Exporting goods to the EU

Published on 20 June 2023 · Last updated 23 October 2026

Exporting goods to the EU raises two sets of legal questions. First, the contract: a sale of goods between businesses in different contracting states is governed by the UN Sales Convention (CISG), unless excluded (Article 1(1)(a) and Article 6 CISG). Second, the goods: goods from outside the EU must clear customs, and products must meet EU product rules. Our team also advises on Dutch Distribution Law.

Contact details

Remko Roosjen | export attorney in the Netherlands
Sander van Someren Gréve | transportation lawyer in the Netherlands
Martin Krüger | (EU)Product Compliance and Regulation Lawyer in the Netherlands

+31 (0)20 – 210 31 38
mail@maakadvocaten.nl

How do supply agreements work when exporting to the EU?

As a Dutch lawyer specialising in international business law, I have seen firsthand how important it is to understand the details of exporting goods into this part of Europe before taking that step.

Whether you are an established company or a new entrant, the rules differ depending on where the goods go. The EU’s 27 member states form a customs union: there are no customs duties on goods moving between them (Article 28(1) TFEU). Goods that enter the EU from outside, or leave it, pass through customs. In both cases you need a sound contract. Our law firm in the Netherlands drafts supply agreements and advises on market entry in the EU and the Netherlands. If you have a question about a supply agreement or about exporting goods to the EU, please contact us.

This guide first covers the contract: the CISG, the applicable law, the competent court, retention of title and Incoterms. It then covers the rules for the goods themselves: customs, tariffs, export controls, VAT and product rules.

Does the CISG apply to your export contract?

The CISG applies to sales of goods between parties whose places of business are in different states, if both states are contracting states or if the rules of private international law lead to the law of a contracting state (Article 1(1) CISG). All EU member states except Ireland and Malta are contracting states (UNCITRAL status page). The CISG does not apply to goods bought for personal, family or household use, unless the seller neither knew nor ought to have known that they were bought for such use (Article 2(a)).

The parties can exclude the CISG (Article 6). A clause that only says “Dutch law applies” does not exclude it, because the CISG is part of Dutch law. The CISG deals with the formation of the contract and the rights and obligations of seller and buyer. It does not deal with the validity of the contract or its clauses, or with the effect of the contract on ownership of the goods (Article 4). A buyer who finds a defect must notify the seller, specifying the nature of the lack of conformity, within a reasonable time after discovering it or when it ought to have been discovered, and in any case within two years after the goods were handed over, unless a contractual guarantee period provides otherwise (Article 39). See our page on the CISG for more detail.

Which law applies to questions the CISG does not cover?

Questions outside the CISG, and contracts to which it does not apply, are governed by the national law that applies to the contract. Courts in the EU member states (except Denmark, which is not bound) determine that law under the Rome I Regulation (EC) No 593/2008. The parties can choose the applicable law (Article 3(1)). Without a choice, a contract for the sale of goods is governed by the law of the country where the seller has its habitual residence (Article 4(1)(a)), subject to the special rules for, among others, consumer contracts (Articles 5 to 8). If the contract is manifestly more closely connected with another country, the law of that country applies (Article 4(3)).

A practical point for foreign businesses: the Dutch rules on general terms and conditions (algemene voorwaarden) in Articles 6:231 to 6:247 of the Dutch Civil Code do not apply between businesses that are not both established in the Netherlands, whatever law governs the contract (Article 6:247(2) DCC). If Dutch law applies, a clause can then only be set aside if applying it would be unacceptable according to standards of reasonableness and fairness (Article 6:248(2) DCC). See our page on general terms and conditions under Dutch law.

Which court decides a dispute with an EU buyer?

Under the Brussels I bis Regulation (EU) No 1215/2012, a company domiciled in an EU member state can in principle be sued in the courts of that member state (Article 4(1)). In a dispute about a sale of goods, it can also be sued in the courts of the place in a member state where, under the contract, the goods were delivered or should have been delivered, unless otherwise agreed (Article 7(1)(b)).

The parties can agree which court has jurisdiction. Such a choice of court is exclusive unless the parties agree otherwise. It must be in writing or evidenced in writing, or in a form that matches the parties’ established practices or a widely known trade usage (Article 25(1)). An electronic communication that provides a durable record counts as writing (Article 25(2)). If the defendant is not domiciled in the EU, each member state applies its own rules of jurisdiction, subject among others to Article 25 (Article 6(1)).

How do you keep ownership until the buyer has paid?

A retention of title (eigendomsvoorbehoud) means that ownership only passes to the buyer once it has paid. Under Dutch law, a retention of title can only secure claims for the price of goods supplied under the contract, for related work and for failure to perform such contracts (Article 3:92(2) DCC). The CISG does not deal with ownership (Article 4(b) CISG).

In a cross-border sale, Dutch private international law applies the law of the country where the goods are at the time of delivery to the property effects of a retention of title (Article 10:128(1) DCC). For goods intended for export, the parties can agree that the law of the country of destination governs those effects, if under that law ownership is not lost until the price has been paid in full. That choice only has effect if the goods are actually imported into that country (Article 10:128(2)). Check the law of the buyer’s country before you rely on the clause.

A retention of title does not keep the risk with the seller. If the CISG applies and the contract involves carriage of the goods, the risk in principle passes to the buyer when the goods are handed over to the first carrier (Article 67(1) CISG), unless the parties agree otherwise, for example through an Incoterm.

What do Incoterms do in an export contract?

Incoterms are standard trade terms published by the International Chamber of Commerce (ICC). The current edition, Incoterms 2020, consists of eleven three-letter rules for business-to-business sales. They allocate costs, risk and obligations such as carriage, insurance and export and import clearance between seller and buyer. Some rules are meant for sea transport only: according to the ICC, CIF is reserved for maritime trade.

Incoterms are contractual terms. State the rule, the place and the edition in the contract. The parties may derogate from the CISG (Article 6 CISG), so an agreed Incoterm in principle takes precedence over the CISG’s default rules on delivery and risk. Who owns the goods is a separate question of property law (see above).

What is international trade law?

In this guide, international trade law means the public law rules for goods that cross borders: customs, tariffs, rules of origin, export controls, sanctions, VAT and product rules. In the EU, most of these rules are set at EU level. The customs union and the common commercial policy are exclusive EU competences (Article 3(1)(a) and (e) TFEU).

It’s also important for companies to understand licensing requirements, country of origin rules, and other related laws that may affect their business dealings with the EU.

Check these rules before you sign a contract or ship goods. Contract disputes and intellectual property questions are matters of private law; see the sections on the contract above.

Having a clear understanding of these regulatory requirements is key to successful operations within the EU market. By taking proactive steps to ensure compliance with all relevant laws, businesses can avoid costly fines or potential liability issues down the line. The next step is ensuring customs compliance when shipping goods into the EU; this will require additional knowledge about specific duties and taxes associated with each product type entering the region.

What does customs compliance involve when exporting to the EU?

Goods brought into the EU from outside are subject to customs control. The rules are in the Union Customs Code, Regulation (EU) No 952/2013 (UCC), which applies uniformly throughout the customs territory of the EU (Article 1(1) UCC). Goods to be placed under a customs procedure, such as release for free circulation or export, must be covered by a customs declaration (Article 158(1)); Union goods taken out of the EU are placed under the export procedure (Article 269(1)). Key elements are tariff classification, customs value, origin and the documents that go with the shipment.

The first step is tariff classification. Import duty is based on the Common Customs Tariff, which uses the Combined Nomenclature of Regulation (EEC) No 2658/87, based on the Harmonized System (HS) (Article 56 UCC). Classification means finding the right subheading of the Combined Nomenclature (Article 57). The tariff is the same in every member state. If the classification is unclear, you can ask customs for a binding tariff information (BTI) decision, which is valid for three years (Article 33).

Each shipment needs the right documents, in practice at least a commercial invoice and transport documents, and for some goods certificates or licences. The customs value is primarily the transaction value: the price actually paid or payable for the goods when sold for export to the EU, with certain adjustments (Article 70(1) UCC). Any person may appoint a customs representative, acting directly (in your name) or indirectly (in its own name on your behalf) (Article 18(1)).

Agree in the contract who acts as importer and pays the import duty and import VAT. When goods are released for free circulation, the customs debt arises when the customs declaration is accepted, and the declarant is the debtor. In the case of indirect representation, the person on whose behalf the declaration is made is also a debtor (Article 77(2) and (3) UCC).

How does EU export control work?

Export controls restrict the export of specific goods, not exports in general. In the EU, the main instrument is the Dual-Use Regulation (EU) 2021/821. An authorisation is required to export the dual-use items listed in Annex I out of the EU (Article 3(1)), and in some cases also for items not listed (Article 3(2)). Transfers within the EU require an authorisation for the items listed in Annex IV (Article 11(1)); a member state can require one for other dual-use items only in specific cases (Article 11(2)).

Depending on where you’re located, there may be additional restrictions imposed by your government or other regulatory bodies. It is therefore essential for exporters to familiarize themselves with their local export control requirements before shipping any product across borders.

Military goods are subject to separate licensing regimes. EU sanctions can also prohibit or restrict trade in certain goods with certain countries, companies or persons. Check the sanctions that apply to the destination and to the parties involved before you sign the contract. Non-compliance can lead to fines and criminal penalties.

When trading internationally, businesses must also consider applicable tariffs and trade agreements which can affect the cost of doing business within the European Union. Knowing which taxes, fees and customs duties are applicable will help reduce overall costs associated with importing and exporting goods. Furthermore, understanding how tariff preferences might impact exports will allow companies to maximize profit margins while staying compliant with all relevant regulations.

Which tariffs and trade agreements apply?

Exporting goods to the EU can feel complicated, with tariffs and trade agreements at every turn. To help you find your way through this complex process, here are five key points to keep in mind:

Export finance – Ensure that any export financing solution allows for smooth cross-border transactions without incurring additional costs or delays.
Free trade agreements and free zones – These are different things. A free trade agreement between the EU and another country can reduce or remove duties for goods that meet the agreement’s rules of preferential origin (Article 64(2) UCC). A free zone is an enclosed part of the EU customs territory designated by a member state (Article 243(1) and (3) UCC).
Anti-dumping measures – The EU can impose anti-dumping duties on dumped products whose release for free circulation in the EU causes injury (Article 1(1) Regulation (EU) 2016/1036).
Trade Agreements – Familiarize yourself with all relevant trade agreements between foreign countries and the EU in order to maximize potential benefits.
Market Access – Understand market access requirements, such as EU product rules, before you ship goods into the EU.

What does EU trade policy mean for exporters?

Trade policy is made by the EU, not by individual member states. The common commercial policy covers, among other things, tariff rates, trade agreements, export policy and measures against dumping or subsidies (Article 207(1) TFEU).

Companies should set up a thorough export compliance program that includes internal audits or external consultants carrying out regular export compliance audits. Companies should also ensure that all documents associated with exports meet applicable regulatory requirements.

It is important for companies to take into account potential customs duties when entering into transactions related to exporting goods to the EU, including verifying origin rules, customs valuation methodologies, tariff classification systems and special regimes such as free zones or VAT rules. Businesses may need assistance from local lawyers or foreign agents in understanding relevant laws, procedures and documentation required for each transaction.

Customs duties and EU trade agreements are the same in every member state. Enforcement is national, however: the customs and market surveillance authorities of each member state check compliance, and VAT rates differ between member states. The next section deals with free zones and VAT.

How do free trade zones and VAT rules work?

Free zones are enclosed areas within the EU customs territory, designated by a member state, where goods are subject to customs supervision (Article 243 UCC). They are not the same as free trade agreements. VAT is due on imports and on supplies of goods by businesses within the EU, with exemptions for, among other things, exports and intra-EU supplies to businesses. Points to keep in mind:

Choose the right Incoterm: FOB (Free On Board) and CIF (Cost, Insurance and Freight) are Incoterms rules; according to the ICC, CIF is reserved for maritime trade. Choose a rule that matches the mode of transport, and agree who handles export and import clearance.
Use a reliable customs representative: a customs representative (customs broker) can make the declarations for you, directly or indirectly (Article 18(1) UCC). It must in principle be established in the EU customs territory (Article 18(2)). Ask whether it acts as direct or indirect representative: in the case of indirect representation, both the representative (as declarant) and the person it acts for are debtors of the customs debt (Article 77(3)).
Ensure proper documentation: prepare the invoice, packing list, transport documents (such as a bill of lading) and, if you claim a lower duty under a trade agreement, the proof of origin required by that agreement (Article 64(2) UCC).
Know your VAT obligations: a supply of goods to a business customer in another member state is exempt in the member state of dispatch if the goods are dispatched or transported to another member state and the customer is identified for VAT in a member state other than that of dispatch and has given its VAT number to the supplier (Article 138(1) VAT Directive 2006/112/EC). The exemption does not apply if the supplier has not filed a correct recapitulative statement, unless it can duly justify the shortcoming to the tax authorities (Article 138(1a)). The customer then pays VAT on the intra-Community acquisition (Article 2(1)(b)). Goods imported from outside the EU are subject to import VAT (Article 2(1)(d)), and supplies of goods transported out of the EU by or on behalf of the seller are exempt (Article 146(1)(a)).

Which certification does an export product need?

There is no single EU export certificate. What a product needs depends on the EU rules for that product. The CE marking may only be affixed to products for which EU harmonisation legislation provides for it, such as toys, electrical equipment and machinery. The manufacturer or its authorised representative affixes it; by doing so, the manufacturer indicates that it takes responsibility for the product’s conformity (Article 30 Regulation (EC) No 765/2008).

Consumer products must also be safe under the General Product Safety Regulation (EU) 2023/988 (GPSR). A product covered by the GPSR may not be placed on the EU market unless an economic operator established in the EU is responsible for it (Article 16(1) GPSR). For a manufacturer outside the EU, that is usually its importer or an authorised representative. See our page on the General Product Safety Regulation.

Also consider export financing and insurance to cover the risks of international trade. Dual-use items may need an export authorisation (see the section on export licences below). Prepare commercial invoices accurately, with the contents, value and country of origin of the shipment, so that customs can process them quickly.

The US Export Administration Regulations (EAR) are United States law, not EU law. They are not a registration system for exports to the EU. If your goods contain items of US origin, check with a US export control specialist whether the EAR apply.

To further guarantee successful delivery of goods to Europe, obtaining proper documentation requirements is essential; these documents include packing lists and, where a lower duty under a trade agreement is claimed or the destination requires it, proof of origin.

Which documents do you need to export to the EU?

Exporters must be aware of the documentation requirements when exporting to the EU. It is important to have all necessary documents in order, and this will help avoid any trade disputes that may arise.

Trade finance documents such as a bill of lading or invoice should be obtained from reliable sources prior to exporting goods. All documents should also include the relevant information for trading within the EU, including tariffs and value-added taxes (VAT). In addition, it is essential to keep records of all transactions related to exporting goods into the EU so that they can be easily accessed if needed in case of a trade dispute.

It is also advisable to consult with experts on legal matters pertaining to EU exports. This ensures that exporters are following correct procedures and regulations while doing business in the EU. Furthermore, consulting with an expert on export law will provide additional insight into what risks exist when exporting goods and how to manage those risks effectively. As such, risk management strategies are important for successful exporting operations within the EU.

How do you manage the risks of exporting to the EU?

Having discussed the essential documentation requirements when exporting goods from one country to another, it is now time to consider risk management strategies.

After all, managing risks can help businesses reduce losses and improve their bottom line by ensuring that they are prepared for any eventuality in the export process. So what steps should be taken when looking at possible risks associated with exporting goods to the EU?

The first step is to identify potential areas of risk. This means assessing everything from economic conditions in your target market, political instability in destination countries, legal restrictions or trade sanctions imposed on certain products and services, as well as how these factors might affect the profitability of an export venture. It also involves taking into account any tariffs applicable to specific commodities or industries within the EU. Once you have identified potential sources of risk, you must then assess how likely those risks are to materialise and put together a plan of action if they do occur.

Finally, it is important to create systems that enable quick responses to changing circumstances during the course of an export operation. This could involve building relationships with reliable third parties who can provide extra resources or services if needed, such as local customs brokers or freight forwarders who know the regulations in different countries and can help you meet them. With solid contingency plans in place before starting an export venture, businesses can limit their exposure to financial loss from unforeseen events or changes in government policy that could otherwise disrupt operations abroad.

With these considerations in mind, companies that want to start trading internationally need to look at which documents are required and understand how to manage the risks of international operations, so they are protected against unexpected outcomes. Now let us take a closer look at licensing and sanction requirements which apply when exporting goods overseas.

When do you need an export licence?

Before exporting goods to the EU, it is necessary for companies to understand various licensing and sanctions requirements. These regulations must be observed in order to ensure that exports comply with international law.

In particular:

Most goods can be exported without a licence. An export licence (authorisation) is required for specific goods, such as the dual-use items listed in Annex I of Regulation (EU) 2021/821 (Article 3(1)) and military goods, and for trade that is restricted by sanctions.
In certain cases, additional licenses may be required depending on the type of product being exported.
Sanctions adopted by the EU, the United Nations (UN) or individual countries must also be taken into account when carrying out international trade activities.
Any breach of these rules can result in penalties and legal action against the company responsible for violating them.

It is therefore important that exporters familiarize themselves with all relevant legislation related to trading abroad prior to engaging in any business transactions across borders. Moreover, they should seek professional advice if they are unsure about any aspect of this process so as to avoid any potential complications down the line. With a clear understanding of applicable laws, businesses will be better equipped to carry out successful operations within the European marketplace without running afoul of local regulations.

The next step focuses on Country Of Origin Rules and Anti-Dumping Measures which pertain specifically to international trade involving EU member states and other nations around the world.

How do rules of origin and anti-dumping measures work?

Exporting goods to the European Union is a big undertaking, requiring careful navigation of numerous laws and regulations. It is important for exporters to understand country-of-origin rules and anti-dumping measures before they start trading across borders.

First, rules of origin determine where goods come from for customs purposes. Goods wholly obtained in one country originate there. If more than one country is involved in production, the goods originate in the country where they underwent their last, substantial, economically justified processing or working, resulting in a new product or an important stage of manufacture (Article 60 UCC). For lower duties under a trade agreement, the preferential origin rules of that agreement apply (Article 64(2)). EU customs law does not generally require a “made in” label; some product-specific rules do require origin labelling.

Secondly, check whether anti-dumping measures apply to your product. A product is dumped if its export price to the EU is lower than a comparable price for a like product in the exporting country (Article 1(2) Regulation (EU) 2016/1036). If dumping causes injury to EU industry and the Union interest calls for intervention (Article 21), the European Commission can impose an anti-dumping duty, which may not exceed the dumping margin (Article 9(4)). Instead of a duty, the Commission can accept an undertaking from an exporter to revise its prices (Article 8). Measures are set per product and country of origin, and often per producer (Article 9(5)).

It is therefore essential for businesses exporting goods into Europe to check both the origin of their goods and any anti-dumping measures beforehand; otherwise they risk paying the wrong duty, with additional duties and penalties later. The next section deals with logistics, cross-border transactions and contracts.

What should you arrange for logistics, cross-border transactions and contracts?

Logistics, cross-border transactions and contracts are key components of exporting goods to the EU. Managing these three aspects correctly is essential for success when doing business in this market. To ensure smooth operations, here are a few things that exporters should keep in mind:

Logistics – Ensure you have secure and reliable transportation options available to get your product across borders quickly and efficiently. Consider engaging with an experienced logistics company to help manage the movement of goods from point A to B.
Cross-Border Transactions – Goods in free circulation move between EU member states without customs duties (Article 28(1) TFEU), but the VAT rules for intra-EU supplies apply. For goods entering or leaving the EU, find out which duties and taxes apply and whether a trade agreement or a customs procedure can lawfully reduce them.
Contracts – Clear contracts prevent misunderstandings and disputes. Set out each party’s rights, obligations and liability, and agree on the applicable law, the competent court, an Incoterm and a retention of title (see the sections above).

It is vital to stay up-to-date on relevant legal requirements related to exporting goods into the EU. Doing so will reduce risk while providing peace of mind that all steps taken during the process are compliant with local laws and regulations governing international trade practices. With adequate preparation now comes time to explore trade finance options available in order to fund export activities moving forward.

Which trade finance options are there?

The trade finance field can seem daunting at first. But with a little bit of guidance, it doesn’t have to be! There are several aspects to consider when you’re looking into financing your export operations to the EU.

First and foremost, there’s the question of risk management. Exporters should make sure they understand their liability in case of non-payment or other risks associated with exporting goods to the EU market. A good way for exporters to manage this risk is through some form of insurance policy that covers potential losses due to unexpected events such as currency fluctuations, political instability, etc.

The second aspect is credit terms and conditions. When negotiating payment terms between buyers and sellers, both parties should agree on clear expectations regarding payment schedules and other provisions before any exports take place. It may also be beneficial to explore options such as letters of credit (LCs) which provide additional security against non-payment by guaranteeing timely payments from buyers.

Finally, exporters should plan ahead when it comes to managing cash flows related to their exports. This includes taking into account costs such as transportation fees, customs duties, taxes, etc., all of which must be factored into total costings before committing to an export order. With proper planning and budgeting, exporters will be able to ensure smooth transactions even if cash flow issues arise during shipments or at later stages once goods have been delivered.

Besides payment terms and insurance, a retention of title can secure payment of the price (see above). Combined with a compliance programme and regular audits, this reduces the financial risks of exporting.

Why set up a compliance programme and audits?

Having discussed trade finance options in the previous section, now it is important to consider compliance programs and audits when exporting goods to the European Union.

Compliance with EU regulations is essential for success in international trade; without it, companies may face significant fines or have their exports blocked altogether.

To ensure that all exported products meet legal requirements, businesses should put in place a thorough compliance program. The components of such a program include:

Creating an effective system for tracking goods from origin to destination
Ensuring accurate product labeling and documentation
Establishing detailed record-keeping processes
Implementing regular training sessions on export controls for personnel involved in exports
Periodically auditing operations against relevant laws and regulations

Compliance programs and audits are essential tools for ensuring successful international business transactions within the European Union. Companies must remain vigilant in following up-to-date policy changes as well as implementing strong internal measures to guarantee full compliance with rules set forth by the EU regulatory bodies. With this information at hand, businesses can confidently move on to explore other aspects of exporting goods into the EU like export restrictions and product classification.

Which export restrictions apply to your product?

It is vital to be aware of export restrictions and product classification when exporting goods to the EU. The Netherlands, being a member state of the European Union, abides by strict standards regarding imported products.

Before sending any item into the country, it is imperative that one understands both trade laws as well as product regulations.

Firstly, one must understand what constitutes an export restriction in order to abide by them correctly. Export restrictions include legal limitations imposed on exports for either economic or political reasons. It is essential that exporters are aware of these restrictions before initiating their shipment so they can avoid potential delays and fines from customs authorities.

Secondly, goods must be classified in the Combined Nomenclature, the EU goods nomenclature based on the Harmonized System of the World Customs Organization (Articles 56(2)(a) and 57 UCC). The right code determines the duty rate and, where appropriate, which other EU trade measures apply (Article 56(1)). A binding tariff information decision gives certainty (Article 33).

Overall, understanding export restrictions and product classification is key when conducting business in the EU market – especially for imports coming from outside Europe’s borders. Knowing the relevant trade laws and regulations lets businesses move through this complex process smoothly while avoiding unnecessary obstacles.

Frequently asked questions about exporting goods to the EU

Does the CISG apply when I sell goods to a business in another EU country?

In most cases, yes. The CISG applies if both parties have their places of business in different contracting states (Article 1(1)(a) CISG). All EU member states except Ireland and Malta are contracting states. The parties can exclude it (Article 6); a choice of “Dutch law” alone does not.

Do I pay customs duties when I ship goods from the Netherlands to another EU country?

No. The EU is a customs union without customs duties between member states (Article 28(1) TFEU). A supply to a business customer that is VAT-identified in another member state and has given its VAT number is exempt from VAT in the member state of dispatch, provided the goods leave the member state of dispatch and the supplier files a correct recapitulative statement (unless it can duly justify a shortcoming); the customer pays VAT on the acquisition (Articles 2(1)(b) and 138 VAT Directive).

Which court decides a dispute with a buyer in another EU country?

The court chosen in the contract, if the choice of court meets Article 25 Brussels I bis. Without a choice, a buyer domiciled in the EU can be sued in its own member state (Article 4(1)) or in the courts of the place in a member state where the goods were or should have been delivered (Article 7(1)(b)).

Does a retention of title still protect me once the goods are abroad?

Not automatically. Under Dutch private international law, the property effects are governed by the law of the country where the goods are at delivery (Article 10:128(1) DCC). For export goods, the parties can choose the law of the country of destination, if under that law ownership is retained until full payment and the goods actually arrive there (Article 10:128(2)).

Who must be established in the EU when I sell consumer products to the EU?

A product covered by the GPSR may only be placed on the EU market if an economic operator established in the EU is responsible for it (Article 16(1) GPSR). Its name and contact details must be on the product, its packaging, the parcel or an accompanying document (Article 16(3)).