{
  "type": "problem",
  "slug": "new-eu-country",
  "lang": "en",
  "url": "https://www.conphora.com/solutions/problem/new-eu-country/",
  "markdown": "https://www.conphora.com/solutions/problem/new-eu-country.md",
  "title": "We want to sell in another EU country",
  "description": "Expanding to a new EU country: local-language instructions and warnings, the online offer, national technical rules and mutual recognition, packaging EPR.",
  "answer": "EU rules for a product are the same in every Member State, but each country sets the language for instructions, safety information and warnings, may have its own rules for non-harmonised aspects, and runs its own registers such as packaging EPR. Before selling there, translate what the product carries, adapt the online offer, check national technical rules and register where required.",
  "theme": {
    "id": "placing-on-market",
    "label": "Placing a product on the market"
  },
  "roles": [
    {
      "id": "manufacturer",
      "label": "Manufacturer"
    },
    {
      "id": "importer",
      "label": "Importer"
    },
    {
      "id": "online-seller",
      "label": "Online seller"
    }
  ],
  "regulations": [
    "GPSR",
    "CosR",
    "PPWR",
    "ELR",
    "TLR"
  ],
  "path": [
    "regulation-library",
    "product-validation"
  ],
  "trigger": "A distributor, a marketplace or the web shop opens a new EU country and the products are to ship there within weeks",
  "keep": null,
  "why": [
    {
      "text": "Selling in a second EU country rarely means a second set of tests. Where an EU act harmonises the rules for a product, the requirements are the same in every Member State, and several acts state that Member States shall not impede products that comply, for example the energy and tyre labelling regulations (Regulation (EU) 2017/1369 Article 7(1); Regulation (EU) 2020/740 Article 11(1)). What differs from country to country is the language, the national rules for aspects that the EU has not harmonised, and national registers.",
      "sources": [
        6,
        7
      ]
    },
    {
      "text": "Language comes first. Under the General Product Safety Regulation, manufacturers and importers ensure that the product comes with clear instructions and safety information in a language consumers easily understand, as determined by the Member State where it is made available (Articles 9(7) and 11(4)), and distributors check this before selling (Article 12(1)). For cosmetics, the content, durability, precautions and function on the label follow the law of the Member State where the product reaches the end user (Regulation (EC) No 1223/2009 Article 19(5)).",
      "sources": [
        1,
        5
      ]
    },
    {
      "text": "The online offer follows the customer. When products are sold at a distance, the offer shows the manufacturer's name and addresses, the EU responsible person where the manufacturer is outside the EU, information that identifies the product including a picture, and the warnings and safety information in a language consumers easily understand, as the Member State where the product is made available determines (GPSR Article 19). A new country's version of the web shop needs its own translated warnings.",
      "sources": [
        1
      ]
    },
    {
      "text": "National technical rules fill the space the EU leaves open. Regulation (EU) 2019/515 applies when an authority in the destination country uses a national rule on an aspect not harmonised at Union level, such as characteristics, names, marking or labelling, to restrict or deny access to goods lawfully marketed in another Member State (Article 2(1) and (2)). The producer may draw up a voluntary mutual recognition declaration to show the goods are lawfully marketed elsewhere, translated into a language the destination country requires (Article 4(1)), and each Member State runs Product Contact Points that explain its rules (Article 9). The regulation applies from 19 April 2020.",
      "sources": [
        3
      ]
    },
    {
      "text": "Some duties are registered per country. Under the Packaging Regulation, producers register in the national producer register of each Member State where they first make packaging or packaged products available, and may not sell there before they are registered (Regulation (EU) 2025/40 Article 44(2) and (4)); the national registers are set up within 18 months of the entry into force of the first implementing act under Article 44(14) (Article 44(1)). On 4 October 2026 no such act was visible on EUR-Lex, so how registration works until the registers exist is a matter for each Member State and a question for a lawyer. A cosmetics distributor that translates label elements on its own initiative to sell in another Member State submits the product category and names, the Member State, its own name and address and the responsible person's address to the Commission electronically (Regulation (EC) No 1223/2009 Article 13(3)). Market surveillance authorities in each country can require warnings in their own language as corrective action (Regulation (EU) 2019/1020 Article 16(3)(e)).",
      "sources": [
        2,
        4,
        5
      ]
    }
  ],
  "steps": [
    {
      "name": "Translate what goes with the product",
      "text": "Instructions and safety information must be in a language consumers easily understand, as the new Member State determines. The same applies to the warnings on the product or packaging under many sector acts. Ask the national authority or check national law for the language or languages it requires.",
      "item": "regulation-library"
    },
    {
      "name": "Adapt the online offer for that country",
      "text": "An offer aimed at consumers in that country shows the manufacturer's name and addresses, the EU responsible person where the manufacturer is outside the EU, a picture and identifiers of the product, and the warnings and safety information in the language that Member State determines."
    },
    {
      "name": "Check national technical rules for non-harmonised aspects",
      "text": "Where an aspect of the product is not harmonised at EU level, the new country may have its own technical rule on characteristics, names, marking or labelling. The Product Contact Point of that Member State gives general information online and, on request, the national technical rules for specific goods, free of charge. If the goods are lawfully marketed in another Member State, mutual recognition may let them in unchanged."
    },
    {
      "name": "Prepare a mutual recognition declaration where useful",
      "text": "For goods lawfully marketed in another Member State, the producer may draw up a voluntary mutual recognition declaration following the annex to Regulation (EU) 2019/515, translated into a language the destination country requires. An importer or distributor can complete Part II, or both parts if it holds the evidence."
    },
    {
      "name": "Register where the new country requires it",
      "text": "Producers of packaging register in the national producer register of each Member State where they first make packaging or packaged products available, and may not sell there before they are registered. Those registers depend on an implementing act not yet adopted; until then, check national rules. Cosmetics distributors that translate labels on their own initiative notify product and contact details to the Commission.",
      "item": "product-validation"
    }
  ],
  "documents": [
    {
      "name": "Instructions, safety information and warnings in the language of the new country",
      "from": "The manufacturer, or the importer for imported products",
      "ground": "GPSR Articles 9(7) and 11(4)"
    },
    {
      "name": "The mutual recognition declaration, where used",
      "from": "The producer, its authorised representative, or the importer or distributor for Part II",
      "ground": "Regulation (EU) 2019/515 Article 4(1)–(3)"
    },
    {
      "name": "Proof of registration in the national register of packaging producers",
      "from": "The producer, or its authorised representative or producer responsibility organisation",
      "ground": "Regulation (EU) 2025/40 Article 44(2)–(4)"
    }
  ],
  "risks": [
    {
      "title": "Distributors cannot sell without the local language",
      "text": "A distributor verifies the instructions and safety information requirement before making a product available and does not make it available if it is not met (GPSR Article 12(1) and (3)).",
      "source": 1
    },
    {
      "title": "Authorities can order local-language warnings",
      "text": "Corrective action can include affixing clear warnings in the language or languages determined by the Member State where the product is made available, and alerting end users in that language (Regulation (EU) 2019/1020 Article 16(3)(e) and (g)).",
      "source": 2
    },
    {
      "title": "No packaging registration, no sale",
      "text": "Producers may not make packaging or packaged products available for the first time in a Member State if they, or their authorised representative for extended producer responsibility, are not registered there (Regulation (EU) 2025/40 Article 44(4)). The national registers are set up within 18 months of the entry into force of the first implementing act under Article 44(14) (Article 44(1)); no such act was visible on EUR-Lex on 4 October 2026.",
      "source": 4
    }
  ],
  "faq": [
    {
      "q": "Do we need a new CE marking or new tests for each country?",
      "a": "Not for harmonised requirements, which are the same across the Union; several acts state that Member States shall not impede complying products (Regulation (EU) 2017/1369 Article 7(1); Regulation (EU) 2020/740 Article 11(1)). What changes are the language and national rules for aspects that are not harmonised."
    },
    {
      "q": "Is English accepted everywhere?",
      "a": "Only where the Member State determines that consumers easily understand it. The language is set by the Member State where the product is made available (GPSR Article 9(7))."
    },
    {
      "q": "What does mutual recognition cover?",
      "a": "Goods of any type lawfully marketed in another Member State, where the destination country's authority applies a national technical rule on an aspect not harmonised at Union level (Regulation (EU) 2019/515 Article 2(1) and (2))."
    },
    {
      "q": "Where do we find the national rules?",
      "a": "Each Member State maintains Product Contact Points that provide online information on mutual recognition and the competent authorities, and on request the national technical rules for specific goods (Regulation (EU) 2019/515 Article 9(1)–(3))."
    },
    {
      "q": "Do we need a new EU responsible person for the new country?",
      "a": "The GPSR requires an economic operator established in the Union for the product (GPSR Article 16(1)); it does not ask for one per Member State."
    }
  ],
  "sources": [
    {
      "title": "Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1020-20260812",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2019/515 on the mutual recognition of goods lawfully marketed in another Member State",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R0515",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2025/40 on packaging and packaging waste",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0040",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EC) No 1223/2009 on cosmetic products (consolidated text of 18 May 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02009R1223-20260518",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2017/1369 setting a framework for energy labelling (consolidated text of 1 May 2021)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02017R1369-20210501",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2020/740 on the labelling of tyres with respect to fuel efficiency and other parameters",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0740",
      "accessed": "2026-10-04"
    }
  ],
  "related": [
    "language-requirements",
    "epr-registration-country",
    "sell-in-europe",
    "weee-several-countries",
    "recall-in-several-countries"
  ],
  "reviewer": "Conphora compliance team",
  "reviewedAt": "2026-10-04",
  "notice": "General information, not legal advice."
}