Dropshipping and print-on-demand

• Regulation (EU) 2023/988 — GPSR Articles 16 and 19
• Regulation (EU) 2019/1020 — Article 4
• Directive 2011/83/EU — consumer rights
• Regulation (EU) 2016/679 — GDPR Article 27
• Union Customs Code for import VAT and duty

Who has to appoint one

Anyone selling to EU consumers goods shipped directly from a third-country supplier. The seller is generally the importer or the manufacturer in law where the product carries its brand, and cannot rely on the factory to hold EU obligations. Print-on-demand sellers are manufacturers because the product is placed on the market under their name.

Thresholds and exemptions

None. The consumer is the importer of record in some arrangements, which does not remove the seller's product obligations and creates customs and VAT problems of its own.

What must appear on the label

Manufacturer and responsible person details, product identifier and warnings on the product or packaging, and the same information in the listing before purchase under Article 19 GPSR. The consumer must also receive the trader identity, total price, delivery time and withdrawal rights.

Marketplace fields

Marketplaces suppress dropshipping listings without a valid EU responsible person, and the model is under particular scrutiny because the supply chain is invisible. Long delivery times without disclosure are a separate consumer law infringement.

Documentation you must hold

Technical documentation for each product, which the seller must obtain from the supplier and be able to produce. Traceability records identifying the supplier. Import VAT arrangements, typically through the Import One Stop Shop. The Article 27 designation and the shop's privacy documentation.

Standards and testing

Determined by the product category. The structural weakness of dropshipping is that no one has tested anything: catalogue products from third-country suppliers frequently lack any EU test evidence, and the seller discovers this only when an authority asks.

Language requirements

Product warnings, listing information and consumer terms in the language of each market served.

When it applies

Before the listing goes live. Import VAT arrangements before the first shipment.

How long records are kept

Ten years for product documentation and traceability records, and tax records per national law.

What happens if you do not comply

Listing suppression, withdrawal orders, customs holds on incoming parcels, and consumer law penalties for delivery and withdrawal failures. Because the seller usually cannot produce documentation, cases escalate quickly from information request to prohibition.

Who enforces it

Market surveillance authorities, customs, consumer protection authorities and data protection authorities.

Where the boundary lies

The model's assumption that the supplier carries the obligations is wrong in EU law: the seller placing the product on the Union market under its own name is the manufacturer, with the full technical file and ten-year retention. Print-on-demand is the clearest case, because the product does not exist until the seller orders it.

Questions we are asked

Our supplier says the product is CE certified — is that enough?

No. If you sell under your own brand you are the manufacturer, and you need the declaration in your name and the technical file in your possession.

Who is the importer if the parcel goes direct to the consumer?

In customs terms it can be the consumer, which is precisely why Article 4 of Regulation 2019/1020 requires an EU economic operator regardless. The product obligations do not disappear.