EU compliance checklist for non-EU sellers

EU compliance checklist

Follow this end-to-end checklist to enter EU & UK markets with confidence. Content here is operational guidance only—always confirm the legal position with your advisors.

FAQ

What is the fastest way for a non-EU seller to confirm VAT/IOSS obligations?
Run the Readiness Check with your shipping origins, consignment values, and storage locations. If you ship only from outside the EU and consignments stay ≤ EUR 150, IOSS is usually appropriate. Any EU storage creates fixed establishment risk, requiring local VAT plus OSS for cross-border B2C. Keep warehouse addresses, SKU maps, and marketplace liability proofs handy so registrations and filings reconcile.

Do I need both GDPR and UK GDPR compliance if I sell into the UK?
Yes. Treat the UK as a separate regime: store consent logs per jurisdiction, localize copy, and respect Do Not Track/Global Privacy Control by default. For ads and analytics, block scripts until consent. Log DSARs with SLA tracking. If you reuse EU consent data in the UK, document transfer safeguards and retention policies so audits see a clear lawful basis.

How do I know if my packaging requires EPR registration in France or Germany?
France requires an eco-organisme contract and Triman markings for packaged goods placed on the market; thresholds are effectively gone. Germany requires LUCID registration plus a dual system before first parcel ships. Marketplace fulfillment does not remove this duty—you must provide IDs. Keep packaging weight data, contracts, and invoices aligned to each brand/SKU and mirror IDs on product pages, invoices, and marketplace listings.

Does CBAM apply if I import small volumes?
If covered goods stay at or below 50 tonnes per category in a rolling 12 months, you may use the small-importer simplification but still file quarterly reports. Track CN codes, tonnes, and supplier emissions data early. If volumes grow, be ready to appoint a CBAM declarant, purchase certificates, and reconcile emissions vs foreign carbon prices.

At a glance timeline

Discovery and scoping

Market and channel assessment

Traffic & order sources

Insight collection

Metrics to capture

• Split historical traffic/orders by EU country to test threshold exposure.
• Map channel mix (Shopify, Woo, custom Next.js, marketplaces) because VAT liability differs.

Documentation

Systems

• Export platform tax settings to benchmark against EU VAT explained.
• Log marketing pixels ahead of GDPR basics implementation.

Inventory planning

Storage questions

Actions

• List every 3PL/FBA/warehouse location; EU storage implies fixed establishment.
• Flag goods shipping directly from outside EU to evaluate IOSS vs OSS.

Supplier data

Actions

• Request HS/CN codes per SKU—needed for packaging eco-fees and CBAM overview.
• Collect packaging weight (paper, plastic, glass) to preload French & German packaging forms.

VAT and IOSS workflow

Evaluate schemes

Threshold checkpoints

Local vs OSS

Decision factors

• If EU-wide B2C sales stay under EUR 10k, you can apply “home” VAT; beyond that, opt for OSS or local VAT.
• Consignments ≤ EUR 150 qualify for IOSS as long as goods ship from outside EU and no EU storage is involved.

Fixed establishment

Decision factors

• EU storage or staff triggers local VAT regardless of IOSS.
• Marketplaces may handle VAT, but you still need VAT numbers for returns and audits.

Filing readiness

Document pack

Contents

• Certificate of incorporation + translations.
• Proof of bank account/IBAN for VAT refunds.

Timeline control

Owners

• Finance owns OSS/local submissions; integrate with treasury calendar.
• Legal validates power of attorney for intermediaries.

Documents you'll need

GDPR and consent deployment

Lawful basis selection

Consent-first channels

Data capture

Controls

• Block analytics/ads until consent stored; the GDPR Generator ships ready scripts.
• Use server-side events only after matching consent to order IDs.

Legitimate interest

Controls

• Document balancing tests for transactional emails.
• Provide opt-outs in both EU and UK local languages.

Banner, DSAR, and logging

Implementation beats

Shopify/Woo/Next.js

Steps

• Shopify: Customer Privacy API + theme app blocks.
• Next.js: hydrate banner via middleware so Do Not Track works globally.

DSAR & audit trail

Steps

• Route DSAR form into your CRM with SLA tracking.
• Store consent logs for six years minimum per ICO guidance.

Packaging, DSA, and sustainability

EPR + DSA tasks

France focus

Eco-organisme

Checklist

• Register with Citeo/Léko, embed Triman logos on packaging/product page.
• Surface operator info in footer per French & German packaging.

Marketplace mirroring

Checklist

• Update IDs inside Amazon FR/FR marketplace dashboards.
• Sync translations with privacy policy from GDPR basics.

Germany focus

LUCID steps

Checklist

• Register brand in ZSVR portal, sign a dual system contract.
• Publish DSA operator/contact/complaints snippet across sites.

Proof retention

Checklist

• Archive fee invoices; marketplaces often request proofs during audits.
• Pair VAT IDs with packaging IDs to avoid account suspensions.

Typical timelines & costs

CBAM planning

Scope confirmation

Covered goods

Steel/aluminum examples

Tasks

• Map CN 7206–7217 (steel) and 7601–7609 (aluminum) SKUs.
• Validate import volumes; under 50 tonnes annually may qualify for small-importer relief.

Fertilizer/other goods

Tasks

• Tag CN 3102–3105 fertilizers, cement, hydrogen, electricity flows.
• Link suppliers to embedded-emissions statements.

Reporting cadence

Quarterly filings

Declarant prep

Steps

• Appoint an authorized CBAM declarant and register before 2026.
• Align data warehouse exports with the CBAM Readiness Tool.

Evidence storage

Steps

• Keep supplier attestations, customs entries, and emissions calculations for four years.
• Cross-check totals with finance carbon budgets.

Ready to check your obligations? Run the Readiness Check → Launch the workflow

Next actions

• Run the VAT/IOSS Checker using your origins and consignment values.
• Deep dive via EU VAT explained before filing.
• Log owners and timelines in the Readiness Wizard.