GPSR for Resellers: Selling Other Brands' Products into the EU from Outside the EU

A trading company in Japan recently asked us for help. It sells new, unused watches, toys and small electronics from well-known Japanese brands to European buyers through Joom, and it wanted us as its EU Responsible Person under the GPSR. The company found us through ChatGPT, which had pointed it to our article on second-hand items. That article was close but not quite right for them: their products are brand new, and the brands are not theirs.

We have had several of these requests from Joom sellers. Under the General Product Safety Regulation (GPSR), every product sold to EU consumers needs a responsible economic operator in the EU. The usual answer, appointing an EU Authorised Representative, assumes you are the manufacturer. A reseller is not, and a brand has little reason to sign a mandate for a trading company it does not know.

Are you a distributor or a manufacturer under the GPSR?

The GPSR answers this with its definitions. A manufacturer is a person who makes a product, or has it made, "and markets that product under that person's name or trademark" (Article 3(8)). A distributor is anyone in the supply chain, other than the manufacturer or the importer, "who makes a product available on the market" (Article 3(11)). If you buy finished watches from a Japanese brand in Tokyo and sell them on unchanged, under that brand, you would normally be a distributor.

Under the GPSR itself, a reseller becomes the manufacturer in two situations: when it sells the product under its own name or trademark (Article 13(1)), or when it substantially modifies the product in a way that affects safety (Article 13(2) and (3)). The European Commission gives a simple example: a company that resells products is a distributor for the products it buys and resells, and a manufacturer for the products it rebrands and sells under its own name (source: Commission Notice C/2025/6233, section 1.1, Example 1).

Unlike the importer, a distributor does not have to be established in the EU. For a reseller in Japan that looks like good news, until you read Article 16.

Why the GPSR needs someone in the EU for every unit you ship

Article 16(1) of the GPSR says a product "shall not be placed on the market unless there is an economic operator established in the Union" who is responsible for it. That person's name and contact details, including a postal and electronic address, must be on the product, its packaging, the parcel or an accompanying document (Article 16(3)).

Two principles from the Commission's Blue Guide show that this applies to each shipment. Placing on the market refers to each individual product, not to a product type (Blue Guide 2022, section 2.3). And a product that an end user in the EU orders online from outside the EU is placed on the market at the moment the order is placed and confirmed (section 2.4). An offer counts as targeted at EU consumers as soon as you direct your activities to an EU country (Article 6 of Regulation (EU) 2019/1020).

So the product you ship from Osaka to a buyer in Lyon is placed on the EU market by that sale. It does not help that the same model is sold in European shops by the brand's own distributor, because that distributor never handled your unit.

Three routes that do not fit a reseller

The Commission lists who can be the responsible person under Article 16: a manufacturer established in the EU, an importer, an authorised representative with a written mandate from the manufacturer, or an EU fulfilment service provider if none of the others is there (source: C/2025/6233, section 3.2; Article 4(2) of Regulation (EU) 2019/1020).

For a reseller shipping directly from Asia, the first three fall away quickly.

The importer route is closed. An importer is a person "established within the Union" who places a product from a third country on the EU market (Article 3(10)), and the Commission repeats that the importer is always established in the EU (section 3.1.3).

Nor can you appoint an authorised representative on the brand's behalf. Article 10(1) says "a manufacturer may, by means of a written mandate, appoint an authorised representative", and Article 3(9) defines the role the same way. As a distributor, you have no mandate to give for someone else's product.

That leaves the brand itself, and you can ask, but do not count on it. The GPSR and the Commission's guidelines do not address whether a brand's existing EU responsible person also covers units that a third party sells from outside the EU. A brand that sells through its own European channel has no obvious reason to take responsibility for stock it did not ship.

How we handle new branded products from resellers

We use the same route as for second-hand and collectible items. The reseller takes on the role of manufacturer for the EU market, is named on the product and in the listing as the party placing the product on that market, and gives us a written mandate to act as its EU contact. We act for the reseller, not for the brand. A typical label looks like this:

On these products we deliberately do not write "EU Authorised Representative" next to the brand name, because that would suggest the brand appointed us. The contract you sign with us is the same one we use for brand owners, and you can read the contract before you order.

The main basis for this route is the Commission's Blue Guide. It says that a person who places on the EU market a product "not designed or manufactured for the Union market" must assume the role of the manufacturer (section 3.1). A product with a Japanese-only manual, bought in Japan for the Japanese market, is such a product. Article 13(1) of the GPSR is sometimes read the same way, although that article is written for products sold under the reseller's own name or trademark. Be aware that this is our reading of a grey area. Section 3.1 of the Blue Guide is written for CE-marked products, the GPSR itself does not mention this situation, and a market surveillance authority could take a different view.

What stays your responsibility as a reseller

Taking on the manufacturer's role means taking on its obligations under Article 9 of the GPSR. You need technical documentation with an internal risk analysis for each product or product family (Article 9(2)). The product needs a type, batch or serial number (Article 9(5)), and the manufacturer's details on the product or its packaging (Article 9(6)). Instructions and safety information must be in a language consumers can easily understand, as decided by the EU country where you sell (Article 9(7)). For products bought on the Japanese market this is often the first gap, because the original manual is frequently in Japanese only.

A common objection is "it is not my brand, so I have no test reports". That does not change anything. The product must be safe and must meet the EU rules that apply to it, because you are the one placing it on the EU market. For several product types that means more than the GPSR:

Products made for the Japanese or Korean market often lack the CE marking, even when the European version of the same model has it. Mains-powered devices for Japan are also often built for 100 volts and a different plug. Unless such a device is rated for 230 volts, it cannot be used on EU mains. An EU contact cannot fix any of this for you; the product has to be made compliant first.

For toys, note that the new Toy Safety Regulation (EU) 2025/2509 has been adopted and will replace the directive from 1 August 2030.

GPSR details in your Joom and Amazon listings

Whatever the platform, Article 19 of the GPSR decides what goes in your listing. It must show the manufacturer's name and postal and electronic address, the responsible person in the EU where the manufacturer is outside the EU, a picture and identifier of the product, and any warnings or safety information. Joom refers to the same Article 19 details in its product-safety requirements for e-scooters.

Joom can also reject a product for brand reasons, such as an unauthorised brand. That is about brand rights, not product safety, and an EU contact does not solve it. If a platform asks you to prove you may sell a brand, you need proof of purchase or permission from the brand.

Once you have placed your order and signed the agreement, you can use our details in your listings and in the compliance forms of Joom, Amazon, Etsy, eBay and other marketplaces. The service costs 150 euros a year and covers an unlimited number of products, listings and variants. A product counts as covered once we have received its technical documentation. See what our EU contact service for the GPSR includes.

Your options as a reseller outside the EU

You have four realistic routes. The first is an EU contact on the basis described above, with your company named as the party placing the product on the market. The second is keeping stock with a fulfilment service provider in the EU; if no manufacturer, importer or authorised representative is in the EU, the Commission says such a provider can automatically become the responsible economic operator (source: C/2025/6233, section 3.1.5). A third option is selling to an importer in the EU, which then buys the goods in its own name and takes on the importer's obligations. Or you can stop offering these products to EU buyers.

If some of your stock is used rather than new, see our article on GPSR for second-hand and collectible items. For the general role of the EU contact, read the EU Authorised Representative under GPSR.

Checklist before your next sale to EU buyers

• Check whether you are a distributor or a manufacturer: do you sell under your own name, or change the product?
• Choose your route: an EU contact, an EU fulfilment provider, an EU importer, or no EU sales.
• Check that each product type has the CE marking and test reports it needs in the EU, especially toys, electronics and personal protective equipment.
• Prepare a technical file per product or product family, with an internal risk analysis.
• Put the original manufacturer, your company and the EU contact on the product, the packaging or an accompanying document, with a type, batch or serial number.
• Add instructions and warnings in the language of the countries you sell to.
• Show the same manufacturer and EU contact details in every marketplace listing.

Sources

• Regulation (EU) 2023/988 on general product safety (GPSR), Articles 3(8) to 3(11), 9(2), 9(5) to 9(7), 10(1), 13, 16 and 19. EUR-Lex
• European Commission, Guidelines on the application of the EU general product safety legislative framework by businesses, C/2025/6233, sections 1.1, 3.1.3, 3.1.5 and 3.2. EUR-Lex
• Regulation (EU) 2019/1020 on market surveillance and compliance of products, Articles 4 and 6. EUR-Lex
• European Commission, The 'Blue Guide' on the implementation of EU product rules 2022 (2022/C 247/01), sections 2.3, 2.4 and 3.1. EUR-Lex
• Directive 2009/48/EC on the safety of toys, Annex I, and Regulation (EU) 2025/2509 on the safety of toys. EUR-Lex and EUR-Lex
• Regulation (EU) 2016/425 on personal protective equipment, Annex I. EUR-Lex
• Directive 2011/65/EU (RoHS), Regulation (EC) No 1907/2006 (REACH), Annex XVII, entry 27, Regulation (EU) 2023/1542 on batteries, and Regulation (EU) No 1007/2011 on textile fibre names and labelling.
• Joom Merchant Help Center, e-scooters: listing and product-safety requirements, consulted October 2026. merchant.joom.com