Compliance
20 October 2026
A purchase order that says "CE marked, RoHS compliant" no longer gets a phone case onto the EU market on its own. Since 13 December 2024 the General Product Safety Regulation (EU) 2023/988 has required a named economic operator established inside the Union for every consumer product sold there — including a USD 1.30 TPU case in a polybag.
Most of the questions we get from German and Dutch buyers are not about the rule itself. They are about who is supposed to be that person, what they have signed up for, and what has to be printed on the packaging. This is the practical version.
The old General Product Safety Directive assumed that a product placed on the market had somebody behind it who could be found. In practice, for goods imported from Asia, that assumption failed constantly: the box said "Made in China", the marketplace listing said a brand name, and nobody in Europe could produce a technical file when a market surveillance authority asked.
The GPSR closes that gap. It requires an economic operator — manufacturer, importer, authorised representative or fulfilment service provider — established in the EU, who can be contacted directly by authorities and who holds the documentation proving the product is safe.
We are the manufacturer. We can give you a technical file, test reports, material declarations, photos of the mould and the production line. What we cannot do is be the EU economic operator, because we are not established in the Union — and the regulation is explicit about establishment, not about willingness.
This is worth stating plainly because it is a common misunderstanding in first-time sourcing. A Chinese factory address on the label, however complete, does not satisfy the requirement.
Notice what is not on the list: designing the product, testing it, or taking commercial responsibility for defects. The role is regulatory, not a warranty. That distinction matters when you negotiate the service with an EU partner, because a responsible person is often priced like insurance when it is really clerical work plus liability exposure.
For a phone case the practical label is small, so it is usually printed on the back of the retail sleeve or on a sticker inside the polybag. It must carry:
On a case, "warnings" is usually nothing. On a case with a magnetic ring, it is a line about pacemakers and implanted devices, which some EU buyers now ask for because the magnets are strong enough to be a plausible concern.
If the product is sold online, the same identity information has to be visible in the listing — not only on the physical product. Marketplaces have translated this into a hard field: no EU responsible person, no listing. Sellers who built a catalogue on a Chinese entity alone discovered this in January 2025 when listings were pulled without warning.
| Model | How it works | Watch out for |
|---|---|---|
| Own EU entity | You register a company or branch in the EU and name it on the label. | Ongoing accounting cost; you carry the liability directly. |
| Authorised representative | A service provider signs a mandate to act for you. | Read the mandate: scope, ten-year document retention, who pays for a recall. |
| Importer of record as operator | Your EU distributor imports and is named. | They become the operator, which shifts leverage — and often the branding. |
Three failure points show up again and again:
We are not your responsible person and we will not pretend to be. What we do supply, per SKU, is the part that only the factory can supply: material declaration, dimensional drawings, the production site address, the batch coding convention, and test reports we actually hold. If a report does not exist for a substance your buyer asks about, we say so rather than sending a generic certificate with a different company name on it — that shortcut has ended more supplier relationships than any price argument.
If you are assembling a EU entry for a first order, start with the iPhone range or the Samsung range, pick two or three models, and build the paperwork around a narrow SKU set before you scale.
Yes, one company can hold both roles, and many EU importers do exactly that. The point is that the obligations are different: the importer of record answers to customs, the responsible person answers to market surveillance. Putting both on one entity concentrates the exposure, so check that the mandate covers it.
It applies to products intended for consumers, and a phone case sold to a retailer for resale is still a consumer product. Selling B2B does not remove the requirement.
No. The responsible person must be established in the EU. A UK entity is a third-country operator for this purpose, which is why some UK-based distributors now run a parallel EU entity.