--- title: "We buy on a sourcing platform and resell in the EU" description: "Buying from a business-to-business sourcing platform does not change who carries the duties. If you bring the goods into the EU and sell them, you are the importer; under your own brand, the manufacturer (GPSR Articles 3(10) and 13(1)). Listing photos and certificates are not evidence. Identify the real manufacturer, check Safety Gate, get the manufacturer's documentation and test a sample before you list." type: "problem" url: "https://www.conphora.com/solutions/problem/sourcing-platform-products/" markdown: "https://www.conphora.com/solutions/problem/sourcing-platform-products.md" locale: "en" language: "en" updated: "2026-10-04" author: "Conphora compliance team" publisher: "Conphora" source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529" tags: ["GPSR", "REACH", "suppliers-imports"] license: "Free to quote with attribution and a link to the page" --- # We buy on a sourcing platform and resell in the EU Buying from a business-to-business sourcing platform does not change who carries the duties. If you bring the goods into the EU and sell them, you are the importer; under your own brand, the manufacturer (GPSR Articles 3(10) and 13(1)). Listing photos and certificates are not evidence. Identify the real manufacturer, check Safety Gate, get the manufacturer's documentation and test a sample before you list. ## Why this happens Where you found the supplier does not change your role. Under the General Product Safety Regulation (EU) 2023/988, the importer is any natural or legal person established in the Union who places a product from a third country on the Union market (Article 3(10)), and a person who places a product on the market under its own name or trademark is deemed the manufacturer (Article 13(1)). A business that orders stock through a sourcing platform, receives it in the EU and sells it is therefore usually the importer, or the manufacturer if the product carries its brand. The Commission's Blue Guide adds that whoever places on the Union market a product not designed or manufactured for the Union market must assume the role of the manufacturer (section 3.1). [1] [6] As importer, you must ensure before placing the product that it meets the general safety requirement and that the manufacturer has drawn up the risk analysis and technical documentation, marked the product with an identifier and given its name and addresses (Article 11(1)). Where you have reason to believe the product does not conform, you may not place it until it does (Article 11(2)). You keep a copy of the technical documentation for 10 years (Article 11(6)). For products under a CE act, the act's own importer article applies instead of the GPSR's (Article 2(1), third subparagraph, point (b)); under the Low Voltage Directive, for example, the importer checks the conformity assessment, the technical documentation and the CE marking (Directive 2014/35/EU, Article 8(2)). [1] [5] Selling online adds information duties that apply to all these products. An offer made online is deemed to make the product available on the market if it targets consumers in the Union (GPSR Article 4), and the offer must show the manufacturer, the EU responsible person where the manufacturer is outside the Union, the product's picture and identifier, and its warnings and safety information (Article 19). [1] Safety Gate shows why the checks matter for this channel: the Commission's portal publishes alerts on dangerous non-food products found by authorities. Chemicals are one recurring theme. REACH forbids placing on the market an article containing a substance in breach of an Annex XVII restriction (Regulation (EC) No 1907/2006, Article 67(1)). At the border, customs suspend the release of products that lack documentation or marking, or that may present a serious risk (Regulation (EU) 2019/1020, Article 26(1)). [2] [3] [4] ## How to solve it 1. **Identify the real manufacturer** Sellers on sourcing platforms are often trading companies, not factories. You need the manufacturer's name and addresses for the label and for every online offer, and you need someone who can produce the technical documentation. Ask who makes the product and where, and get it in writing before the first order. 2. **Work out which rules apply to the product** Start from what the product is and who uses it: a toy, an electrical product, a cosmetic or a general consumer product each have their own rules. A first indicative check shows which acts are likely to apply and what documentation they need. 3. **Search Safety Gate for the same kind of product** The Commission's Safety Gate portal publishes alerts on dangerous non-food products found on the EU market. Search for your product type to see which hazards authorities keep finding, such as small parts, overheating or restricted chemicals, and ask the supplier how its product avoids them. 4. **Ask for the manufacturer's file, not the listing** A listing badge or a certificate image is not documentation. Ask for the technical documentation with the risk analysis, the test reports for your model and, for CE products, the EU declaration of conformity. Where chemicals are a known hazard, ask for test results against the REACH restrictions that apply to the product. 5. **Test a sample before you list** Order a pre-shipment sample from the production run and have the critical hazards tested. If the result or the documentation leaves reason to doubt the product, it may not be placed on the market until it is brought into conformity. 6. **Build the offer with the mandatory information** Your online offer must show the manufacturer's name and postal and electronic address, the responsible person in the EU where the manufacturer is outside it, a picture and identifier of the product, and its warnings and safety information in the language of the country you sell to. ## What you need to show - **Manufacturer's identity, address and production site** — The supplier, confirmed in writing (GPSR Articles 9(6), 15(3) and 19(a)) - **Technical documentation and test reports for your model** — The manufacturer, with a copy kept by you (GPSR Articles 9(2) and 11(6)) - **Your pre-shipment test report** — Your laboratory (GPSR Article 11(1) and (2)) - **The online offer with the mandatory information** — Your webshop or marketplace listing (GPSR Article 19) ## If you do nothing - **The product turns up on Safety Gate** — Where an importer has reason to believe a product it placed is dangerous, it must ensure corrective measures, including withdrawal or recall, inform consumers and notify the authorities through the Safety Business Gateway (GPSR Article 11(8)). - **Customs stop the goods** — Release for free circulation is suspended where the product lacks the required documentation, marking or labelling, or there is cause to believe it does not comply or presents a serious risk (Regulation (EU) 2019/1020, Article 26(1)). - **Restricted substances make the product unlawful** — A substance in an article for which REACH Annex XVII contains a restriction may not be placed on the market unless it complies with the conditions of that restriction (REACH Article 67(1)). ## Questions ### The listing says 'CE certified'. Is that enough? No. The importer must ensure that the manufacturer drew up the technical documentation (GPSR Article 11(1)) or, for CE products, carried out the conformity assessment and drew up the documentation (for example LVD Article 8(2)). A claim on a listing is not that documentation. ### Is the sourcing platform responsible for the product? The GPSR's duties for online marketplaces concern platforms that let consumers conclude distance contracts with traders (Article 3(14)), and so do the Digital Services Act's trader-traceability rules (Regulation (EU) 2022/2065, Article 30). A platform where only businesses buy from businesses does not appear to fit those definitions, so the duties stay with you as importer or manufacturer. ### The supplier ships straight to our customers. Are we still the importer? That is a dropshipping set-up, and the answer depends on who places the product on the market. In every case, a product covered by the GPSR may not be placed on the market unless an economic operator established in the Union is responsible for it (Article 16(1)). ### Do we have REACH duties as well? Possibly. Importers of articles register substances intended to be released, and notify Candidate List substances of very high concern above 0.1 % weight by weight, where the quantity exceeds one tonne per year (REACH Article 7(1) and (2)). Whatever the quantity, a supplier of an article with a Candidate List substance above 0.1 % must give recipients the information needed for safe use, at least the substance name (Article 33). ## Regulations involved GPSR, REACH ## 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. [Safety Gate: the EU rapid alert system for dangerous non-food products](https://ec.europa.eu/safety-gate/) — European Commission, 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. [Regulation (EC) No 1907/2006 (REACH), consolidated text of 22 June 2026](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02006R1907-20260622) — EUR-Lex, 2026-10-04 5. [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 6. [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 7. [Regulation (EU) 2022/2065 on a Single Market for Digital Services (Digital Services Act)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022R2065) — EUR-Lex, 2026-10-04