL contract. France's mandatory textile EPR scheme requires registration before a single garment goes on sale — and there is no EU-wide equivalent to fall back on.

€210B+

EU apparel and footwear market — the largest fashion market outside the US

Separate compliance obligations specific to apparel most brands miss before first sale

100%

Of textile products sold in France require Refashion registration regardless of sales volume

€0

EU entity capital required with a Seller of Record structure

Apparel & Fashion Selling Clothing in EU Seller of Record Refashion GPSR EPR

Selling clothing in EU non-EU brand compliance starts where most brands think it ends: after VAT, customs, and an Importer of Record are sorted. Refashion registration in France, a GPSR Responsible Person, correct fibre composition labelling, and REACH compliance for dyes and finishes all need to be in place before the first sale. This post covers the obligations specific to apparel and where they sit in the overall market entry sequence.

Refashion: France's Textile EPR That Catches Every Fashion Brand Off-Guard

Refashion is France's eco-organisation for textiles, clothing, footwear, and household linens. Under France's anti-waste legislation (AGEC), any producer, importer, or seller placing textile products on the French market must register with Refashion and pay an annual eco-contribution based on units placed on the market. This applies from the first unit sold. There is no minimum volume threshold and no exemption for non-EU brands.

The obligation falls on the entity that first places the product on the French market. For non-EU brands, that means the EU-established entity acting as seller of record in France. A non-EU brand without an EU operating structure cannot register with Refashion directly.

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Refashion has no EU-level equivalent — it is France-specific and mandatory Unlike packaging EPR, which most EU member states have implemented under a broadly similar framework, there is no single EU-wide textile EPR directive yet. Brands selling into Germany, the Netherlands, or Spain alongside France still need Refashion specifically for French sales. It cannot be satisfied by registration with a packaging EPR scheme or any other EU body.

Refashion registration applies to clothing, footwear, household linens, and accessories with textile components. Both Amazon France and Zalando require a valid Refashion producer identification number during seller onboarding. Without it, products cannot be listed for sale in France on either platform.

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Other EU markets with emerging textile EPR schemes France is currently the only EU member state with a mandatory operational textile EPR scheme. Sweden, the Netherlands, and Belgium have signalled intentions to introduce similar schemes under the EU's Textile Strategy. Brands registering with Refashion now through an EU-based operating structure are well-positioned to extend that structure as other markets come into force.

GPSR: The Responsible Person Obligation That Now Covers Clothing and Footwear

Regulation (EU) 2023/988 came into force on 13 December 2024. It requires every non-EU brand placing consumer products on the EU market to appoint an EU-established Responsible Person before any product goes on sale. The regulation explicitly covers clothing, footwear, accessories, and textile products sold to consumers.

The RP's name, address, and electronic contact details must appear on the product label or packaging. The Responsible Person must be able to produce technical documentation to market surveillance authorities on request and must cooperate on any corrective action or recall. Amazon Fashion and Zalando began checking GPSR Responsible Person details for all product categories from December 2024, including apparel. Brands without a valid EU RP address had listings suspended.

On the Label

What must appear

RP name, postal address, and electronic contact (email or website with direct contact). Can appear on care label, hang tag, or secondary label. Must be permanent and legible.

Held by the RP

What must be accessible

Technical documentation covering product composition, origin, applicable safety standards, and testing data. Must be retained for 10 years from last sale date and produced on authority request.

EU Garment Labelling: Fibre Composition, Origin, and Care Instructions

EU textile labelling is governed by Regulation (EU) 1007/2011. Every garment and textile product sold in the EU must carry mandatory label information. For non-EU brands, existing packaging rarely meets these requirements without active rework.

Label Element	EU Requirement	Typical Non-EU Gap
Fibre composition	Full fibre composition using standardised EU fibre names from Annex I, in descending order by weight. All fibres at or above 5% must be named individually.	Generic terms ("polyester blend") used instead of exact percentages and standardised names
GPSR RP address	EU-established RP name, address, and contact on product or label	No EU address on existing care label or packaging
Care instructions	Not mandated by EU law but required by major EU retailers and marketplaces. ISO care symbols are the accepted standard.	Written instructions in English only; ISO symbols absent
Language	Mandatory label fields in the official language(s) of each country of sale.	English-only labelling for DE, FR, IT, ES, NL markets
Size labelling	No mandatory EU size standard, but EU numeric sizing is expected by retailers. US letter sizing without EU equivalents creates high return rates.	US sizing only, no EU numeric equivalent

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Fibre composition claims are a market surveillance priority National authorities in Germany, France, and Italy regularly test garments to verify fibre composition declarations match actual composition. Mislabelling results in enforcement action and product withdrawal. Brands should hold laboratory test data confirming label claims.

REACH and Restricted Substances in Textiles

Regulation (EC) 1907/2006 (REACH) applies to textile products placed on the EU market. The most relevant restrictions cover substances used in dyeing, printing, and finishing treatments. REACH Annex XVII prohibits or limits azo dyes that can release carcinogenic amines, formaldehyde in finishing treatments, and phthalates in plastic components such as buttons and zips.

Request REACH compliance declarations from all fabric, dye, and garment suppliers covering the Annex XVII restricted substances list and current SVHC candidate list
Obtain azo dye test reports for products using synthetic dyes on items intended for extended skin contact
Check formaldehyde levels in finished garments with resin or wrinkle-resistant treatments
Verify PVC-coated components, buttons, and accessories meet phthalate restrictions under REACH Annex XVII
Ensure the EU RP can respond to consumer SVHC queries within 45 days

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Azo dye restrictions catch brands sourcing from non-EU manufacturers Certain azo dyes restricted under REACH Annex XVII Entry 43 are commonly used in South Asian and South-East Asian textile production. Test reports from a REACH-accredited laboratory are the standard way to demonstrate compliance. Supplier declarations alone are not accepted by EU market surveillance authorities.

Full Compliance Checklist Before Stock Enters the EU

Requirement	What It Involves	Timing
Refashion registration	Registration with Refashion and annual eco-contribution per unit placed on the French market. Required for all clothing, footwear, household linens, and accessories with textile components sold in France. Registration number required for Amazon France and Zalando FR listings.	Before first FR sale
GPSR Responsible Person	EU-established entity designated as RP under Regulation (EU) 2023/988. Name, address, and contact on product label. Mandatory since 13 December 2024.	Before first sale
EU label rework	Full fibre composition using Regulation 1007/2011 standardised names. GPSR RP address. Mandatory fields in the language of each country of sale. ISO care symbols. Must be complete before packaging is printed.	Before label print
REACH compliance	Supplier declarations for restricted substances under REACH Annex XVII. Laboratory test reports for azo dyes. Updated as ECHA candidate list is revised twice yearly.	Before first sale
Packaging EPR (per country)	Registration with national packaging EPR scheme in each country of sale. Covers polybags, hang tags, boxes, and plastic or paper packaging. Annual contributions based on material weight.	Before first sale
Importer of Record	EU-based entity with EORI number and VAT registration to file customs declarations and pay import duties. Required before any inbound shipment clears EU customs.	Before first inbound
EU VAT registration	Storing inventory in the EU creates a VAT obligation regardless of where the brand is registered. Non-EU companies must appoint a fiscal representative jointly liable for VAT filings.	Before stock ships

EU apparel compliance sequence. GPSR RP appointment and REACH checks come first. Label rework, Refashion, EPR, and operational setup can then run concurrently.

How EuroSOR Handles This as One Structure

The compliance picture for a non-EU fashion brand entering Europe spans multiple regulatory frameworks and multiple types of provider. Refashion registration requires an EU-based entity acting as the French market producer. GPSR requires an EU Responsible Person on every label. Packaging EPR requires registration in each country of sale. IoR and VAT require separate operational setup. No single compliance consultancy handles all of these, and no 3PL does either.

EuroSOR acts as the EU Responsible Person on your product labels, registers with Refashion as the French market producer for your brand, handles packaging EPR across your target countries, acts as Importer of Record at the border, and manages VAT registrations and filings. One contract covers the full compliance operating layer. The brand retains full pricing control and all customer relationships.

One EuroSOR contract covers GPSR RP, Refashion registration, IoR, VAT, and packaging EPR. No fragmented providers across five separate compliance obligations.

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In practice: a UK DTC fashion brand entering France, Germany, and the Netherlands A UK brand with 30 clothing SKUs targeting Amazon FR, Zalando DE, and its own DTC site needs GPSR RP on every label, Refashion registration for French sales, packaging EPR in three countries, an IoR for inbound stock, and VAT registration in at least two jurisdictions. Since Brexit, UK brands have the same non-EU status as US or Asian brands. EuroSOR handles the complete EU operating layer under one contract.

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Frequently Asked Questions

What does selling clothing in the EU require for a non-EU brand?

Non-EU fashion brands need a GPSR Responsible Person appointed before any product goes on sale, EU-compliant garment labelling covering fibre composition and RP address, Refashion registration if selling in France, packaging EPR registration in each country of sale, an Importer of Record for customs, and EU VAT registration. None of these are covered by a standard marketplace account or 3PL contract. EuroSOR's Seller of Record structure covers all of them under one arrangement.

What is Refashion and does it apply to my brand?

Refashion is France's mandatory eco-organisation for textiles under the AGEC anti-waste law. Any brand placing clothing, footwear, household linens, or accessories with textile components on the French market must register and pay an annual eco-contribution per unit. There is no minimum volume threshold. Amazon France and Zalando FR require a valid Refashion registration number before textile products can be listed.

What are the EU labelling requirements for garments?

Under Regulation (EU) 1007/2011, all garments must declare fibre composition using standardised EU fibre names in descending order by weight, with percentages for all fibres present at 5% or more. Mandatory label fields must appear in the official language of each country of sale. The GPSR Responsible Person's address must also appear. Most non-EU garment labels need full rework before they meet these requirements.

Can I sell on Zalando or Amazon Fashion without setting up a European company?

Yes. You need a GPSR Responsible Person on your labels, Refashion registration for France, packaging EPR registrations, an Importer of Record, and VAT registration — but not your own EU legal entity. EuroSOR's Seller of Record structure provides all of these under one arrangement, allowing non-EU fashion brands to sell compliantly on Zalando, Amazon Fashion, and DTC into the EU without incorporating in Europe.

How does EuroSOR handle Refashion registration for non-EU brands?

EuroSOR acts as the EU-established entity selling into the French market on behalf of the brand, which qualifies it to register with Refashion as producer and handle annual eco-contribution filings. This sits alongside GPSR RP, packaging EPR, IoR, and VAT under one Seller of Record contract.

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. Refashion eco-contribution rates, GPSR Responsible Person obligations, garment labelling requirements, REACH restrictions, and EPR contribution rates should be confirmed against current official guidance for each target member state before acting.

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Selling Clothing in the EUas a Non-EU Brand: Refashion,GPSR, and What Most Brands Miss