---
title: "The importer role in EU product compliance"
description: "The importer is the company established in the EU that places a product from a country outside the EU on the EU market. It does not make the product, but it must make sure the manufacturer did its part before the first unit is sold, add its own name and address to the product, and keep the documents for 10 years. If the product carries the importer's own brand, the importer is the manufacturer instead."
type: "role"
url: "https://www.conphora.com/roles/importer/"
markdown: "https://www.conphora.com/roles/importer.md"
locale: "en"
language: "en"
updated: "2026-10-05"
author: "Conphora compliance team"
publisher: "Conphora"
source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529"
tags: ["roles", "Importer"]
license: "Free to quote with attribution and a link to the page"
---

# The importer role in EU product compliance

The importer is the company established in the EU that places a product from a country outside the EU on the EU market. It does not make the product, but it must make sure the manufacturer did its part before the first unit is sold, add its own name and address to the product, and keep the documents for 10 years. If the product carries the importer's own brand, the importer is the manufacturer instead.

## The definition in the law

> Any natural or legal person established within the Union who places a product from a third country on the Union market.

[Regulation (EU) 2023/988 on general product safety (GPSR), Article 3(10)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529)

The CE acts define the importer in the same terms, for example the Low Voltage Directive (Article 2, point (5)). The definition goes back to the reference provisions in Decision No 768/2008/EC (Annex I, Article R1, point 5) and appears in the same terms in Regulation (EU) 2019/1020 (Article 3, point (9)). Placing on the market is the first making available of a product on the Union market (GPSR Article 3(7)).

## Am I the importer?

- **Yes: Lamps bought from a maker in China and sold in the EU under the maker's brand.** You are established in the EU and you are the first to make the product available here. The maker stays the manufacturer, and the importer's duties are yours. If the product was not designed or made for the EU market, you take on the manufacturer's role instead (Blue Guide, section 3.1).
- **Yes: A webshop in the EU whose supplier outside the EU ships straight to the customer.** Placing on the market means the first making available in the Union, not handling the parcel. A web shop established in the EU that buys from a supplier outside the EU and sells the product on the EU market places it on the market and is its importer, even though the goods never pass through its hands.
- **No, you are the manufacturer: A toy you have made in China and sell under your own brand.** Your name or trademark on the product makes you the manufacturer, whoever makes it (GPSR Article 13(1); Low Voltage Directive Article 10). You carry the manufacturer's duties, not the importer's. (https://www.conphora.com/roles/manufacturer/)
- **No, you are the distributor: Kitchenware bought from a wholesaler in another EU country.** An importer places a product from a third country on the Union market. Buying inside the Union makes you a distributor, unless you use your own brand or substantially modify the product. (https://www.conphora.com/roles/distributor/)

## What the law asks of you

The references name the General Product Safety Regulation (GPSR) and, as the example of a CE act, the Low Voltage Directive (LVD). For products under a product-specific harmonisation act, such as the Low Voltage or Toy Safety Directive, the GPSR's Chapter III, Section 1 (Articles 9 to 18) does not apply, and the act's own duties take its place (Article 2(1), third subparagraph, point (b)). The GPSR's safety requirement still covers risks the act does not (point (a)), and Articles 19 to 22, on online offers, accidents and online marketplaces, apply to all products, as do the recall rules in Articles 35 to 37. REACH restrictions and labelling rules do not take a product out of Articles 9 to 18. Whoever places on the EU market a product not designed for it, or a used product from outside the EU, takes on the manufacturer's role (Blue Guide, section 3.1); a used CE product resold inside the EU falls under the GPSR in full. The regulation guides list the article for each act.

### Before the product is placed or sold

- Place only compliant products on the market. Before you do, make sure the manufacturer has carried out the risk analysis or conformity assessment, drawn up the technical documentation and marked the product; for a CE product, also that it bears the CE marking and comes with the required documents. [GPSR Art. 11(1); LVD Art. 8(1) and 8(2)]
- Do not place a product you have reason to believe is dangerous or non-conforming. Where it is dangerous, inform the manufacturer and make sure the market surveillance authorities are informed. [GPSR Art. 11(2); LVD Art. 8(2)]

### On the product and in the offer

- Add your name, registered trade name or registered trade mark and your postal and electronic address (under the Low Voltage Directive, the postal address) to the product, or to the packaging or an accompanying document where that is not possible, without covering the manufacturer's information. [GPSR Art. 11(3); LVD Art. 8(3)]
- Make sure the product comes with instructions and safety information in the language determined by the Member State where it is made available. [GPSR Art. 11(4); LVD Art. 8(4)]

### Records to keep

- Keep a copy of the technical documentation for 10 years after placing the product on the market. Under the Low Voltage Directive, keep a copy of the EU declaration of conformity for 10 years and make sure the technical documentation can be made available to the authorities on request. [GPSR Art. 11(6); LVD Art. 8(8)]
- Be able to say who supplied you and whom you supplied: for six years under the GPSR, for 10 years under the Low Voltage Directive. [GPSR Art. 15; LVD Art. 11]

### While it is on the market

- While the product is under your responsibility, keep storage and transport from jeopardising its conformity. [GPSR Art. 11(5); LVD Art. 8(5)]
- Check that consumers can reach the manufacturer with complaints and provide a channel yourself if they cannot. Investigate complaints, keep the register and keep the manufacturer and the distributors informed. Under the Low Voltage Directive, sample-test marketed equipment where the risks warrant it. [GPSR Art. 11(9) and 11(10); LVD Art. 8(6)]
- Where the manufacturer is not established in the Union, you are the economic operator responsible for the product, for products under the GPSR and the CE acts listed in Article 4(5) of Regulation (EU) 2019/1020: under the GPSR, also check regularly that the product matches its technical documentation and carries the required identification, contact details and instructions. [GPSR Art. 16(1) and 16(2); Regulation (EU) 2019/1020 Art. 4(2)(b), 4(3) and 4(5)]
- When you offer the product online or at a distance, show in the offer the manufacturer, the responsible person where the manufacturer is outside the EU, the product identification with a picture, and the warnings. [GPSR Art. 19]

### When something is wrong

- Under the GPSR, if a product you placed on the market is dangerous, at once inform the manufacturer, make sure corrective measures are taken, including withdrawal or recall, or take them yourself, make sure consumers are informed, and inform the market surveillance authorities through the Safety Business Gateway. [GPSR Art. 11(8)]
- Under the Low Voltage Directive, if equipment you placed on the market does not conform, at once take the corrective measures to bring it into conformity, withdraw or recall it; where it presents a risk, at once inform the national authorities where you made it available. [LVD Art. 8(7)]
- Tell the manufacturer without undue delay about an accident caused by a product you placed on the market. The manufacturer makes the notification through the Safety Business Gateway, or instructs you to make it. This duty applies to CE products too. [GPSR Art. 20(3)]

The importer is defined by what it does. Under the General Product Safety Regulation (EU) 2023/988, the importer is any natural or legal person established within the Union who places a product from a third country on the Union market (Article 3(10)); placing on the market is the first making available on the Union market (Article 3(7)). The Commission's Blue Guide describes the importer as more than a re-seller: it has a key role in guaranteeing that imported products comply, and its obligations build on the manufacturer's. [1] [4]

For consumer products under the GPSR, Article 11 sets the list. Before placing a product on the market, the importer ensures that it meets the general safety requirement and that the manufacturer has drawn up the risk analysis and technical documentation and put the identifier and its contact details on the product. The importer adds its own name and addresses, ensures instructions and safety information in the required language, protects the product in storage and transport, keeps a copy of the technical documentation for 10 years, and investigates complaints and acts on dangerous products. [1]

For products covered by a CE act, Chapter III, Section 1 of the GPSR (Articles 9 to 18) does not apply (Article 2(1), third subparagraph, point (b)), and the act itself sets the importer's duties. Under the Low Voltage Directive 2014/35/EU, importers place only compliant equipment on the market; before doing so they ensure that the manufacturer carried out the conformity assessment, drew up the technical documentation and affixed the CE marking; they add their details, ensure the instructions, carry out sample testing where appropriate and keep the declaration for 10 years (Article 8). The GPSR's rules on online offers and accidents (Articles 19 and 20) and its recall rules (Articles 35 to 37) still apply to those products. [1] [2]

Where the manufacturer is outside the Union, the importer is also the economic operator responsible for the product towards the authorities, for products under the GPSR and the CE acts listed in Article 4(5) of Regulation (EU) 2019/1020 (Article 4(2)(b); GPSR Article 16(1)). At the border, customs control products declared for release for free circulation and suspend the release where documentation, marking or the EU operator's details are missing (Regulation (EU) 2019/1020, Articles 25 and 26). [1] [3]

## What Conphora does for the importer

- **A supplier request to the manufacturer** — One link asks the manufacturer for the declaration, the test reports and the technical documentation. What comes back is filed on the product with the sender's name.
- **The importer's steps, product by product** — The product workspace sets the role for each product and lists the steps the importer carries under the regulations that apply to it.
- **One document when an authority asks** — The documents filed on a product are assembled into one technical file, with the declaration of conformity, ready to send on a reasoned request.
- **Radar and recall** — Compliance Radar reports changes in the rules and Safety Gate alerts for your product types, and the recall manager runs a recall from the first alert to closure.

## Who you share with

- **the manufacturer** — You give: Requests for documents, the markets you sell in, complaints and accident information. You receive: The EU declaration of conformity; a copy of the technical documentation (GPSR) or, under a CE act, the assurance that it can be made available when an authority asks; test reports, instructions and safety information.
- **the distributor** — You give: A product that carries the manufacturer's and your own name and address, with instructions in the market's language, and word of any safety issue. You receive: Complaints, accident information and non-conformities found in the shop.
- **the online marketplace** — You give: The information for each offer: the manufacturer, the responsible person, the product identification and the warnings. You receive: Notices when an offer is removed, and cooperation when a product is recalled.
- **Market surveillance authorities** — You give: The technical documentation, the declaration and the names of your supplier and your business customers, on request. You receive: Reasoned requests, orders for corrective action, withdrawal or recall.

## Regulations that bind the importer

- [GPSR — General Product Safety Regulation](https://www.conphora.com/regulations/gpsr/): Art. 11, 15, 16, 19, 20
- [BattR — EU Batteries Regulation](https://www.conphora.com/regulations/battr/): Art. 3, 41, 44, 46, 47, 48, 55, 56, 77
- [ELR — Energy Labelling Framework Regulation](https://www.conphora.com/regulations/elr/): Art. 1, 2, 3, 4, 6, 8, 9, 10, 11
- [FPR — Fertilising Products Regulation](https://www.conphora.com/regulations/fpr/): Art. 8, 10, 11, 12
- [IVDR — In Vitro Diagnostic Medical Devices Regulation](https://www.conphora.com/regulations/ivdr/): Art. 13, 16, 22, 27, 28
- [MDR — Medical Devices Regulation](https://www.conphora.com/regulations/mdr/): Art. 13, 16, 30, 31
- [ErP — Ecodesign Directive](https://www.conphora.com/regulations/erp/): Art. 3, 4, 5
- [PyroD — Pyrotechnic Articles Directive](https://www.conphora.com/regulations/pyrod/): Art. 7, 9, 12, 14, 15
- [UAS — UAS Regulation](https://www.conphora.com/regulations/uas/): Art. 8, 10, 11
- [RCD — Recreational Craft Directive](https://www.conphora.com/regulations/rcd/): Art. 9, 11, 13
- [RED — Radio Equipment Directive](https://www.conphora.com/regulations/red/): Art. 12, 14, 15
- [SPVD — Simple Pressure Vessels Directive](https://www.conphora.com/regulations/spvd/): Art. 8, 10, 11
- [ATEX — ATEX Directive](https://www.conphora.com/regulations/atex/): Art. 8, 10, 11
- [CIR — Cableway Installations Regulation](https://www.conphora.com/regulations/cir/): Art. 13, 15, 16
- [GAR — Gas Appliances Regulation](https://www.conphora.com/regulations/gar/): Art. 9, 11, 12
- [LiftD — Lifts Directive](https://www.conphora.com/regulations/liftd/): Art. 10, 12, 13
- [LVD — Low Voltage Directive](https://www.conphora.com/regulations/lvd/): Art. 8, 10, 11
- [MID — Measuring Instruments Directive](https://www.conphora.com/regulations/mid/): Art. 10, 12, 13
- [NAWI — Non-automatic Weighing Instruments Directive](https://www.conphora.com/regulations/nawi/): Art. 8, 10, 11
- [PED — Pressure Equipment Directive](https://www.conphora.com/regulations/ped/): Art. 8, 10, 11
- [PPE — PPE Regulation](https://www.conphora.com/regulations/ppe/): Art. 10, 12, 13
- [TPED — Transportable Pressure Equipment Directive](https://www.conphora.com/regulations/tped/): Art. 6, 7, 10, 11
- [TSD — Toy Safety Directive](https://www.conphora.com/regulations/tsd/): Art. 6, 8, 9
- [CER — Ceramics Directive](https://www.conphora.com/regulations/cer/): Art. 2, 2a
- [EMC — Electromagnetic Compatibility Directive](https://www.conphora.com/regulations/emc/): Art. 9, 11, 12
- [ExplD — Civil Explosives Directive](https://www.conphora.com/regulations/expld/): Art. 7, 9
- [PPWR — Packaging and Packaging Waste Regulation](https://www.conphora.com/regulations/ppwr/): Art. 7, 10, 18, 21, 22
- [CosR — Cosmetics Regulation](https://www.conphora.com/regulations/cosr/): Art. 2, 4, 5, 10, 11, 13, 18, 19
- [FCM — Food Contact Materials Framework Regulation](https://www.conphora.com/regulations/fcm/): Art. 3, 5, 6, 15, 16, 17
- [HWB — Hot-Water Boilers Directive](https://www.conphora.com/regulations/hwb/)
- [PIM — Plastics Regulation](https://www.conphora.com/regulations/pim/): Art. 4, 14a, 15, 16
- [POPs — POPs Regulation](https://www.conphora.com/regulations/pops/): Art. 2, 3, 4, 5
- [RoHS — RoHS Directive](https://www.conphora.com/regulations/rohs/): Art. 9, 11, 12
- [DetR — Detergents Regulation](https://www.conphora.com/regulations/detr/): Art. 2, 3, 4a, 7, 9, 11
- [PPWD — Packaging and Packaging Waste Directive](https://www.conphora.com/regulations/ppwd/): Art. 8
- [ELVD — ELV Directive](https://www.conphora.com/regulations/elvd/): Art. 2, 4, 5, 8, 9
- [REACH — REACH Regulation](https://www.conphora.com/regulations/reach/): Art. 5, 6, 7, 8, 12, 14, 31, 32, 33, 36, 56, 59, 67
- [TLR — Tyre Labelling Regulation](https://www.conphora.com/regulations/tlr/): Art. 2, 3, 4, 5, 10, 12
- [AerD — Aerosol Dispensers Directive](https://www.conphora.com/regulations/aerd/): Art. 1, 3, 8, 9, 10
- [FtLblD — Footwear Labelling Directive](https://www.conphora.com/regulations/ftlbld/): Art. 4
- [MED — Marine Equipment Directive](https://www.conphora.com/regulations/med/): Art. 14, 26, 28
- [OND — Outdoor Noise Directive](https://www.conphora.com/regulations/ond/): Art. 4, 5, 8, 11, 12
- [PVD — Paints Directive](https://www.conphora.com/regulations/pvd/): Art. 2, 3, 4
- [TexR — Textile Regulation](https://www.conphora.com/regulations/texr/): Art. 5, 7, 8, 9, 12, 14, 15, 16, 18, 19
- [UoMD — Units of Measurement Directive](https://www.conphora.com/regulations/uomd/): Art. 1, 2, 3, 4
- [BottD — Measuring Container Bottles Directive](https://www.conphora.com/regulations/bottd/): Art. 2, 3
- [MetrD — Metrology Framework Directive](https://www.conphora.com/regulations/metrd/): Art. 1, 7
- [EUDR — EU Deforestation Regulation](https://www.conphora.com/regulations/eudr/): Art. 4, 7, 26, 33

## Problems people in this role ask about

- [Our supplier will not say what the product is made of](https://www.conphora.com/solutions/problem/supplier-material-data/)
- [We import power adapters and chargers](https://www.conphora.com/solutions/problem/power-adapter-imported/)
- [We have to file an EUDR due diligence statement](https://www.conphora.com/solutions/problem/eudr-due-diligence-statement/)
- [Customs stopped our shipment at the EU border](https://www.conphora.com/solutions/problem/customs-stopped-goods/)
- [Our supplier cannot provide a test report](https://www.conphora.com/solutions/problem/supplier-no-test-report/)
- [We doubt that the supplier's certificate is genuine](https://www.conphora.com/solutions/problem/supplier-fake-certificate/)
- [We import and do not know what an importer must check](https://www.conphora.com/solutions/problem/importer-duties/)
- [The supplier's documents are in Chinese only](https://www.conphora.com/solutions/problem/supplier-documents-language/)
- [We cannot keep track of documents from many suppliers](https://www.conphora.com/solutions/problem/many-suppliers-tracking/)
- [We do not put our importer name on the product](https://www.conphora.com/solutions/problem/importer-name-on-product/)
- [The tested sample is not the product we received](https://www.conphora.com/solutions/problem/sample-vs-production/)
- [A retailer wants proof of compliance before listing](https://www.conphora.com/solutions/problem/retailer-proof/)
- [A new regulation applies and nobody knows what changes](https://www.conphora.com/solutions/problem/new-regulation/)
- [A product needs to be recalled](https://www.conphora.com/solutions/problem/recall/)
- [Marketing wants to say the product is sustainable](https://www.conphora.com/solutions/problem/green-claim/)
- [Our plastic kitchen product has no declaration of compliance](https://www.conphora.com/solutions/problem/plastic-food-contact/)
- [We sell bamboo-melamine tableware](https://www.conphora.com/solutions/problem/bamboo-melamine/)
- [We sell fireworks or party pyrotechnics](https://www.conphora.com/solutions/problem/pyrotechnics/)
- [We repeat our supplier's environmental claims](https://www.conphora.com/solutions/problem/supplier-green-claims/)
- [A customer asks where our wood, cocoa or rubber comes from](https://www.conphora.com/solutions/problem/deforestation-origin/)
- [We do not know if we are an EUDR operator or trader](https://www.conphora.com/solutions/problem/eudr-operator-or-trader/)
- [We sell imported goods under our own brand](https://www.conphora.com/solutions/problem/own-brand-import/)
- [We buy on a sourcing platform and resell in the EU](https://www.conphora.com/solutions/problem/sourcing-platform-products/)
- [We onboard a new supplier and want the documents first](https://www.conphora.com/solutions/problem/new-supplier-onboarding/)
- [The supplier changed a component without telling us](https://www.conphora.com/solutions/problem/supplier-changed-component/)
- [Our supplier contract says nothing about compliance](https://www.conphora.com/solutions/problem/contract-compliance-clauses/)
- [We audit the factory but not the product compliance](https://www.conphora.com/solutions/problem/factory-audit-scope/)
- [We buy branded goods outside the EU and sell them here](https://www.conphora.com/solutions/problem/parallel-import/)
- [A marketplace removed our listing for missing safety data](https://www.conphora.com/solutions/problem/marketplace-listing-removed/)
- [A retailer's supplier portal asks questions we cannot answer](https://www.conphora.com/solutions/problem/retailer-supplier-portal/)
- [A retailer announces a compliance audit of our range](https://www.conphora.com/solutions/problem/retailer-compliance-audit/)
- [A retailer asks for proof that the CE mark is real](https://www.conphora.com/solutions/problem/retailer-asks-ce-proof/)
- [A business customer sends a compliance questionnaire](https://www.conphora.com/solutions/problem/b2b-customer-questionnaire/)
- [A tender requires compliance documentation per product](https://www.conphora.com/solutions/problem/tender-compliance-docs/)
- [A retailer asks for packaging data per product](https://www.conphora.com/solutions/problem/retailer-packaging-data/)
- [A marketplace asks for battery information on the listing](https://www.conphora.com/solutions/problem/marketplace-battery-info/)
- [We do not know if our product needs CE marking](https://www.conphora.com/solutions/problem/needs-ce-marking/)
- [Are we the manufacturer, the importer or the distributor?](https://www.conphora.com/solutions/problem/which-role-are-we/)
- [We do not know which regulations apply to our product](https://www.conphora.com/solutions/problem/which-regulations-apply/)
- [We want to sell in another EU country](https://www.conphora.com/solutions/problem/new-eu-country/)
- [We do not know which languages the instructions must be in](https://www.conphora.com/solutions/problem/language-requirements/)
- [We changed the product. Does our compliance still hold?](https://www.conphora.com/solutions/problem/product-change-recheck/)
- [Nobody in the company owns product compliance](https://www.conphora.com/solutions/problem/who-owns-compliance/)
- [We are unsure whether our product counts as a toy](https://www.conphora.com/solutions/problem/toy-or-not/)
- [We sell a product for babies or small children](https://www.conphora.com/solutions/problem/childcare-product/)
- [Management asks what the company is liable for](https://www.conphora.com/solutions/problem/management-liability/)
- [We are unsure whether our product is protective equipment](https://www.conphora.com/solutions/problem/ppe-or-not/)
- [Purchasing and marketing do not know the compliance basics](https://www.conphora.com/solutions/problem/train-the-team/)
- [We want to sell a cosmetic product in the EU](https://www.conphora.com/solutions/problem/cosmetic-product-launch/)
- [Our product touches food](https://www.conphora.com/solutions/problem/food-contact-product/)
- [We sell a machine or power tool](https://www.conphora.com/solutions/problem/machinery-or-tool/)
- [We are unsure whether our product is a medical device](https://www.conphora.com/solutions/problem/medical-or-wellness/)
- [We sell drones or drone accessories](https://www.conphora.com/solutions/problem/drone-product/)
- [Our product works under pressure](https://www.conphora.com/solutions/problem/pressure-equipment/)
- [We sell a scale or a measuring instrument](https://www.conphora.com/solutions/problem/measuring-instrument/)
- [We sell a construction product](https://www.conphora.com/solutions/problem/construction-product/)
- [We sell furniture and no specific EU act covers it](https://www.conphora.com/solutions/problem/furniture-general-safety/)
- [We sell in both the UK and the EU](https://www.conphora.com/solutions/problem/uk-and-eu/)
- [An authority asks for our technical documentation](https://www.conphora.com/solutions/problem/authority-asks-technical-file/)
- [We have sold for years without technical documentation](https://www.conphora.com/solutions/problem/no-technical-documentation/)
- [Which language must the declaration of conformity be in?](https://www.conphora.com/solutions/problem/doc-in-which-language/)
- [Our compliance documents are scattered everywhere](https://www.conphora.com/solutions/problem/documents-scattered/)
- [How long must we keep compliance documents?](https://www.conphora.com/solutions/problem/keep-documents-how-long/)
- [The person who knew our compliance has left](https://www.conphora.com/solutions/problem/employee-left/)
- [A buyer's due diligence asks for our compliance status](https://www.conphora.com/solutions/problem/due-diligence-buyer/)
- [Our label has no EU address on it](https://www.conphora.com/solutions/problem/label-no-eu-address/)
- [We do not know what the packaging rules mean for us](https://www.conphora.com/solutions/problem/packaging-rules-meaning/)
- [We are unsure whether we are a packaging producer](https://www.conphora.com/solutions/problem/packaging-producer-or-not/)
- [We sell to several countries without packaging EPR](https://www.conphora.com/solutions/problem/epr-registration-country/)
- [We do not know which recycling symbols to print](https://www.conphora.com/solutions/problem/recycling-labels/)
- [We do not know which warnings a toy needs](https://www.conphora.com/solutions/problem/warning-texts-toys/)
- [Our textile label lacks the fibre composition](https://www.conphora.com/solutions/problem/textile-label/)
- [We sell shoes without the material label](https://www.conphora.com/solutions/problem/footwear-label/)
- [Our product needs an energy label and EPREL registration](https://www.conphora.com/solutions/problem/energy-label/)
- [Our cosmetic label misses mandatory information](https://www.conphora.com/solutions/problem/cosmetics-label/)
- [Our packaging uses non-metric units](https://www.conphora.com/solutions/problem/units-of-measurement/)
- [A customer asks for our RoHS declaration](https://www.conphora.com/solutions/problem/rohs-substances/)
- [A customer asks if our product contains SVHCs](https://www.conphora.com/solutions/problem/reach-svhc-question/)
- [Could our product contain a banned persistent pollutant?](https://www.conphora.com/solutions/problem/pops-in-product/)
- [We sell jewellery: what are the nickel and lead limits?](https://www.conphora.com/solutions/problem/jewellery-nickel-lead/)
- [Our plastic toy was flagged for phthalates](https://www.conphora.com/solutions/problem/phthalates-toys/)
- [We want to sell a detergent or cleaning product](https://www.conphora.com/solutions/problem/detergent-product/)
- [We want to sell a fertiliser or a plant biostimulant](https://www.conphora.com/solutions/problem/fertiliser-product/)
- [An ingredient in our cosmetic has been banned or restricted](https://www.conphora.com/solutions/problem/cosmetics-banned-ingredient/)
- [We sell a product in a spray can](https://www.conphora.com/solutions/problem/aerosol-product/)
- [Customers ask about chemicals in our clothing](https://www.conphora.com/solutions/problem/textile-chemicals/)
- [Our product contains a battery and we sell it as before](https://www.conphora.com/solutions/problem/battery-in-product/)
- [A customer asks about the battery passport](https://www.conphora.com/solutions/problem/battery-passport/)
- [We are asked about battery due diligence](https://www.conphora.com/solutions/problem/battery-due-diligence/)
- [We do not know how to label our batteries](https://www.conphora.com/solutions/problem/battery-labelling/)
- [We sell electronics and are not registered for take-back](https://www.conphora.com/solutions/problem/weee-registration/)
- [We heard our device must charge with USB-C](https://www.conphora.com/solutions/problem/charger-common-port/)
- [We sell LED lamps or luminaires](https://www.conphora.com/solutions/problem/led-lighting/)
- [We sell e-bikes or e-scooters](https://www.conphora.com/solutions/problem/e-bike-e-scooter/)
- [Our product falls under an ecodesign regulation](https://www.conphora.com/solutions/problem/ecodesign-requirements/)
- [A customer asks when we will have a digital product passport](https://www.conphora.com/solutions/problem/dpp-preparation/)
- [We claim recycled content and are asked for proof](https://www.conphora.com/solutions/problem/recycled-content-claim/)
- [We sell single-use plastic products](https://www.conphora.com/solutions/problem/single-use-plastic/)
- [A large customer asks for ESG data per product](https://www.conphora.com/solutions/problem/esg-customer-request/)
- [A customer was injured by our product](https://www.conphora.com/solutions/problem/customer-injured/)
- [We got a safety complaint and cannot tell if it is serious](https://www.conphora.com/solutions/problem/safety-complaint/)
- [A market surveillance authority sent us a letter](https://www.conphora.com/solutions/problem/authority-letter/)
- [Our product, or one like it, is on Safety Gate](https://www.conphora.com/solutions/problem/product-on-safety-gate/)
- [We do not know how to word the recall notice](https://www.conphora.com/solutions/problem/recall-notice-wording/)
- [We do not know whether to withdraw or recall](https://www.conphora.com/solutions/problem/withdrawal-or-recall/)
- [We have to report in the Safety Business Gateway](https://www.conphora.com/solutions/problem/safety-business-gateway/)
- [We keep no register of complaints](https://www.conphora.com/solutions/problem/complaints-register/)
- [An authority's test purchase failed](https://www.conphora.com/solutions/problem/test-purchase-failed/)
- [We do not know which remedy we must offer in a recall](https://www.conphora.com/solutions/problem/recall-cost-remedy/)
- [We must recall a product sold in several EU countries](https://www.conphora.com/solutions/problem/recall-in-several-countries/)
- [The recall is over and we want to prevent the next one](https://www.conphora.com/solutions/problem/after-the-recall/)

## Questions about the role

### Do we have to test every product we import?

No. The Blue Guide says the importer's checks do not imply a need to resort systematically to third-party testing, nor do they preclude it. Under the Low Voltage Directive, importers carry out sample testing of marketed products when deemed appropriate to the risks (Article 8(6)).

### From when do the 10 years run?

From placing the product on the market (GPSR Article 11(6); Low Voltage Directive Article 8(8)). The Commission's Blue Guide reads this as the last item of the product model placed on the market, so the period keeps moving as long as you place new units of that model.

### Do we need a mandate from the manufacturer?

No. The Blue Guide says the importer needs neither a mandate nor a preferential relationship with the manufacturer, but must make sure that contact with the manufacturer can be established. To carry out tasks on the manufacturer's behalf, the importer must be designated as authorised representative.

### What is the difference between an importer and a distributor?

The distributor makes available a product that someone else already placed on the market and verifies the identifier, contact details, instructions and safety information (GPSR Article 12(1)). The importer places it first and must check the manufacturer's documentation itself (Article 11(1)).

### Do importers have duties beyond product safety?

Often. An importer that places electrical and electronic equipment from a third country on a Member State's market on a professional basis is a producer under the WEEE Directive (Article 3(1)(f)(iii)). Importers of articles can also have REACH duties, such as passing on information on Candidate List substances above 0.1 % weight by weight (Article 33).

### Is the importer liable for damage a product causes?

Liability for damage is a separate regime. Under the Product Liability Directive (EU) 2024/2853, which applies to products placed on the market or put into service from 9 December 2026, the importer is liable alongside a manufacturer established outside the Union, as national law transposing the directive provides (Articles 2(1) and 8(1)(c)(i)).

## Sources

1. [Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529) — EUR-Lex, 2026-10-05
2. [Directive 2014/35/EU on electrical equipment (Low Voltage Directive), consolidated text of 30 May 2026](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0035-20260530) — EUR-Lex, 2026-10-05
3. [Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1020-20260812) — EUR-Lex, 2026-10-05
4. [The 'Blue Guide' on the implementation of EU product rules 2022 (2022/C 247/01)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52022XC0629(04)) — European Commission, via EUR-Lex, 2026-10-05
5. [Decision No 768/2008/EC on a common framework for the marketing of products](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008D0768) — EUR-Lex, 2026-10-05
6. [Directive (EU) 2024/2853 on liability for defective products](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024L2853) — EUR-Lex, 2026-10-05