You import from China into the UK. Can you sell it on into the EU?
You can sell on, but not on your own name alone. Regulation (EU) 2023/988 says a consumer product may not be placed on the Union market unless there is an economic operator established in the Union responsible for it. A British company is not established in the Union, so somebody inside the EU has to hold that role before the goods travel, and their details have to appear with the product.
Selling UK-imported consumer goods on into the EU needs an economic operator established in the Union. Who can hold that role, and why your UK company cannot.
What the rule actually says
The General Product Safety Regulation, Regulation (EU) 2023/988, has applied since 13 December 2024. Article 16(1) is the sentence that catches UK sellers: a product covered by the Regulation shall not be placed on the market unless there is an economic operator established in the Union who is responsible for the tasks set out in Article 4(3) of Regulation (EU) 2019/1020 in respect to that product.
Two words carry the weight. Product, defined in Article 3(1), means any item intended for consumers or likely, under reasonably foreseeable conditions, to be used by consumers even if not intended for them. That is wider than the aisle you think you sell in. Established in the Union means what it says, and a company registered in Great Britain is not.
Article 16(3) then makes the arrangement visible: the name, registered trade name or registered trade mark, and contact details including the postal and electronic address of that operator shall be indicated on the product or on its packaging, the parcel or an accompanying document. So this is not paperwork you can keep in a drawer. It has to be printed somewhere the buyer and the market surveillance authority can both see it.
Who is allowed to be that operator
Article 4(2) of Regulation (EU) 2019/1020 sets out the closed list, and the Regulation on general product safety applies it. There are four kinds of party and no fifth.
Read the table as a ranking of your realistic options rather than a menu. If your factory will not appoint an authorised representative, and you do not want to set up in the Union yourself, then whoever imports the goods into the Union becomes the responsible operator, and that is your EU customer.
| Who | When it applies | What it costs you |
|---|---|---|
| A manufacturer established in the Union | Not your case if the goods are made in China | Unavailable |
| An importer, where the manufacturer is not established in the Union | Whoever brings the goods into the Union | Usually your EU customer, who then holds the obligations and the relationship |
| An authorised representative with a written mandate from the manufacturer | Where the Chinese manufacturer will sign a mandate | A mandate you have to get out of your factory, plus the representative's fee |
| A fulfilment service provider established in the Union | Only where none of the above is established in the Union | A warehouse arrangement inside the EU for the goods it handles |
What the role actually involves
Article 4(3) of Regulation (EU) 2019/1020 lists the tasks: verifying that the declaration of conformity and technical documentation have been drawn up, keeping them available to market surveillance authorities, answering a reasoned request from an authority with the information needed to demonstrate conformity, informing authorities where there is reason to believe a product presents a risk, and cooperating on corrective action.
Article 16(2) of the general product safety Regulation adds a standing duty. The operator has to check regularly that the product still complies with its technical documentation and with the requirements in Article 9, and to provide documented evidence of those checks when asked.
That is the part worth reading twice before you offer the job to somebody as a favour. It is not a forwarding address. It is a continuing obligation with an evidence trail attached, and whoever accepts it has taken on work that has to be done whether or not anyone ever asks.
Where this leaves you, said plainly
A UK sourcing agent cannot be your responsible person, and that includes us. We are not established in the Union and neither is your Chinese factory, so the role has to sit with a party inside the EU. If we told you otherwise we would be selling you an address rather than a service.
The cheapest route is usually to sell to an EU business that imports the goods and becomes the responsible operator by doing so, which also means handing that customer relationship to somebody else. That is a commercial cost, not a compliance one, and it is the real reason most small UK importers stop at the Channel.
Great Britain did not adopt this Regulation, so none of it changes what you have to do to sell the same goods at home. GOV.UK sets out the separate question of conformity marking for the EU market. The Northern Ireland position rests on different arrangements again and we do not set it out here. If you sell there, ask the Office for Product Safety and Standards rather than reading across from this page.
Before any of this matters, the goods have to be right. Our guide on CE and UKCA certification covers what a factory has to give you, and none of that documentation gets easier to obtain after the container has sailed.
Frequently asked questions
Can my Chinese factory be the responsible person?
Not directly. Article 4(2) of Regulation (EU) 2019/1020 requires the operator to be established in the Union, and a Chinese manufacturer is not. The factory can sign a written mandate appointing an authorised representative inside the EU, which is the route that keeps the role out of your customer's hands, but the mandate has to come from the manufacturer.
Does this apply to business-to-business sales?
The test is the product, not your customer. Article 3(1) defines a product as any item intended for consumers or likely, under reasonably foreseeable conditions, to be used by consumers even if not intended for them. Goods sold business to business that end up in consumer hands are caught by that wording.
What has to be printed on the product?
Article 16(3) requires the name, registered trade name or registered trade mark, and contact details including postal and electronic address of the responsible operator, shown on the product, its packaging, the parcel or an accompanying document. Deciding this after the packaging is printed is an expensive way to learn the rule.
Does any of this affect selling the same goods in Great Britain?
No. Regulation (EU) 2023/988 is Union law and Great Britain did not adopt it. Your obligations for the domestic market are unchanged, which is why a UK-only seller can ignore this page entirely and a UK seller with one German customer cannot.