CE marking for e-commerce sellers

Last reviewed: August 2026 · Sources listed at the end of this page.

Selling online does not soften any CE marking obligation — and since the General Product Safety Regulation (EU) 2023/988 began applying on 13 December 2024, online sellers and marketplaces carry additional duties that offline retail never had: mandatory compliance information inside the product listing, a Union-established responsible person for essentially every consumer product, and structured cooperation between marketplaces and authorities. This page covers the rules that matter for anyone selling CE-marked (or unmarked consumer) products to EU customers over the internet.

An online offer counts as making available

EU product law attaches obligations to "making available on the market". For distance sales the position is explicit in two places:

• Article 6 of Regulation (EU) 2019/1020 (the Market Surveillance Regulation, MSR): products offered for sale online are deemed made available on the market if the offer is targeted at end users in the Union — that is, if the seller directs its activities, by any means, to a Member State.
• Article 4 of the GPSR applies the same rule to consumer products sold at a distance.

Whether an offer "targets" the EU is assessed on the facts, in line with the Blue Guide's interpretation: use of an EU language or currency, delivery to EU addresses, EU domain names, and EU-directed advertising all point towards targeting. A US webshop that ships worldwide and accepts orders from Germany in euros is likely to be targeting the EU, with everything that follows, even though no stock ever sits in an EU warehouse. The offer itself counts as making available, so authorities can act on it before any sale. The Blue Guide (section 2.4) adds that the actual placing on the market depends on the supply chain: stock in an EU fulfilment centre that has been released for free circulation is already placed on the market, while goods bought directly from outside the EU are placed once an order is confirmed.

What the listing itself must contain (GPSR Article 19)

For consumer products sold at a distance, Article 19 of the GPSR requires the online offer to indicate, clearly and visibly, at minimum:

• the name, registered trade name or trademark of the manufacturer, together with a postal and electronic address at which the manufacturer can be contacted;
• where the manufacturer is not established in the Union, the name and postal and electronic address of the responsible person established in the EU (GPSR Article 16 or, for products under the acts it lists, the Article 4 operator under the MSR);
• information allowing the identification of the product, including a picture of it, the type, and any other product identifier; and
• any warning or safety information required for the product, in a language easily understood by consumers, as determined by the Member State in which the product is made available.

Article 19 applies to CE-marked consumer products as well as to others (GPSR Article 2(1) does not exclude it). In practice this means a compliant Amazon, eBay, or webshop listing for the EU market names the actual manufacturer with two addresses, names an EU responsible person where the manufacturer is outside the Union, shows the product identifiers, and reproduces the required warnings in the buyer's language — not only English. Missing Article 19 information is easy for authorities and marketplace compliance teams to spot at scale.

Obligations of online marketplaces

The GPSR (Article 22, building on the Digital Services Act) places direct product-safety obligations on providers of online marketplaces. In outline, marketplaces must:

• register with the Safety Gate portal and designate single contact points for Member State authorities and for consumers;
• act on orders from authorities to remove or disable access to dangerous-product listings without undue delay and in principle within two working days;
• operate notice-and-action mechanisms so that third parties can flag dangerous product listings, and process notices about product safety within three working days;
• take account of Safety Gate data, and use at least the Safety Gate Portal for the random checks against official databases required by Article 31(3) of the Digital Services Act;
• ensure traceability of traders before allowing them to sell — collecting and verifying seller identity and contact details in line with the Digital Services Act's "know your business customer" rules (Regulation (EU) 2022/2065, Article 30) — and design their interfaces so sellers can provide the Article 19 information;
• suspend, after a warning, traders that frequently offer non-compliant products;
• cooperate in recalls, and notify authorities of dangerous products they become aware of.

Enforcement has reached the largest platforms. In 2026 the Commission fined Temu €200 million (May) and AliExpress €550 million (July) under the Digital Services Act, reportedly for failing to assess and mitigate the risk of illegal and unsafe products. Both companies have disputed the decisions.

Delisting risk

For sellers, the operational consequence is that the marketplace is now an enforcement channel. Listings without a named EU responsible person, without manufacturer contact details, or matching a Safety Gate alert may be removed by the platform, and GPSR Article 22(11) requires marketplaces to suspend traders that frequently offer non-compliant products. Platforms commonly ask for the Declaration of Conformity, test evidence, and proof of the responsible person arrangement before reinstating a listing. A seller whose paperwork is genuinely in order (see common CE marking mistakes) can usually resolve a delisting; a seller who never built a technical file cannot.

The EU responsible person for online sales

Two overlapping instruments require a person established in the Union behind every online sale to EU customers:

• MSR Article 4: for products covered by the 18 harmonisation acts it lists — including toys, electrical equipment under the LVD and EMC Directive, radio equipment, machinery, and PPE — a product may be placed on the market only if a Union-established economic operator (manufacturer, importer, authorised representative, or fulfilment service provider) is responsible for the compliance tasks, with its contact details on the product, packaging, parcel, or accompanying document.
• GPSR Article 16: extends the same requirement to consumer products not covered by those harmonisation acts, closing the gap for generic consumer goods.

Between them, essentially any consumer product sold online into the EU needs an identifiable EU responsible person. A fulfilment service provider (an EU warehouse-and-dispatch operator that never owns the goods) counts as an economic operator and becomes the responsible person by default where no manufacturer, importer, or authorised representative is established in the Union — one reason fulfilment contracts increasingly demand proof of an authorised representative before accepting inventory. The mechanics are covered in importing from non-EU manufacturers.

Checklist: non-EU seller (Amazon FBA or independent shop)

1. Confirm which EU acts apply to the product (does my product need CE marking?) and that conformity assessment, technical documentation, and the Declaration of Conformity exist and are in your possession — not only the factory's.
2. If you sell under your own brand, recognise that you are the manufacturer in EU law, with full manufacturer obligations.
3. Appoint a Union-established authorised representative / responsible person (mandatory in effect for direct-to-consumer sales; verify the mandate covers MSR Article 4 and GPSR Article 16 tasks).
4. Add the responsible person's name and contact details to the product, packaging, or accompanying documents, alongside your own manufacturer details. For GPSR products the details must include an electronic as well as a postal address (Article 16(3)).
5. Complete the marketplace's compliance fields: manufacturer identity and addresses, EU responsible person, product identifiers, warnings translated into each target market's language.
6. Ensure instructions and safety information ship with the product in the required languages, and that labelling survives the fulfilment chain (polybags, overboxes).
7. Monitor Safety Gate for alerts touching your category, and keep a complaints register and recall procedure ready.

Checklist: EU-established seller

1. Determine your role: manufacturer (own brand), importer (first EU placement of third-country goods), or distributor (reselling goods another EU operator placed on the market). Each role has distinct duties, and importing under your own brand makes you the manufacturer.
2. As importer, verify before listing: conformity assessment done, technical file exists, CE mark and required documents present, manufacturer identified on the product — then add your own name and address.
3. Mirror the GPSR Article 19 information in every listing, including warnings in the buyer's language for each Member State you ship to.
4. Keep the Declaration of Conformity retrievable at once, because marketplaces and authorities may ask for it at short notice.
5. If you also sell to Great Britain, note that CE marking remains recognised there for most categories — see CE marking vs UKCA.

Worked examples

• UK brand selling toys through a German marketplace, shipped from Germany. The stock is placed on the market when it reaches the EU fulfilment centre and is released for free circulation. The brand is the manufacturer, and it needs an EU importer or a mandated authorised representative. If neither exists, the fulfilment service provider becomes the Article 4 operator.
• French reseller of branded headphones bought from a French wholesaler. A distributor. It makes the Article R5 checks, shows the Article 19 information in its listing and does not need an EU responsible person of its own.
• Dropshipper in the EU selling goods sent straight from a Chinese factory. If the EU business is the one placing the goods on the market it is likely to be the importer, or the manufacturer if it uses its own brand. Do not assume that holding no stock removes those duties; assess who actually sells and who appears as the seller to the customer.

Separately from product rules, a temporary €3 customs duty has applied since 1 July 2026 to goods worth up to €150 imported into the EU, charged per item by tariff classification. Low value does not exempt goods from CE marking or the GPSR.

Frequently asked questions

Do I need a CE mark to sell on Amazon in the EU?

If the product falls under an act that requires CE marking, yes, and the rule comes from EU law rather than the platform. Listings for consumer products must also carry the GPSR Article 19 information.

Who is the EU responsible person for an online seller?

For products under the acts listed in Article 4(5) of Regulation 2019/1020, it is an EU-established manufacturer, an importer, a mandated authorised representative or, failing those, a fulfilment service provider. GPSR Article 16 applies the same model to other consumer products.

Does a listing have to show the CE mark?

Article 19 of the GPSR does not list it, but the Blue Guide says it is useful for the CE marking and any required warnings to be shown on the website. Warnings and safety information required by law must appear in the offer.

Do these rules apply to a seller outside the EU?

Yes, if the offer targets end users in the EU, for example through EU delivery, language or currency. Authorities act on the offer itself.

Sources

• Regulation (EU) 2023/988 on general product safety (Articles 2, 4, 16, 19, 22) — EUR-Lex.
• Regulation (EU) 2019/1020 on market surveillance and compliance of products (Articles 4 and 6) — EUR-Lex.
• Regulation (EU) 2022/2065 on a Single Market for Digital Services (Digital Services Act), Articles 30–31 — EUR-Lex.
• Commission Notice — The "Blue Guide" on the implementation of EU product rules 2022 (OJ C 247, 29.6.2022, p. 1) — EUR-Lex.
• European Commission — Safety Gate (EU rapid alert system for dangerous non-food products).
• European Commission — €3 customs duty on low-value parcels (29 June 2026).
• Society for Computers and Law — European Commission fines AliExpress €550 million; Retail Gazette — Temu fined €200m (secondary reports).