Insights · EU law and compliance

EU representative for non-EU companies: products, data, customs and VAT

Why marketplaces block products without an EU responsible person, when a GDPR representative is required, why customs needs an EU declarant, and which other roles apply to platforms and AI, with a checker for your business.
Check my roles ↓

Reading time7 minutes
TopicEU law and compliance
Rules as ofOctober 2026
AuthorAlexander Baranov
The short version

Non-EU companies selling into the EU increasingly need a person established in the EU. Since December 2024 every consumer product needs a GPSR responsible person, or marketplaces remove the listing. Processing EU residents' data requires a GDPR representative. Imports need an EU-established customs declarant and, in some countries, a fiscal representative. Platforms and high-risk AI providers need representatives too. One provider can cover most roles.

01 · In plain words

Selling into the EU without being there now needs a local name

For years a company in China, Turkey, the UK, the US or the Gulf could sell to European customers with nothing more than a website or a marketplace account. That changed. EU product safety, data protection, customs and platform rules now each require a person or company established in the EU that authorities can contact and, in some cases, hold liable.

The most visible change came in December 2024, when marketplaces started blocking products without an EU responsible person. The others are quieter but enforced: GDPR representatives, customs representatives, fiscal representatives and, for some businesses, digital and AI representatives.

Products

GPSR responsible person

Name on the packaging and the listing.

Data

GDPR representative

Article 27 contact for regulators.

Customs

Indirect representative

Declarant established in the EU.

Digital

DSA and AI Act

Legal representative for platforms and AI.

02 · The roles

Every EU representative role in one table

RoleLegal basisWho needs it
Responsible economic operatorGPSR, Regulation 2023/988, Art. 16; Market Surveillance Regulation 2019/1020, Art. 4Non-EU sellers of consumer products, CE-marked goods
Cosmetics responsible personRegulation 1223/2009, Art. 4Non-EU brands selling cosmetics
GDPR representativeGDPR, Art. 27Non-EU businesses processing EU residents' data
Indirect customs representativeUnion Customs Code, Art. 18 and 170Non-EU importers clearing goods
Fiscal representativeNational VAT law (e.g. Belgium for non-EU companies; Dutch Article 23 licence)Non-EU companies registered for VAT
Legal representativeDigital Services Act, Art. 13Non-EU intermediary services and platforms
Authorised representativeAI Act, Art. 22Non-EU providers of high-risk AI systems

Law and practice: The GPSR applies since 13 December 2024 and obliges online marketplaces to show the EU responsible person in listings. The GDPR representative can be addressed by authorities and data subjects instead of, or in addition to, the controller. Under the Union Customs Code the declarant must generally be established in the EU. Fines under the GPSR and the GDPR are set by member states and can be significant; for the GDPR up to 4% of worldwide turnover.

03 · What we do

One EU address for all roles

  1. Map your obligationsProducts, data, imports, VAT, platforms, AI.
  2. Appoint the rolesWritten mandates for GPSR and GDPR representation from our Benelux entity or a partner.
  3. Labels and listingsName and contact data for packaging and marketplace listings.
  4. Customs and VATEORI, indirect customs representative and fiscal representative where needed.
  5. Documents on fileTechnical documentation, declarations of conformity, records of processing.
  6. Contact pointHandling of requests from authorities and customers.
Example

A Turkish kitchenware brand sells on Amazon in Germany, France and the Netherlands. Its listings are blocked in early 2025 for lack of a GPSR responsible person. We appoint our Dutch entity as authorised representative, update labels and listings, add GDPR representation for its EU customer data and arrange an indirect customs representative in Rotterdam. Listings are back within two weeks.

04 · Your case

Which EU representatives do you need?

The result updates with each answer.

Which EU representatives do you need?

Tick what applies to your business outside the EU. You see every representative role you need, why, and what happens without it.

What do you do in the EU?Several answers possible
Do you charge EU VAT yourself?
Selling into the EU from outside?We act as your EU representative and arrange customs and VAT representation through licensed partners.
Get a quote
01Products

GPSR responsible person since 2024.

02Data

GDPR representative.

03Imports

EU-established declarant.

04One address

Several roles, one provider.

05 · FAQ

EU representative for non-EU companies: frequent questions

Why did Amazon block my listings in the EU?

Since 13 December 2024 the General Product Safety Regulation requires an economic operator established in the EU for every consumer product sold there, with its name and contact details on the product or its packaging and in the online listing. Marketplaces must remove listings without one.

Who can be my responsible person under the GPSR?

An EU manufacturer, an EU importer, an authorised representative appointed in writing, or a fulfilment service provider in the EU. For a non-EU seller without an importer, an authorised representative is the usual solution.

Does a non-EU company need a GDPR representative?

Yes, if it offers goods or services to people in the EU or monitors their behaviour, unless the processing is occasional, low-risk and does not cover sensitive data on a large scale. The representative must be in a member state where the data subjects are.

Can a company outside the EU clear goods through EU customs itself?

Generally not: the declarant must be established in the EU. A non-EU importer needs an EORI number and an indirect customs representative, who shares liability for the duties and VAT.

Is one company enough for all roles?

Often yes. One EU entity or service provider can act as GPSR authorised representative, GDPR representative and contact point, while customs and VAT representation are usually done by a licensed broker or fiscal representative.

Your structure

Selling into the EU from outside?

We act as your EU responsible person and GDPR representative and arrange customs and VAT representation through licensed partners.