Market
Launching a product brand in the European Union
The EU is one set of product rules with 27 sets of waste registers, languages and buyers. A brand from outside the Union needs a legal presence before its first sale.
How to launch a private label brand in the EU
To launch a private label brand in the EU you need a compliant product file, an economic operator established in the Union, packaging registered in each selling country, and a trademark that covers your market. Under the General Product Safety Regulation, applicable since 13 December 2024, a consumer product cannot reach the market without that responsible operator, and a company selling under its own name is treated as the manufacturer.
The packaging side changed recently. The Packaging and Packaging Waste Regulation has applied since 12 August 2026. PFAS limits on food-contact packaging apply from that date, and an authorised representative for producer responsibility is now required for selling into other Member States, although the Commission has proposed suspending this for small businesses and asked for a pragmatic approach in the meantime. Check that position when you start, as the proposal was still being examined at the time of writing.
Our group is an EU company, which helps with contracts and communication, but legal roles still depend on the product. This summary is general information, and the actual file is reviewed by a licensed specialist. See the compliance stage and your product category for detail.
Who does what in the EU, by product group
Three things are shared across all groups: an EU trademark route, EPR in every selling country and labels in local languages.
| Group | Who is responsible | Product rule | Trademark route | Packaging and EPR |
|---|---|---|---|---|
| General consumer goods | Manufacturer or importer in the EU, or an EU responsible person | Regulation 2023/988: risk analysis and technical documentation; importers keep a copy for 10 years | EU trade mark through EUIPO: basic online fee €850 for one class, €50 for the second, €150 for each further class; or Madrid | PPWR applies; national producer register in each selling country; harmonised sorting labels from 12 August 2028 or 24 months after the implementing acts, whichever is later |
| Cosmetics | Responsible person within the EU | Regulation 1223/2009: safety report, product file, CPNP notification | As above, in the correct class | As above; check claims about recyclable packaging |
| Food and supplements | Food business operator or importer established in the EU | Regulation 1169/2011; Directive 2002/46/EC; claims under Regulation 1924/2006 | As above | PFAS limits for food contact from 12 August 2026; national EPR |
| Toys and children’s goods | Manufacturer, importer, or their authorised representative | Directive 2009/48/EC now; Regulation 2025/2509 from 1 August 2030 | As above; design rights for characters | As above |
| Electrical goods | Manufacturer or importer | LVD, EMC, RoHS, RED; Batteries Regulation 2023/1542 | As above | WEEE and battery registers on top of packaging |
National law still matters: registers, some labels and take-back schemes are set by each country.
What to have in place before first delivery
This is a working list, and an individual product may add to it.
- EU economic operator named, with a contract setting out the role, and contact details on the product
- Technical documentation and test reports matching your exact product
- Product and pack labels in the language of each country of sale
- Online listings showing required safety information, and the responsible person when the maker is outside the EU
- Authorised representative decision, checked against the current status of the Commission’s proposal
Main channels and how they work
Your route determines who holds stock, who sets price and who asks for which papers.
Pan-European marketplaces
Amazon’s EU stores offer reach, with national VAT and EPR duties. Platforms may ask for EPR numbers before allowing sales.
Local marketplaces
Allegro in Poland and comparable local platforms often beat a generic plan. Local language, reviews and delivery expectations matter.
Direct to consumer from outside
A flat €3 customs duty on low-value parcels applies from 1 July 2026 until 1 July 2028, ending the old duty-free route. Reassess parcel models accordingly.
Related pages
United Kingdom
UK importer duties, UKCA, packaging EPR and UK trade marks.
Compliance & trademark
Market rules, testing, labelling and a trademark filing plan.
Toys & plush
Safety testing, age grading and own characters.
Marketplace sellers
From reselling to an owned brand on Amazon and other marketplaces.
Frequently asked questions
Does my brand need an EU company to sell in the EU?
You need an economic operator established in the EU for products under the General Product Safety Regulation. This can be your own entity, an importer, an authorised representative or a fulfilment provider in some cases. Having one on paper is not enough, as that party has checking duties.
What changed for packaging in August 2026?
The Packaging and Packaging Waste Regulation began to apply on 12 August 2026, replacing most of the old directive. This brought PFAS limits for food-contact packaging and an authorised representative duty for other Member States, with a proposed suspension for small businesses still under examination.
Is one trademark enough for the whole EU?
An EU trade mark from EUIPO covers all Member States as a single right. National conflicts can still block it, and the UK needs its own filing. EUIPO does not refuse marks on the basis of earlier rights by itself, so a search and watch remain worthwhile.
Can we sell to one country first?
Yes, and we usually suggest this. Choosing one country reduces languages, registers and marketing spend, and shows you whether the numbers work before rolling out. Register the trademark more broadly if your plan justifies it. Launch planning covers the rollout.
Have a product idea? Check it before you buy stock.
Send a short brief. We tell you what we think, including when we think you should not do it.
Tell us about your brand
A few lines are enough: what you want to sell, where and to whom. We reply with an honest view of feasibility, the stages you need and the next step.
- No obligation: the first review of your idea is free
- If we think the idea will not pay back, we say so
- Your idea stays confidential; we can sign an NDA
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