B2B suppliers selling into EU businesses

• Regulation (EU) 2019/1020 — Article 4
• Regulation (EU) 2023/988 — GPSR where products reach consumers
• Directive (EU) 2024/2853 — product liability
• Directive 2011/7/EU on late payment

Who has to appoint one

Suppliers outside the Union selling components, equipment or goods to businesses in the EU. Selling business to business does not remove product conformity obligations, and where the product ultimately reaches consumers, GPSR applies through the chain.

Thresholds and exemptions

None. The Article 4 requirement attaches to the product categories listed in Regulation 2019/1020, which include most CE-marked goods, regardless of the buyer.

What must appear on the label

Manufacturer and EU economic operator details, CE marking where the sectoral rules require it, and the technical documentation available to the buyer, who needs it for its own compliance.

Marketplace fields

EU buyers increasingly require the declaration of conformity, the EU operator details and, where relevant, the supply chain due diligence documentation before onboarding a supplier, because their own obligations depend on it.

Documentation you must hold

Declaration of conformity and technical file for each product, traceability records, and contractual allocation of the economic operator role. Buyers may also request conflict minerals, deforestation or forced labour due diligence depending on the product.

Standards and testing

Per the product category. What distinguishes B2B is that the buyer audits: documentation gaps surface in supplier qualification rather than in market surveillance.

Language requirements

Documentation in a language the buyer and the authorities can use, which in practice means the national language of the buyer's market for instructions.

When it applies

Before the first delivery into the Union.

How long records are kept

Ten years, and the buyer will expect access for the same period.

What happens if you do not comply

Rejected consignments and terminated supply agreements are the immediate consequence, and under the recast product liability rules the person who put their name on the product, and in some cases the fulfilment provider, can be sued directly by an injured person.

Who enforces it

Market surveillance authorities, customs, and the buyer's own audit function.

Where the boundary lies

The recast Product Liability Directive extends liability to software and to digital services integrated in products, and makes it easier for claimants to obtain evidence. B2B suppliers who previously relied on contractual limits now face direct claims from end users.

Questions we are asked

Do B2B sales need an EU representative?

Where the product falls under Article 4 of Regulation 2019/1020, yes, regardless of whether the buyer is a business.

Can we limit liability by contract?

Between businesses, within limits. Toward an injured consumer, no: the product liability regime does not permit exclusion.