---
title: "We do not put our importer name on the product"
description: "An EU importer must put its own name, registered trade name or trade mark and its contact address on each product it places on the market. The General Product Safety Regulation and the CE acts, such as the Low Voltage Directive, allow the packaging or an accompanying document only where the product itself cannot carry it. Fix the artwork for the next order and label stock before it ships."
type: "problem"
url: "https://www.conphora.com/solutions/problem/importer-name-on-product/"
markdown: "https://www.conphora.com/solutions/problem/importer-name-on-product.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: ["GPSR", "LVD", "suppliers-imports"]
license: "Free to quote with attribution and a link to the page"
---

# We do not put our importer name on the product

An EU importer must put its own name, registered trade name or trade mark and its contact address on each product it places on the market. The General Product Safety Regulation and the CE acts, such as the Low Voltage Directive, allow the packaging or an accompanying document only where the product itself cannot carry it. Fix the artwork for the next order and label stock before it ships.

## Why this happens

The importer's name on the product is a duty of its own. Under the General Product Safety Regulation (EU) 2023/988, importers indicate their name, registered trade name or registered trade mark, their postal and electronic address and, where different, the address of a single contact point. The information goes on the product, or where that is not possible, on its packaging or in a document accompanying the product, and any additional label must not obscure information the manufacturer had to provide (Article 11(3)). The manufacturer's own details are a separate requirement under Article 9(6). [1]

Products under a CE act follow that act. For products subject to Union harmonisation legislation, the GPSR's Chapter III, Section 1, which contains Article 11, does not apply (Article 2(1), third subparagraph, point (b)). The Low Voltage Directive 2014/35/EU then sets the importer's duty: name, registered trade name or registered trade mark and the postal address at which the importer can be contacted, on the equipment or, where that is not possible, on its packaging or in an accompanying document, in a language easily understood by end-users and market surveillance authorities (Article 8(3)). The other CE acts contain similar articles. [1] [2]

The Commission's Blue Guide explains how to read "where that is not possible". As a rule the importer's details go on the product. Only where that is not possible may they go on the packaging or in an accompanying document, and the Guide gives as an example the case where the importer would have to open the packaging to add its details. The address is one at which the importer can be contacted, in particular by authorities, and can be a customer service address. A website address may be given in addition to, but not instead of, a postal address (section 4.2.2.2). [4]

The details are checked further down the chain. Distributors verify that the importer has complied with Article 11(3) before making a product available, and must not sell it until it is brought into conformity (GPSR Article 12(1) and (3)). At the border, customs suspend the release for free circulation where a product is not labelled as required, and for products under the CE acts listed in Article 4(5) of Regulation (EU) 2019/1020, where the responsible economic operator's name and postal address are not indicated (Article 26(1)(b) and (d)). [1] [3]

## How to solve it

1. **Check what each unit carries today** Take a unit of every imported model from stock and note whose name and address appear on the product, the packaging and the leaflet. Two sets are expected on an imported product: the manufacturer's and yours. List the models where yours is missing.
2. **Find the rule for each model** Consumer products without a CE act follow the GPSR importer article, which asks for a postal and an electronic address. Products under a CE act follow that act, such as the Low Voltage Directive, which asks for a postal address. Note the rule per model before you change the artwork.
3. **Decide where your details go** The product itself comes first. The packaging or an accompanying document is the fallback only where the product cannot carry the details, for example because it is too small or because you would have to open sealed packaging to label it. Write down the reason when you use the fallback.
4. **Have the factory print them on future orders** Send the factory artwork with your name and address next to the manufacturer's, and make it part of the order specification. Check the first production units against the artwork before the goods ship.
5. **Label stock before it leaves your warehouse** Units already in stock get a durable label with your details before you sell them. Place it so that it does not cover the manufacturer's name, the identifier, the CE marking or any warning. Record which batches you relabelled and when.

## What you need to show

- **Label artwork showing the manufacturer and the importer** — The factory, with your details added (GPSR Article 11(3); LVD Article 8(3))
- **A note on why the details sit on the packaging or a document, where they do** — Your product file (GPSR Article 11(3); Blue Guide section 4.2.2.2)
- **Record of relabelled batches** — Your warehouse (Supports GPSR Article 15(3) traceability)

## If you do nothing

- **Customs hold the shipment** — Customs suspend release for free circulation where a product is not marked or labelled as the Union law applicable to it requires, and, for products under the listed CE acts, where the responsible operator's name and postal address are missing (Regulation (EU) 2019/1020, Article 26(1)(b) and (d)).
- **Retailers stop selling the product** — Before making a product available, a distributor verifies that the importer has met Article 11(3), and must not make the product available until it is brought into conformity (GPSR Article 12(1) and (3)).
- **Orders and penalties** — Authorities can require you to end the non-compliance and can restrict or withdraw the product if it persists (Regulation (EU) 2019/1020, Article 14(4)(g) and (h)). Member States set penalties for GPSR infringements (Article 44).

## Questions

### Is a sticker allowed?

The law asks for the details on the product and does not prescribe how they are applied. A label on the product meets it as long as it stays legible and does not obscure any information the manufacturer had to put on the label (GPSR Article 11(3)).

### Can we use our customer service address?

The Commission's Blue Guide says the importer's address is the one at which it can be contacted, in particular by authorities, and need not be where it is established. A website may be added but cannot replace the postal address.

### The manufacturer's details are already on it. Is that not enough?

No. The Blue Guide expects an imported product to bear two addresses: the manufacturer's outside the EU and the importer's inside it. Your details tell authorities and consumers who answers for the product in the Union.

### May the details go only on the shipping carton?

Only where the product cannot carry them. The fallback in GPSR Article 11(3) and LVD Article 8(3) is the packaging or a document accompanying the product. The Blue Guide gives having to open the packaging as one example of when the product cannot.

## Regulations involved

GPSR, LVD

## 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, 2026-10-04
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, 2026-10-04
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, 2026-10-04
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, 2026-10-04