---
title: "Online sellers in EU product compliance"
description: "Online seller is not a role of its own in EU product law. A company that sells to consumers online or at a distance is a manufacturer, an importer or a distributor for each product it sells, and carries that role's duties. What online selling adds is the same for all three: an offer aimed at consumers in the EU makes the product available on the EU market, and every offer must show the manufacturer, the responsible person in the EU, the product identification and the warnings."
type: "role"
url: "https://www.conphora.com/roles/online-seller/"
markdown: "https://www.conphora.com/roles/online-seller.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", "Online seller"]
license: "Free to quote with attribution and a link to the page"
---

# Online sellers in EU product compliance

Online seller is not a role of its own in EU product law. A company that sells to consumers online or at a distance is a manufacturer, an importer or a distributor for each product it sells, and carries that role's duties. What online selling adds is the same for all three: an offer aimed at consumers in the EU makes the product available on the EU market, and every offer must show the manufacturer, the responsible person in the EU, the product identification and the warnings.

## The definition in the law

> Products offered for sale online or through other means of distance sales shall be deemed to be made available on the market if the offer is targeted at consumers in the Union. An offer for sale shall be considered to be targeted at consumers in the Union if the relevant economic operator directs, by any means, its activities to one or more Member States.

[Regulation (EU) 2023/988 on general product safety (GPSR), Article 4](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529)

The law has no definition of an online seller; this is its rule on distance sales. Regulation (EU) 2019/1020 has a matching rule, worded for end users, for products under Union harmonisation legislation (Article 6).

## Which role does an online seller hold?

- **You are also the distributor: A web shop that resells brands bought from suppliers in the EU.** Someone else placed the products on the EU market, and you make them available. You are a distributor who sells online: verify the marking and the information, and show the mandatory information in each offer. (https://www.conphora.com/roles/distributor/)
- **You are also the importer: A web shop 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 is its importer, even if the supplier ships the parcel. (https://www.conphora.com/roles/importer/)
- **You are also the manufacturer: Products sold under the shop's own name or trademark.** A person who places a product on the market under its own name or trademark is deemed to be the manufacturer (GPSR Article 13(1)). The shop carries the manufacturer's duties for those products. (https://www.conphora.com/roles/manufacturer/)
- **You are also the manufacturer: A brand outside the EU that ships its own products directly to consumers in the EU.** Your brand makes you the manufacturer. Established outside the Union, you cannot be the importer, and the consumer is not one. The product may be placed on the market only when an economic operator established in the Union is responsible for it: appoint an authorised representative with a written mandate, or a fulfilment service provider in the Union takes the role for the products it handles (GPSR Article 16(1); Regulation (EU) 2019/1020, Article 4(2)). (https://www.conphora.com/roles/manufacturer/)

## 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

- Work out your role for each product: manufacturer when it carries your name or trademark, importer when you are established in the EU and place a product from a third country on the market, distributor otherwise. Then meet that role's duties. [GPSR Art. 3(8), 3(10), 3(11) and 13(1)]
- Check that an economic operator established in the Union is responsible for the product. Without one, the product may not be placed on the market. [GPSR Art. 16(1); Regulation (EU) 2019/1020 Art. 4(1)]

### On the product and in the offer

- Show in every offer the manufacturer's name, registered trade name or trade mark and its postal and electronic address. [GPSR Art. 19(a)]
- Where the manufacturer is not established in the Union, show in the offer the name and the postal and electronic address of the responsible person in the EU. [GPSR Art. 19(b)]
- Show in the offer the information that identifies the product, including a picture of it, and the warnings and safety information that go on the product or its packaging, in the language determined by the Member State where it is made available. [GPSR Art. 19(c) and 19(d)]

### Records to keep

- Be able to say who supplied you and, where you sell to other businesses, whom you supplied: for six years under the GPSR, for 10 years under the Low Voltage Directive. [GPSR Art. 15(3) and 15(5); LVD Art. 11]

### While it is on the market

- As a distributor, verify the marking, the names and addresses and the instructions before you list a product, and do not sell a product you have reason to doubt. [GPSR Art. 12(1) and 12(3)]

### When something is wrong

- If a product you sold is dangerous, inform the manufacturer or the importer, make sure corrective measures are taken and make sure the authorities are informed. Tell the manufacturer about accidents without undue delay. [GPSR Art. 12(4) and 20(3)]
- Expect the marketplace to act too: it removes offers of dangerous products on an authority's order and suspends traders that frequently offer non-compliant products, after a prior warning. [GPSR Art. 22(4) and 22(11)]

EU product law does not know the online seller as a role. The General Product Safety Regulation (EU) 2023/988 knows a manufacturer, who markets a product under its own name or trademark, an importer, who is established in the Union and places a product from a third country on the Union market, and a distributor, who is anyone else in the supply chain making a product available (Article 3). A company that sells online is one of these for each product it sells. [1]

Distance sales are covered expressly. Products offered for sale online or through other means of distance sales are deemed to be made available on the market if the offer is targeted at consumers in the Union, and an offer is targeted when the economic operator directs its activities, by any means, to one or more Member States (Article 4). Regulation (EU) 2019/1020 has the same rule for products under the CE acts (Article 6). The Commission's Blue Guide adds that a product bought online by an end user directly from outside the EU is placed on the market when the order for a specific product, already made and ready to be shipped, has been placed and confirmed (section 2.4). [1] [2] [3]

Each such offer must show the information in Article 19 of the GPSR: the manufacturer, the responsible person where the manufacturer is outside the Union, the product identification with a picture, and the warnings. Article 19 also applies to products covered by a CE act, although Chapter III, Section 1 of the GPSR (Articles 9 to 18) does not (Article 2(1), third subparagraph, point (b)); for those products the manufacturer's, importer's and distributor's duties come from the act itself. [1]

Whatever the set-up, one operator in the Union has to be responsible for the product: a manufacturer established in the Union, an importer, an authorised representative with a written mandate, or, where none of these is established in the Union, a fulfilment service provider for the products it handles (Regulation (EU) 2019/1020, Article 4(2); GPSR Article 16(1)). Marketplaces ask sellers for that operator because they have to display it. [1] [2]

## What Conphora does for the online seller

- **Which rules apply to a product** — The free compliance checker shows which EU regulations are likely to apply to a product and what documentation it needs. It is indicative and needs no account.
- **The steps for your role, product by product** — The product workspace sets the role for each product, manufacturer, importer or distributor, and lists the steps that role carries under the regulations that apply.
- **Supplier requests** — Ask the supplier for the manufacturer's identity, the declaration and the test reports through one link. What comes back is filed on the product with the sender's name.
- **Documents ready for the marketplace** — The declaration of conformity is generated from the product's data, and the documents filed on a product can be shared as one link when a marketplace or a retailer asks.

## Who you share with

- **the manufacturer** — You give: Complaints and accident information from your customers. You receive: The manufacturer's identity and addresses, the product identification, the warnings and the evidence that the product is safe.
- **the online marketplace** — You give: For each listing: the manufacturer, the responsible person in the EU, the product identification and the warnings. You receive: Notice when an offer is removed, a warning before a suspension, and recall information.
- **Shop or consumer** — You give: An offer with the mandatory information, and the product with its marking, instructions and safety information. You receive: Complaints and reports of accidents.
- **Market surveillance authorities** — You give: Who supplied you, and the information that shows the product's conformity, on request. You receive: Reasoned requests, orders for corrective action, and orders to remove an offer.

## Regulations that bind the online seller

- [GPSR — General Product Safety Regulation](https://www.conphora.com/regulations/gpsr/): Art. 19
- [TLR — Tyre Labelling Regulation](https://www.conphora.com/regulations/tlr/): Art. 4, 6, 7
- [ELR — Energy Labelling Framework Regulation](https://www.conphora.com/regulations/elr/): Art. 5, 6, 16
- [RED — Radio Equipment Directive](https://www.conphora.com/regulations/red/): Art. 3a, 12, 13
- [BattR — EU Batteries Regulation](https://www.conphora.com/regulations/battr/): Art. 55, 62, 74
- [PPWR — Packaging and Packaging Waste Regulation](https://www.conphora.com/regulations/ppwr/): Art. 45
- [UoMD — Units of Measurement Directive](https://www.conphora.com/regulations/uomd/): Art. 1, 2, 3
- [CER — Ceramics Directive](https://www.conphora.com/regulations/cer/)
- [ErP — Ecodesign Directive](https://www.conphora.com/regulations/erp/)
- [FPR — Fertilising Products Regulation](https://www.conphora.com/regulations/fpr/)
- [FtLblD — Footwear Labelling Directive](https://www.conphora.com/regulations/ftlbld/)
- [TexR — Textile Regulation](https://www.conphora.com/regulations/texr/): Art. 16
- [TSD — Toy Safety Directive](https://www.conphora.com/regulations/tsd/): Art. 11
- [WEEE — WEEE Directive](https://www.conphora.com/regulations/weee/): Art. 14

## Problems people in this role ask about

- [The marketplace says our product page lacks warnings](https://www.conphora.com/solutions/problem/product-images-warnings/)
- [We dropship and do not know who is responsible](https://www.conphora.com/solutions/problem/dropshipping-responsibility/)
- [Our seller account was suspended for non-compliant products](https://www.conphora.com/solutions/problem/marketplace-account-suspended/)
- [We ship electronics to consumers in several EU countries](https://www.conphora.com/solutions/problem/weee-several-countries/)
- [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/)
- [A marketplace removed our listing for missing safety data](https://www.conphora.com/solutions/problem/marketplace-listing-removed/)
- [A marketplace asks for our EU responsible person](https://www.conphora.com/solutions/problem/marketplace-responsible-person/)
- [A marketplace wants our declaration and test report uploaded](https://www.conphora.com/solutions/problem/marketplace-doc-upload/)
- [A marketplace asks for battery information on the listing](https://www.conphora.com/solutions/problem/marketplace-battery-info/)
- [We sell refurbished products and are asked for safety proof](https://www.conphora.com/solutions/problem/second-hand-refurbished/)
- [We sell to several countries without packaging EPR](https://www.conphora.com/solutions/problem/epr-registration-country/)
- [Our e-commerce parcels are mostly air](https://www.conphora.com/solutions/problem/packaging-empty-space/)
- [We sell tyres online without the label shown](https://www.conphora.com/solutions/problem/tyre-label/)
- [We have no EU responsible person](https://www.conphora.com/solutions/problem/no-eu-responsible-person/)
- [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 are unsure whether we are a packaging producer](https://www.conphora.com/solutions/problem/packaging-producer-or-not/)
- [We sell jewellery: what are the nickel and lead limits?](https://www.conphora.com/solutions/problem/jewellery-nickel-lead/)
- [We sell bamboo-melamine tableware](https://www.conphora.com/solutions/problem/bamboo-melamine/)
- [We sell electronics and are not registered for take-back](https://www.conphora.com/solutions/problem/weee-registration/)
- [We made a green claim and cannot document it](https://www.conphora.com/solutions/problem/green-claim-no-evidence/)
- [We call our product climate neutral](https://www.conphora.com/solutions/problem/climate-neutral-claim/)
- [We call the product biodegradable or compostable](https://www.conphora.com/solutions/problem/biodegradable-claim/)
- [We repeat our supplier's environmental claims](https://www.conphora.com/solutions/problem/supplier-green-claims/)
- [We do not know which claims are on our own website](https://www.conphora.com/solutions/problem/website-claims-audit/)
- [We advertise durability or repairability](https://www.conphora.com/solutions/problem/durability-repair-claims/)
- [A competitor complained about our environmental claim](https://www.conphora.com/solutions/problem/competitor-complaint-claim/)
- [Our supplier recalled a product we sell](https://www.conphora.com/solutions/problem/supplier-recalled/)
- [We cannot reach the customers who bought the product](https://www.conphora.com/solutions/problem/reach-the-buyers/)
- [An authority's test purchase failed](https://www.conphora.com/solutions/problem/test-purchase-failed/)
- [We buy on a sourcing platform and resell in the EU](https://www.conphora.com/solutions/problem/sourcing-platform-products/)
- [We are outside the EU and ship directly to EU consumers](https://www.conphora.com/solutions/problem/non-eu-seller-direct/)

## Questions about the role

### The supplier ships directly to the customer. Are we still involved?

Yes. The offer is yours, and a product offered online is made available on the market when the offer is targeted at consumers in the Union.

### Are we the importer if the goods never pass through our hands?

Often, yes. The definition turns on who places a product from a third country on the Union market, and placing on the market means the first making available, not handling the parcel. A seller established in the Union that buys from a supplier outside the Union and sells the product on the EU market meets the definition. A seller established outside the Union cannot be the importer, so someone else in the Union has to be the responsible person.

### Is the consumer not the importer when they order from outside the EU?

The GPSR defines the importer as a person established in the Union who places a product from a third country on the market, and the economic operators as businesses with duties under it. A consumer buying for private use is not one of them, which is why the regulation asks for a separate responsible operator.

### Can the marketplace be our responsible person?

Not as a marketplace. A fulfilment service provider established in the Union can fill the role for the products it handles, but only where no manufacturer, importer or authorised representative is established in the Union. A marketplace provider that also offers fulfilment services can be a fulfilment service provider for those products, assessed case by case (GPSR recital 46).

### Is a postal address enough in the offer?

No. The offer must show the name, the postal address and the electronic address.

### When does an offer target consumers in the EU?

When you direct your activities, by any means, to one or more Member States. Delivery to EU addresses, EU languages, euro prices and EU shipping options are the signs to look at.

## 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. [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
3. [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