CE marking for e-commerce sellers

Last reviewed: August 2026 · Legal status verified against EUR-Lex.

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 is "placing on the market"

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, for these purposes, placing products on the EU market — with everything that follows, even though no stock ever sits in an EU warehouse.

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 — for harmonised products this role corresponds to 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 which can be easily understood by consumers of the Member State in which the product is made available.

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 detect at scale, which is why it has become a leading cause of delisting.

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 a single contact point 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 such notices within short deadlines;
• take account of Safety Gate data, including making reasonable efforts to carry out random checks of products offered against dangerous products notified in Safety Gate;
• 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;
• cooperate in recalls, including informing affected consumers directly where they hold contact details, and notify authorities of dangerous products they become aware of.

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 are removed by the platforms themselves — often automatically, and often account-wide for repeat findings. Reinstatement generally requires producing the Declaration of Conformity, test evidence, and proof of the responsible person arrangement. 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.
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 — marketplaces and authorities typically expect it within days, not weeks.
5. If you also sell to Great Britain, note that CE marking remains recognised there for most categories — see CE marking vs UKCA.

Sources

• Regulation (EU) 2023/988 on general product safety (Articles 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), Article 30 — 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).