# /news-insights/gpsr-dac7-18-months-marketplace-enforcement-review  —  GPSR and DAC7, 18 months in: what marketplaces are actually enforcing
# https://o1.eu/news-insights/gpsr-dac7-18-months-marketplace-enforcement-review
# Operator One — Merchant of Record for European marketplaces.

## Metadata
- Canonical URL: https://o1.eu/news-insights/gpsr-dac7-18-months-marketplace-enforcement-review
- Published: 2026-05-22
- Updated: 2026-09-13
- Publisher: Operator One (https://o1.eu)

## Summary
GPSR has applied since 13 December 2024 and DAC7 reports fall due each 31 January. What EU marketplaces now block at upload, and who carries each duty.

## Full article
By Operator One Editorial — 22 May 2026

## Key takeaways

- GPSR, Regulation (EU) 2023/988, has applied in all EU member states since 13 December 2024, and its Article 16(1) bars a product from being placed on the EU market unless an economic operator established in the Union is responsible for it.
- GPSR Article 22 gives an online marketplace two working days to act on a market surveillance authority's order and three working days to process a product safety notice, and Article 22(11) requires it to suspend traders that frequently offer non-compliant products.
- DAC7, Council Directive (EU) 2021/514, has applied since 1 January 2023: platforms must complete seller due diligence by 31 December of the reportable period and report to the tax authority by 31 January of the following year.
- Under DAC7 Annex V, a seller that has not supplied its tax data after two reminders and at least 60 days must have its account closed and re-registration blocked, or its payouts withheld until it provides the information.
- Many trader-identity suspensions come from Article 30 of the Digital Services Act, Regulation (EU) 2022/2065, applicable since 17 February 2024, not from GPSR or DAC7.
- From 12 August 2026 the Packaging and Packaging Waste Regulation (EU) 2025/40 requires platforms to collect packaging EPR registration data before a producer may sell to consumers in a member state.

Two pieces of EU legislation reshaped what marketplaces must verify about the sellers and products they host: the General Product Safety Regulation (GPSR, Regulation (EU) 2023/988, applicable from 13 December 2024 under its Article 52) and DAC7 (Council Directive (EU) 2021/514, applicable in member states from 1 January 2023, with first reports for 2023 activity due by 31 January 2024).

A third instrument sits alongside both and explains many account suspensions: the Digital Services Act (DSA, Regulation (EU) 2022/2065), whose trader traceability rules in Article 30 have applied since 17 February 2024. Here is what the law requires marketplaces to enforce, and what Operator One sees on the operational floor.

## GPSR: the responsible person requirement is being enforced

Article 16(1) of GPSR provides that a consumer product in scope may not be placed on the EU market unless an economic operator established in the Union is responsible for the tasks set out in Article 4(3) of the Market Surveillance Regulation (EU) 2019/1020. Under Article 4(2) of that regulation, the responsible operator is an EU manufacturer, the importer where the manufacturer is not established in the EU, an authorised representative holding a written mandate, or an EU fulfilment service provider for the products it handles where none of the others is established in the Union.

GPSR Article 16(3) requires that operator's name, registered trade name or registered trade mark, and contact details including postal and electronic address, to appear on the product, its packaging, the parcel or an accompanying document. Under GPSR Article 16(2) the responsible person must also, where appropriate with regard to the possible risks, regularly check that the product complies with the manufacturer's technical documentation under Article 9(2), and provide documented evidence of those checks on request of a market surveillance authority.

For products covered by EU harmonisation legislation, such as radio equipment under Directive 2014/53/EU, GPSR Chapter III, Section 1, which contains Article 16, does not apply (GPSR Article 2(1)); Article 4 of Regulation (EU) 2019/1020 applies instead, together with the importer obligations in the relevant sector directive. GPSR Article 19 on distance sales still applies to those products.

What GPSR requires of the marketplaces themselves:

- GPSR Article 19: every distance-selling offer must show the manufacturer's name and postal and electronic address, the responsible person's details where the manufacturer is not established in the EU, product identification including a picture, and any warning or safety information.
- GPSR Article 22(9): marketplaces must design their interface so traders can enter that information for each product and consumers can see it on the listing.
- GPSR Article 22(4): marketplaces must act on a market surveillance authority's order to remove or disable an offer of a dangerous product within two working days.
- GPSR Article 22(8): marketplaces must process product safety notices within three working days.
- GPSR Article 22(11): marketplaces must, after a prior warning, suspend for a reasonable period traders that frequently offer non-compliant products.

In Operator One's experience, the practical result is that EU marketplaces increasingly ask for responsible-person and manufacturer details when a listing is created, rather than waiting for a complaint or an authority order.

## DAC7: the data is being collected and reported

DAC7 makes digital platform operators mandatory tax-data reporters. Under Annex V of Council Directive (EU) 2021/514, a reporting platform must collect each seller's identification data, including name, address, Tax Identification Number (TIN), VAT number where available and business registration number, and report it together with the financial account identifier, the total consideration paid or credited in each quarter, the number of relevant activities, and fees, commissions or taxes withheld in each quarter.

DAC7 Annex V, Section II requires due diligence to be completed by 31 December of the reportable period. Section III requires the report to reach the competent tax authority no later than 31 January of the following year, and the same information must be given to the seller by that date. The first reports, for 2023 activity, were due by 31 January 2024; reports for 2025 activity were due by 31 January 2026.

DAC7 does not reach every account. An Excluded Seller of goods is one for which the platform facilitated fewer than 30 sales and paid or credited no more than EUR 2,000 of consideration in the reportable period; both conditions must be met. Almost any commercial brand account exceeds those limits and is therefore reported.

The enforcement lever is in DAC7 Annex V, Section IV: where a seller does not provide the required information after two reminders, and not before 60 days have passed, the platform must close the seller's account and prevent re-registration, or withhold payment of the consideration until the information is provided.

## What is being suspended

In Operator One's operational experience across EU marketplaces, the most frequent compliance-driven reasons for listing or account suspension, each with its legal hook, are:

- Missing or unverifiable EU responsible person on a product from a manufacturer outside the EU (GPSR Article 16, Regulation (EU) 2019/1020 Article 4).
- Incomplete, inaccurate or inconsistent trader identity, such as a legal name that does not match registration documents (DSA Article 30(3)).
- Missing or invalid TIN or other DAC7 identification data after the platform's reminders (DAC7 Annex V, Section IV).
- Inability to produce, on request, the manufacturer's technical documentation (GPSR Article 9(2)) or, for CE-marked products, the manufacturer's EU Declaration of Conformity.
- Listings in regulated categories such as toys, cosmetics and electrical equipment where the required product safety information cannot be linked to the offer (GPSR Article 19).

## Looking forward

Three further changes are now in force or close. First, Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) has applied since 12 August 2026: Article 45(3) requires a producer that makes packaging or packaged products available for the first time directly to end users in a member state other than the one where it is established to appoint, by written mandate, an authorised representative for extended producer responsibility in that member state, and Article 45(4) requires online platforms to obtain the producer's packaging EPR registration information for the consumer's member state before allowing it to sell.

Second, Council Regulation (EU) 2026/382 removed the EU customs duty relief for low-value consignments: from 1 July 2026 until 1 July 2028, a temporary flat customs duty of EUR 3 per item applies to consignments valued up to EUR 150 imported from outside the EU, according to the European Commission.

Third, the first Digital Product Passport obligation applies from 18 February 2027 under Article 77 of the Batteries Regulation (EU) 2023/1542, for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries. Passports for other product groups will follow through delegated acts under the Ecodesign for Sustainable Products Regulation (EU) 2024/1781. We covered the implications in our April note (https://o1.eu/news-insights/eu-digital-product-passport-2027-battery-rollout).

## How to prepare a marketplace account, step by step

- Map the responsible person per product. For each product sold into the EU, identify the economic operator established in the Union under GPSR Article 16 and Regulation (EU) 2019/1020 Article 4(2): EU manufacturer, importer, authorised representative or fulfilment service provider.
- Put the contact details on product and listing. Show the responsible person's name, postal address and electronic address on the product, packaging, parcel or accompanying document (GPSR Article 16(3)), and enter the GPSR Article 19 information in the marketplace listing fields.
- Keep the documentation retrievable. Make sure the manufacturer's technical documentation (GPSR Article 9(2)) and, for CE-marked products, the manufacturer's EU Declaration of Conformity can be produced on request from a market surveillance authority or marketplace.
- Complete trader verification. Supply and keep current the Digital Services Act Article 30 data: legal name, address, telephone, email, identification document, payment account, trade register number and self-certification.
- Answer DAC7 requests before the 60-day limit. Provide TIN, VAT number, business registration number and address when the platform asks, so due diligence closes by 31 December and DAC7 Annex V Section IV account closure or payment withholding is avoided.
- Register packaging EPR in each destination country. Since 12 August 2026, supply packaging EPR registration data per member state under PPWR (EU) 2025/40 Article 45(4), and appoint an authorised representative for EPR where Article 45(3) requires one.

## Frequently asked questions

### Do I need an EU responsible person to sell on Amazon or bol.com under GPSR?

Yes, for consumer products in scope. GPSR, Regulation (EU) 2023/988, has applied since 13 December 2024, and Article 16(1) says a product cannot be placed on the EU market unless an economic operator established in the Union is responsible for it. Through Article 4(2) of Regulation (EU) 2019/1020 that operator is an EU manufacturer, an importer, an authorised representative with a written mandate, or an EU fulfilment service provider where none of the others exists.

### Which GPSR article covers the responsible person: Article 4 or Article 16?

Article 16. In Regulation (EU) 2023/988, Article 16 is headed "Responsible person for products placed on the Union market", while Article 4 is headed "Distance sales". The confusion comes from Article 16(1), which refers to the tasks in Article 4(3) of Regulation (EU) 2019/1020, the EU market surveillance regulation. Cite GPSR Article 16 when a marketplace or an authority asks for the legal basis.

### What happens if I ignore GPSR and DAC7 obligations on EU marketplaces?

Listings come down and payouts can stop. GPSR Article 22(4) obliges an EU online marketplace to act on a market surveillance authority's removal order within two working days, and Article 22(11) requires it to suspend traders that frequently offer non-compliant products. Under DAC7 Annex V, Section IV, a platform still lacking a seller's tax data after two reminders and 60 days must close the account and block re-registration, or withhold the consideration.

### Who is the responsible person when a Merchant of Record is the seller?

Where a Merchant of Record imports the goods into the EU, it is the EU importer as a legal consequence and therefore the responsible economic operator under Regulation (EU) 2019/1020 Article 4(2) and GPSR Article 16. Its name and postal and electronic address go on the product or packaging. CE marking, conformity assessment, technical documentation and the EU Declaration of Conformity remain the manufacturer's obligations under Regulation (EC) 765/2008 and GPSR Article 9.

### What is the DAC7 reporting deadline, and what data goes to the tax authority?

Under Council Directive (EU) 2021/514, platforms must complete due diligence by 31 December of the reportable period and report by 31 January of the following year. Annex V requires the seller's identification data collected under Section II, the financial account identifier where available, each member state of residence, total consideration per quarter with the number of relevant activities, and fees, commissions or taxes withheld per quarter. Sellers receive the same figures by 31 January.

### Is my small seller account exempt from DAC7 reporting?

Only if both thresholds hold. Council Directive (EU) 2021/514 defines an Excluded Seller of goods as one for which the platform facilitated fewer than 30 sales and paid or credited total consideration of no more than EUR 2,000 during the reportable period. Cross either limit on a single EU platform and the account is reportable. Governmental entities and listed entities are also excluded under the same DAC7 definition.

### Why did my EU marketplace account get suspended for missing trader information?

Often the legal basis is the Digital Services Act, not GPSR. Regulation (EU) 2022/2065 has applied since 17 February 2024, and Article 30 requires marketplaces to obtain a trader's name, address, telephone number, email, identification document, payment account details, trade register number and a compliance self-certification before the trader may sell to EU consumers. Under Article 30(3), if the trader does not correct inaccurate or incomplete data, the platform must swiftly suspend it.

### What must a product listing show under GPSR in Germany or the Netherlands?

The same minimum everywhere in the EU. GPSR Article 19 requires every distance-selling offer, whether on Amazon.de in Germany or bol.com in the Netherlands, to show the manufacturer's name with postal and electronic address, the responsible person's details where the manufacturer is not established in the Union, product identification including a picture, type and identifier, and any warning or safety information. Article 22(9) obliges marketplaces to provide the fields for this.

### When does the Digital Product Passport start, and does it apply to my products?

The first binding date is 18 February 2027, and it applies to batteries, not to all products. Article 77 of the Batteries Regulation (EU) 2023/1542 requires a battery passport for each LMT battery, each industrial battery above 2 kWh and each electric vehicle battery placed on the EU market from that date. Other product groups follow later through delegated acts under the Ecodesign for Sustainable Products Regulation (EU) 2024/1781.

## Where a Merchant of Record carries the obligation

Where a Merchant of Record (https://o1.eu/merchant-of-record) such as Operator One is the legal seller and imports goods into the EU, it is the EU importer as a legal consequence, which makes it the responsible economic operator under Regulation (EU) 2019/1020 Article 4(2) and GPSR Article 16. As importer it verifies that the manufacturer's technical documentation and, where applicable, EU Declaration of Conformity exist, adds its own name and postal address, makes the documentation available to authorities and runs corrective action. CE marking, conformity assessment, the technical file and the Declaration of Conformity remain with the manufacturer under Regulation (EC) 765/2008 Article 30(1). DAC7 reports are filed by the platform operator and cover the seller account holder that receives the consideration. Listings show the client as Brand and Operator One as the seller. Packaging EPR registration remains per country and per stream. Definitions are in our compliance glossary (https://o1.eu/compliance-glossary).

Sources: GPSR, Regulation (EU) 2023/988 (https://eur-lex.europa.eu/eli/reg/2023/988/oj/eng); DAC7, Council Directive (EU) 2021/514 (https://eur-lex.europa.eu/eli/dir/2021/514/oj/eng); Digital Services Act, Regulation (EU) 2022/2065 (https://eur-lex.europa.eu/eli/reg/2022/2065/oj/eng); Market Surveillance Regulation (EU) 2019/1020 (https://eur-lex.europa.eu/eli/reg/2019/1020/oj/eng); Batteries Regulation (EU) 2023/1542 (https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng); European Commission, Digital Batteries Passport guidance (21 August 2026) (https://single-market-economy.ec.europa.eu/news/guidance-support-preparations-digital-batteries-passport-2026-08-21_en); PPWR, Regulation (EU) 2025/40 (https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng); European Commission, temporary flat fee on low-value imports (https://taxation-customs.ec.europa.eu/news/guidance-and-legal-text-temporary-flat-fee-low-value-imports-which-will-apply-until-1-july-2028-2026-06-08_en); European Commission, DAC7 overview (https://taxation-customs.ec.europa.eu/taxation/tax-transparency-cooperation/administrative-co-operation-and-mutual-assistance/dac7_en).

## FAQ (structured)
Q: Do I need an EU responsible person to sell on Amazon or bol.com under GPSR?
A: Yes, for consumer products in scope. GPSR, Regulation (EU) 2023/988, has applied since 13 December 2024, and Article 16(1) says a product cannot be placed on the EU market unless an economic operator established in the Union is responsible for it. Through Article 4(2) of Regulation (EU) 2019/1020 that operator is an EU manufacturer, an importer, an authorised representative with a written mandate, or an EU fulfilment service provider where none of the others exists.

Q: Which GPSR article covers the responsible person: Article 4 or Article 16?
A: Article 16. In Regulation (EU) 2023/988, Article 16 is headed "Responsible person for products placed on the Union market", while Article 4 is headed "Distance sales". The confusion comes from Article 16(1), which refers to the tasks in Article 4(3) of Regulation (EU) 2019/1020, the EU market surveillance regulation. Cite GPSR Article 16 when a marketplace or an authority asks for the legal basis.

Q: What happens if I ignore GPSR and DAC7 obligations on EU marketplaces?
A: Listings come down and payouts can stop. GPSR Article 22(4) obliges an EU online marketplace to act on a market surveillance authority's removal order within two working days, and Article 22(11) requires it to suspend traders that frequently offer non-compliant products. Under DAC7 Annex V, Section IV, a platform still lacking a seller's tax data after two reminders and 60 days must close the account and block re-registration, or withhold the consideration.

Q: Who is the responsible person when a Merchant of Record is the seller?
A: Where a Merchant of Record imports the goods into the EU, it is the EU importer as a legal consequence and therefore the responsible economic operator under Regulation (EU) 2019/1020 Article 4(2) and GPSR Article 16. Its name and postal and electronic address go on the product or packaging. CE marking, conformity assessment, technical documentation and the EU Declaration of Conformity remain the manufacturer's obligations under Regulation (EC) 765/2008 and GPSR Article 9.

Q: What is the DAC7 reporting deadline, and what data goes to the tax authority?
A: Under Council Directive (EU) 2021/514, platforms must complete due diligence by 31 December of the reportable period and report by 31 January of the following year. Annex V requires the seller's identification data collected under Section II, the financial account identifier where available, each member state of residence, total consideration per quarter with the number of relevant activities, and fees, commissions or taxes withheld per quarter. Sellers receive the same figures by 31 January.

Q: Is my small seller account exempt from DAC7 reporting?
A: Only if both thresholds hold. Council Directive (EU) 2021/514 defines an Excluded Seller of goods as one for which the platform facilitated fewer than 30 sales and paid or credited total consideration of no more than EUR 2,000 during the reportable period. Cross either limit on a single EU platform and the account is reportable. Governmental entities and listed entities are also excluded under the same DAC7 definition.

Q: Why did my EU marketplace account get suspended for missing trader information?
A: Often the legal basis is the Digital Services Act, not GPSR. Regulation (EU) 2022/2065 has applied since 17 February 2024, and Article 30 requires marketplaces to obtain a trader's name, address, telephone number, email, identification document, payment account details, trade register number and a compliance self-certification before the trader may sell to EU consumers. Under Article 30(3), if the trader does not correct inaccurate or incomplete data, the platform must swiftly suspend it.

Q: What must a product listing show under GPSR in Germany or the Netherlands?
A: The same minimum everywhere in the EU. GPSR Article 19 requires every distance-selling offer, whether on Amazon.de in Germany or bol.com in the Netherlands, to show the manufacturer's name with postal and electronic address, the responsible person's details where the manufacturer is not established in the Union, product identification including a picture, type and identifier, and any warning or safety information. Article 22(9) obliges marketplaces to provide the fields for this.

Q: When does the Digital Product Passport start, and does it apply to my products?
A: The first binding date is 18 February 2027, and it applies to batteries, not to all products. Article 77 of the Batteries Regulation (EU) 2023/1542 requires a battery passport for each LMT battery, each industrial battery above 2 kWh and each electric vehicle battery placed on the EU market from that date. Other product groups follow later through delegated acts under the Ecodesign for Sustainable Products Regulation (EU) 2024/1781.

## Steps (structured)
1. Map the responsible person per product: For each product sold into the EU, identify the economic operator established in the Union under GPSR Article 16 and Regulation (EU) 2019/1020 Article 4(2): EU manufacturer, importer, authorised representative or fulfilment service provider.
2. Put the contact details on product and listing: Show the responsible person's name, postal address and electronic address on the product, packaging, parcel or accompanying document (GPSR Article 16(3)), and enter the GPSR Article 19 information in the marketplace listing fields.
3. Keep the documentation retrievable: Make sure the manufacturer's technical documentation (GPSR Article 9(2)) and, for CE-marked products, the manufacturer's EU Declaration of Conformity can be produced on request from a market surveillance authority or marketplace.
4. Complete trader verification: Supply and keep current the Digital Services Act Article 30 data: legal name, address, telephone, email, identification document, payment account, trade register number and self-certification.
5. Answer DAC7 requests before the 60-day limit: Provide TIN, VAT number, business registration number and address when the platform asks, so due diligence closes by 31 December and DAC7 Annex V Section IV account closure or payment withholding is avoided.
6. Register packaging EPR in each destination country: Since 12 August 2026, supply packaging EPR registration data per member state under PPWR (EU) 2025/40 Article 45(4), and appoint an authorised representative for EPR where Article 45(3) requires one.