Andreas Schilling

14/05/2026

Who is responsible for your product in the EU?

Most companies answer this wrong.

I’m currently seeing setups where:

– products are CE marked
– imported and sold
– multiple parties are involved

👉 …but responsibility is unclear.

Why is this critical?

Because EU authorities don’t accept:

👉 “It’s the manufacturer.”
👉 “It’s the importer.”
👉 “Someone else is handling it.”

They require:

– a clearly defined responsible entity
– accessible documentation
– a contact point inside the EU

👉 Without this:

– responsibility becomes unclear
– compliance cannot be verified
– enforcement escalates

👉 And this is where problems start.

If responsibility is not clearly defined:

❌ products get stopped
❌ listings get removed
❌ investigations start

👉 Reality check:

If no one is clearly responsible,
👉 everyone is at risk.

We are currently seeing increasing enforcement in Germany.

👉 Many companies rely on assumptions instead of structure.

👉 Do you KNOW who is responsible — or just assume it?



This content reflects general compliance practices and does not constitute legal advice. Specific requirements may vary depending on product and jurisdiction.

13/05/2026

EU law requires a responsible economic operator inside the EU.

Many companies underestimate this.

I’m currently seeing setups where:

– products are imported
– CE marking is in place
– sales already started

👉 …but no clear responsibility is defined.

Why is this critical?

Because EU law requires:

– a responsible entity within the EU
– clear allocation of roles
– access to documentation
– a contact point for authorities

👉 Without this structure:

– responsibility is unclear
– compliance cannot be verified
– authorities cannot enforce requirements

👉 And this is where problems start.

If no responsible economic operator is defined:

❌ products get stopped
❌ customs blocks shipments
❌ listings get removed

👉 Reality check:

No responsible entity in the EU
= no compliant market access.

We are currently seeing increasing enforcement in Germany.

👉 Many companies rely on incomplete structures.

👉 Is your setup legally structured — or just operational?



This content reflects general compliance practices and does not constitute legal advice. Specific requirements may vary depending on product and jurisdiction.

12/05/2026

What is an economic operator in the EU — and why does it matter?

Most companies don’t think about this.

👉 Until authorities ask.

Every product in the EU needs a clearly defined structure:

– manufacturer
– importer
– distributor
– EU authorised representative

👉 Together, they form the economic operator structure.

Why is this important?

Because authorities need to know:

– who is responsible
– who provides documentation
– who can be contacted

👉 Without this clarity:

– responsibility is unclear
– documentation is not accessible
– compliance cannot be verified

👉 And this is where problems start.

If no responsible structure exists:

❌ products get stopped
❌ listings get removed
❌ investigations start

👉 Reality check:

No economic operator in the EU
= no compliance.

We are currently seeing increasing enforcement in Germany.

👉 Many companies don’t define roles clearly.



This content reflects general compliance practices and does not constitute legal advice. Specific requirements may vary depending on product and jurisdiction.

11/05/2026

EU authorities can check your product at any time.

Most companies are not prepared.

I’m currently seeing cases where products are:

– already on the EU market
– selling without issues
– considered “compliant”

👉 …until a check happens.

And then:

– documentation is requested
– responsibilities must be defined
– compliance must be proven

👉 That’s the critical point.

Authorities expect:

– complete and accessible documentation
– a clearly defined EU-based contact
– a structure that allows verification

👉 Not assumptions. Proof.

If you can’t provide it:

❌ product removal
❌ sales bans
❌ customs blocks
❌ fines and penalties

👉 Reality check:

Compliance is not about having documents.

👉 It’s about being able to provide them immediately.

We are currently seeing increasing enforcement in Germany.

👉 Many companies are not ready for real checks.

👉 Is your setup ready — or just documented?



This content reflects general compliance practices and does not constitute legal advice. Specific requirements may vary depending on product and jurisdiction.

08/05/2026

Products don’t get banned in the EU because they are unsafe.

Most companies believe that.

👉 It’s usually wrong.

I’m currently seeing products that are:

– CE marked
– technically working
– already on the market

👉 …and still get banned.

Why?

Because compliance is more than the product itself.

Typical reasons:

– missing or incomplete documentation
– incorrect CE marking
– no EU-based responsible entity
– labelling and identification issues

👉 And this is where things break.

Authorities don’t ask:
“Is the product working?”

👉 They ask:

– who is responsible
– where is the documentation
– can compliance be verified

If not:

❌ product removed
❌ sales banned
❌ investigations start

👉 Reality check:

No compliance = no market access.

We are currently seeing increasing enforcement in Germany.

👉 Many companies realise this too late.

👉 Want to avoid this?



This content reflects general compliance practices and does not constitute legal advice. Specific requirements may vary depending on product and jurisdiction.

07/05/2026

Your product can be live on Amazon — and suddenly disappear.

Most sellers don’t expect this.

👉 Until the listing is gone.

I’m currently seeing products that are:

– CE marked
– already selling
– fully active on marketplaces

👉 …and then get removed.

Why?

Because platforms don’t just check your listing.

👉 They check compliance.

Typical issues:

– missing or incomplete documentation
– no EU-based responsible entity
– incorrect or missing labelling
– no clear contact for authorities

👉 And this is where things break.

If something is flagged:

❌ listing removed
❌ sales stop immediately
❌ account risk increases

👉 Reality check:

Compliance is not optional.

👉 It’s your access to the EU market.

👉 Want to stay on the market?



This content reflects general compliance practices and does not constitute legal advice. Specific requirements may vary depending on product and jurisdiction.

06/05/2026

Your product can be ready, certified — and still get stopped at EU customs.

Most companies don’t expect this.

👉 Until the shipment is already at the border.

I’m currently seeing cases where products are:

– CE marked
– technically compliant
– ready for sale

👉 …and still blocked.

Why?

Because customs doesn’t check logistics.

👉 They check compliance.

Typical issues:

– missing or incomplete documentation
– no EU-based responsible entity
– incorrect or missing labelling
– incomplete compliance structure

👉 And this is where everything stops.

If something is unclear:

❌ shipment gets held
❌ release is delayed
❌ documents are requested

👉 In some cases:

– goods are returned
– or blocked completely

👉 Reality check:

Customs is often the first place
where compliance issues become visible.

👉 No compliance = no entry.

👉 Want to avoid this?



This content reflects general compliance practices and does not constitute legal advice. Specific requirements may vary depending on product and jurisdiction.

05/05/2026

Selling in the EU without an Authorised Representative — what really happens?

Most companies think everything is fine.

👉 Until it isn’t.

👉 Reality check:

No issue today
does NOT mean no risk tomorrow.

👉 Authorities don’t check intentions.
They check structure.

👉 What happens next?

– documentation requests
– no EU contact
– no responsible entity

👉 …and then escalation starts.

👉 Want to understand your real risk?



This content reflects general compliance practices and does not constitute legal advice. Specific requirements may vary depending on product and jurisdiction.

26/04/2026

Many companies entering the EU market rely on existing partners to handle compliance. Importers, distributors, or logistics providers are expected to “take care of everything.” While this may work operationally, it creates a dangerous assumption: that responsibility is automatically covered — even when it is not formally defined.
Typical statements:

“Our importer handles compliance.”“We have AEO — everything is covered.”

In reality, this is rarely the case.

What an Importer Actually Does
Importers play a critical role in placing products on the EU market. However, their responsibilities are clearly defined and limited. They are not a substitute for a structured compliance setup, and they do not automatically assume full responsibility for product conformity.

Many companies entering the EU market rely on existing partners to handle compliance. Importers, distributors, or logistics providers are expected to “take ca

24/04/2026

Many manufacturers believe that once a product carries the CE marking, it is fully compliant and can be freely sold across the European Union without further requirements. This assumption is widespread because CE marking is often perceived as a comprehensive approval that covers all regulatory aspects. In reality, CE marking only confirms technical conformity under specific directives, but it does not establish the legal and organisational framework required for market access. Compliance in the EU depends not only on product characteristics, but also on whether there is a clearly defined structure that ensures accountability, documentation access, and communication with authorities.
What CE Marking Actually Covers
CE marking focuses on technical conformity and confirms that a product meets the essential requirements defined in applicable EU legislation. It is a necessary component of compliance, but it represents only one part of the overall regulatory framework.

Many manufacturers believe that once a product carries the CE marking, it is fully compliant and can be freely sold across the European Union without further re

08/02/2026

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