EU + UK marketplace compliance, plainly explained

The EU VAT e-commerce package replaced the previous distance-selling thresholds (which differed by country) with a single €10,000 EU-wide threshold for cross-border B2C goods and digital services. ^[4]

Three OSS schemes exist: - Union OSS — EU-established businesses report all cross-border B2C EU sales in one return, filed in their country of establishment. - Non-Union OSS — non-EU businesses providing services (not goods) to EU consumers. - Import OSS (IOSS) — distance sales of imported goods up to €150, exempt from import VAT at the border but subject to destination-rate VAT collected at point of sale.

Without OSS, a seller shipping into Germany, France, Italy, Spain and the Netherlands needs five separate VAT registrations and five sets of quarterly returns plus annual recap statements. With OSS, one quarterly return covers all 27.

OSS does NOT replace local VAT registration for B2B sales, for goods stored locally (e.g. Amazon FBA / Pan-EU), or for marketplaces operating as deemed supplier. Pan-EU FBA still triggers VAT registration in every storage country.

Under a Merchant of Record arrangement, the MoR is the seller of record on the marketplace. It issues the invoice, collects the VAT and files the OSS return. The brand never appears on the VAT chain.

GPSR replaced the 2001 General Product Safety Directive (GPSD) and is the catch-all consumer-safety baseline for any product NOT covered by a sector-specific regulation (toys, cosmetics, machinery, electrical, etc. each have their own). ^[1]

What every product needs on the listing, package or in accompanying documents: - Manufacturer name, postal address and electronic address (email or webform URL) - EU Responsible Person name + postal address + email (mandatory for non-EU manufacturers) - A product identifier (model number, batch code or serial number) - Safety warnings + instructions in the local language(s) of every member state where the product is sold

Marketplace co-liability (Art. 22 + DSA Art. 30): marketplaces are now required to design their seller-onboarding flows to capture and verify Responsible Person data BEFORE a listing can go live. Sellers without an RP are blocked at the offer-creation step. ^[7]

Operator One holds Authorised Representative / Responsible Person status for client product categories under the MoR arrangement — the brand never needs to set up an EU entity to satisfy GPSR.

EPR is the single most fragmented compliance domain in EU e-commerce. There is no single EU "EPR registration" — each member state runs its own scheme, each scheme is split into streams (packaging / batteries / WEEE / textiles / furniture / tyres / oils), and each stream has its own producer-responsibility organisation (PRO), portal, fee structure and reporting cadence. ^[8]

The four EPR streams that hit every consumer-goods brand: - Packaging — primary, secondary, tertiary packaging weight per material (plastic, paper, glass, metal, wood). Fees range from ~€0.10/kg (paper) to ~€1.20/kg (problematic plastics). Eco-modulated: easier-to-recycle = cheaper. - Batteries — every battery sold separately OR included with a product (e.g. a remote with batteries). Covers portable, industrial and EV. The Battery Regulation 2023/1542 supersedes the old Directive from August 2025. ^[6] - WEEE (electrical & electronic equipment) — anything that plugs in, runs on a battery or contains electronics. Six product categories. - Textiles, footwear & household linen — Refashion in France since 2007, expanding to Spain, Netherlands and Italy from 2025 onwards under the EU Waste Framework Directive revision.

The PPWR harmonisation (Reg. 2025/40, applying 12 August 2026): packaging EPR will move to a common EU registry framework with eco-modulated fees and harmonised labelling. National PROs remain, but the data definitions, recyclability assessment and marketplace-verification obligation become EU-wide and uniform. ^[29]

See the per-country specifics section below for FR, DE, ES, IT, AT, NL, BE, PL, PT, CZ and SE.

The Ecodesign for Sustainable Products Regulation (ESPR, EU 2024/1781) is the legal scaffolding for product-by-product sustainability requirements across the EU. The Digital Product Passport (DPP) is its principal enforcement mechanism. ^[5]

What a DPP carries (varies per product group, but the common core): - Unique product identifier + batch / serial number - Material composition (substances of concern, recycled content %, critical raw materials) - Carbon footprint across the life cycle - Repairability score, availability of spare parts, end-of-life instructions - Compliance documentation (declarations of conformity, test reports) - Supply-chain due-diligence data (under CSDDD where applicable)

Rollout timing (most likely sequence, per the ESPR Working Plan 2025-2030): - 18 Feb 2027 — Batteries ≥2 kWh (EV, industrial, light-transport-vehicle batteries). First binding deadline. ^[6] - 2027-2028 — Textiles, footwear, furniture, electronics (consumer & professional) - 2028-2030 — Tyres, detergents, paints, chemicals; iron, steel, aluminium intermediates; remaining ICT hardware ^[30]

For marketplace sellers: the DPP carrier (QR code, RFID, NFC) must be visible on the product or its packaging AND accessible via the marketplace listing. Marketplaces will be required to check existence + content validity before publishing the offer. ^[5]

This sits on top of, not instead of, GPSR + CE marking + EPR. A toaster sold in the EU in 2028 will need: CE mark, GPSR Responsible Person, packaging EPR + WEEE + battery EPR registrations, and a Digital Product Passport.

DAC7 is part of the EU's automatic exchange of tax information (AEoI) regime. It targets the platform economy specifically — Airbnb, Etsy, Amazon, Bol.com, Zalando, eBay, Vinted, Cdiscount, all in scope. ^[2]

Data reported per seller, per year: - Legal name, registered address, date of birth (individuals) - Tax Identification Number (TIN) + VAT number, country of residence - IBAN of the account where proceeds are paid - Quarterly totals: number of transactions + total consideration paid - Permanent establishment country for legal entities

Member states automatically exchange this data so that one EU tax authority sees a seller's full pan-EU platform revenue.

Under a Merchant of Record arrangement, it is the MoR (not the brand) that appears as the seller on the marketplace, so it is the MoR's data that flows through DAC7. Brands carry zero DAC7 exposure: their name, TIN, bank details and revenue never enter the marketplace's reporting feed.

This matters for two reasons: (1) confidentiality — brands often don't want their pan-EU marketplace revenue inventoried by every EU tax authority; (2) administrative load — DAC7 reporting accuracy is the marketplace's problem, but discrepancies trigger seller-side tax-authority enquiries.

CE marking is required for ~30 EU directive categories — toys, electronics, machinery, EMC, radio, PPE, pressure vessels, medical devices, in-vitro diagnostics, and so on. It signifies that the manufacturer (or their EU Authorised Representative) has prepared a Declaration of Conformity, holds technical documentation, and has carried out the conformity assessment required by the applicable directive.

Non-EU manufacturers must appoint an EU-based Authorised Representative named on the Declaration of Conformity. Marketplaces increasingly require the AR details in seller account profiles.

UKCA — the 2026 reality: Post-Brexit, the UK introduced UKCA marking as the GB equivalent. After several delays and an industry pushback on testing capacity, the UK government announced (August 2023) indefinite recognition of CE marking in Great Britain — enacted via the Product Safety and Metrology etc. (Amendment) Regulations 2024, in force 1 October 2024. ^[26]

This means: - A CE-marked product is accepted in England, Scotland and Wales indefinitely for the 21 product regulations in scope. - Northern Ireland continues to require CE marking (or CE + UKNI for products certified by a UK notified body) under the Windsor Framework. - Medical devices are still under MHRA consultation (closes 10 April 2026); construction products are also pending. - UKCA remains a valid voluntary alternative.

Practical answer for a brand selling on Amazon UK + EU: CE marking covers both. UKCA is no longer worth the parallel paperwork unless you're in one of the still-consulting categories. ^[27]

A Merchant of Record is the entity that takes the seller-side legal position on a marketplace transaction. The MoR: - Issues the VAT invoice to the consumer - Collects and remits VAT to the relevant tax authority (via OSS / local registrations) - Is the named producer for EPR registration in every market - Is the named Responsible Person under GPSR - Is the named Authorised Representative for CE / UKCA where applicable - Is the reported entity under DAC7 - Carries legal responsibility for returns, chargebacks, payment disputes, consumer-protection claims

The brand supplies products and receives net revenue after the MoR has settled VAT, marketplace fees, EPR contributions, fulfilment costs and any compliance overheads.

Why brands choose a MoR over a local entity: - Eliminates 27 country-by-country VAT registrations + OSS filing - Eliminates 27 EPR registrations + monthly/quarterly reporting per scheme - Eliminates DAC7 exposure on the brand's tax filings - Eliminates marketplace-account suspension risk on a single compliance miss - Compresses time-to-launch on a new EU market from 6-12 months (entity + VAT + EPR + GPSR) to days

Operator One has held EU MoR status since 2021, with live VAT registrations in every EU member state plus the UK, EPR memberships across all eleven national schemes documented on this page, and Authorised Representative coverage for CE-regulated categories.

The Importer of Record is the entity legally responsible for the import of goods into the EU customs territory. Responsibilities: - Paying import duty + import VAT (or applying IOSS for shipments ≤€150) - Lodging the customs declaration - Ensuring goods comply with EU product safety requirements at the border (GPSR, CE, EPR registration in destination MS) - Maintaining import documentation (entry summary declaration, customs decisions, certificates of conformity) - Acting as the EU-based contact for customs authorities

For non-EU brands shipping to an EU marketplace fulfilment centre (e.g. Amazon FBA in Germany, Bol.com FBB in the Netherlands), someone must act as IoR at the EU border. Without an EU-registered IoR, shipments are held at customs and either returned at the seller's expense or destroyed after 30 days.

Operator One acts as Importer of Record for all client shipments entering the EU under the MoR arrangement. The IoR and MoR are usually the same entity, though they can be split where the supply chain runs through a third-party logistics provider with its own customs licence.