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Selling on Amazon, bol.com and Cdiscount: seller obligations

Selling products made in China on Amazon, bol.com or Cdiscount requires appointing a responsible operator established in the European Union, obtaining an EPR identifier in France, and, for packaging sold in Germany, registering with the LUCID register, before you even open your first listing. This article covers what each marketplace requires, the documents to gather, and the mistakes that get a seller account suspended.

Updated September 26, 2026

GPSR: the common baseline for all three marketplaces

Regulation (EU) 2023/988 on general product safety, known as GPSR, has applied since December 13, 2024. It replaces Directive 2001/95/EC and applies directly in all Member States, with no transposition law needed. It covers non-food consumer products, whether new, used or refurbished, except for categories under their own regime, medicines, foodstuffs, animal feed, plants and live animals, and plant protection products.

Direct consequence for a seller importing from China: a product can only be placed on the market if there is an economic operator established in the Union, responsible for the tasks under Article 4(3) of Regulation (EU) 2019/1020, whether manufacturer, authorized representative, importer, distributor or fulfilment service provider. Without this operator and its visible contact details, no serious marketplace should list the item. The Commission published implementation guidelines on November 19, 2025.

  • In force since December 13, 2024, directly applicable across the whole Union
  • An economic operator established in the Union is mandatory before placing goods on the market
  • Its contact details must appear on the product, the packaging, the parcel or an accompanying document
  • Marketplaces must verify its existence before listing the product

Read next CE Marking on Imports: What It Covers and How to Verify

EPR France: the unique identifier marketplaces require

Since January 1, 2022, any producer under extended producer responsibility, manufacturer, distributor or importer, who places products subject to an EPR scheme on the French market must register with the SYDEREP register run by ADEME and obtain a unique identifier, a fifteen-character code starting with the letters FR. This identifier must appear in the terms and conditions of sale and be given to any trade buyer, including marketplaces, which are required to collect it before allowing a seller to publish listings.

Lacking the identifier exposes a seller to a fine of up to 30,000 euros, plus a daily penalty of up to 20,000 euros if the number has been withdrawn and the seller remains in breach. It is obtained through an approved eco-organization, under the collective scheme, or directly from ADEME, under the individual scheme. Details of the schemes and how the eco-contribution is calculated are covered in our dedicated article on EPR.

Read next EORI number: what it is for and how to get it

EPR Germany: the LUCID register for packaging

Any company that first places packaged goods into commercial circulation in Germany, whether manufacturer, brand or online seller, must register free of charge with the LUCID register, run by the Zentrale Stelle Verpackungsregister. There is no minimum threshold: neither the size of the company nor the volume of packaging exempts anyone from this registration from the very first sale delivered to Germany.

Registering with LUCID is not enough on its own: it comes with a participation contract with an approved dual system, with data declared identically to both bodies. The European PPWR regulation, (EU) 2025/40, provides in its Article 45 for an authorized representative for any producer not established in the Union, with a deadline announced for August 12, 2026; its transposition into German law remained, at the time of writing, to be confirmed.

  • Free LUCID registration, no threshold on volume or company size
  • Mandatory participation contract with a dual system for packaging concerned
  • German authorized representative announced for August 12, 2026 under the PPWR regulation, German transposition to be confirmed

Read next Importing packaging from China: boxes, cartons, printing

Selling on Amazon: product compliance and the responsible person

Amazon France's official seller page requires product compliance across its entire life cycle, electrical and electronic, toys, chemicals, cosmetics and pharmaceuticals, textiles, food, medical devices, and the environment. For non-EU brands using Fulfilled by Amazon, the platform collects the contact details of a responsible person established in the Union, an obligation in force since July 16, 2021 for CE-marked products. Amazon states that this page does not constitute legal advice and that verification remains the seller's responsibility.

Several sourcing agencies report tighter checks since GPSR came into application, with a fourteen-day deadline to submit requested documents, test report, declaration of conformity, technical data sheet, supplier invoice, under threat of the listing being blocked. This timeframe has no confirmed official source directly on Amazon's pages; keep these documents ready before listing rather than in reaction to a request.

Read next Product technical documentation: what the importer must hold

Selling on bol.com from outside the European Union: what is required

According to agencies specializing in supporting bol.com sellers, to be confirmed directly on the official partner page before any steps, a seller established outside the European Union cannot register directly: an entity established in the Union and a VAT registration, in the Netherlands and potentially in Belgium, are required, along with stock physically located in the Union. Each product must carry an EAN or GTIN code, or an ISBN for books.

The same sources indicate delivery within one to eight business days, returns accepted within thirty days, and a customer response within twenty-four hours. GPSR also requires a responsible person established in the Union for a large share of the products sold on the platform. A seller outside the Union can apply through a dedicated form, opened once a year.

  • Entity and VAT registration in the European Union required for a non-EU seller
  • Stock located in the Union, EAN or GTIN code on each listing
  • Delivery within 1 to 8 business days, returns within 30 days, customer response within 24 hours

Read next Import VAT and Reverse Charge: How It Works in France

Selling on Cdiscount Marketplace: SIRET and seller responsibility

Cdiscount Marketplace requires a SIRET number tied to a professional activity; all legal statuses are accepted, sole proprietorship, individual enterprise, EURL, SARL, SAS or SASU. The platform explicitly asks sellers to verify that the manufacturer and importer have met their obligations, and to refrain from selling a product they are not certain complies, which places responsibility on whoever publishes the listing, not only on the originating factory.

Subscription and commission figures circulate on third-party sites, without direct confirmation on the official seller pages at the time of writing: check these amounts on Cdiscount's seller portal before registering. The application file undergoes manual review before activation.

Read next Importing from China: the complete journey, from idea to delivered product

Mistakes that get a seller account suspended

Most suspensions come from an incomplete file, not a genuinely dangerous product: the seller discovers the requirement at the check, when it should have been prepared before ordering from the factory.

  • No responsible person established in the Union, or contact details missing from the product and packaging
  • Unable to produce the risk analysis, technical documentation or test reports within the requested deadline
  • Selling categories subject to EPR in France without a valid unique identifier
  • Packaged goods shipped to Germany without LUCID registration or a contract with a dual system
  • Invoices and company information inconsistent from one marketplace to another, mismatched SIRET or company name
  • Stock located outside the Union on a marketplace that requires local stock, with delivery and return deadlines not met
  • No response to a safety alert or customer report, when the regulation requires cooperation with authorities

Read next Non-conforming goods: what to do with a Chinese supplier

What Sorva does for you

Sorva is a brokerage and trading house between Europe and China, with a Chinese-speaking team based in Guangzhou and a team in Paris. We buy the goods in China and resell them delivered, which places us directly in the chain of responsibility targeted by GPSR, EPR and LUCID: before ordering, we frame the file to gather from the factory, risk analysis, technical documentation, packaging data useful for your declarations, and we have the actual product checked through a pre-shipment inspection.

Sorva also designs online stores and works on search optimization, our own site being published in twenty-four languages. A regulatory compliance study frames the obligations specific to your product and your sales markets, a technical product file gathers the evidence marketplaces expect, and the Produce and deliver formula handles production, inspection and delivery. In most cases, you open a file with us and we take a commission on the ex-works value.

What to remember

Before your first listing on Amazon, bol.com or Cdiscount, line up a responsible operator established in the Union for GPSR, a unique EPR identifier if your category is covered in France, and a LUCID registration if your packaging ships to Germany. Account suspensions almost always come from an incomplete file discovered at a check, not a genuinely dangerous product.

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Frequently asked questions

01Do you need a responsible operator established in the Union to sell products made in China on Amazon?
Yes. GPSR requires an economic operator established in the Union before any product is placed on the market, and Amazon specifically collects the contact details of a responsible person for non-European brands using Fulfilled by Amazon, an obligation in force since July 16, 2021 for CE-marked products.
02What is the unique EPR identifier and why do marketplaces ask for it?
It is a fifteen-character code starting with FR, issued by ADEME since January 1, 2022 to any producer placing products subject to an EPR scheme on the French market. Marketplaces must collect it before letting a seller publish listings, under threat of penalties for both the marketplace and the seller.
03Does the LUCID register in Germany apply to small volumes?
Yes, with no exception. Free registration with the Zentrale Stelle Verpackungsregister is mandatory from the very first packaged item placed in commercial circulation in Germany, regardless of company size or the volume of packaging involved.
04Can you sell on bol.com without being established in the European Union?
Not directly, according to information available from specialized agencies: an entity and a VAT registration in the Union, with stock located in the Union, are expected. A seller established outside the Union can apply through a dedicated form, opened once a year, to be confirmed on the official partner page before any steps.
05What document do you need to open a seller account on Cdiscount Marketplace?
A SIRET number tied to a professional activity, whatever legal status you use. The platform also asks the seller to verify that the manufacturer and importer have met their compliance obligations before listing a product.
06What happens to a listing that doesn't provide its compliance documents in time?
The listing gets blocked until the seller submits the requested documents, risk analysis, declaration of conformity, technical data sheet, supplier invoice. Gathering these documents before listing avoids this interruption.
07Does dropshipping change a seller's regulatory obligations?
No. The professional remains fully responsible for proper performance of the contract, compliance included, even when shipping is handled by a partner supplier. The fourteen-day right of withdrawal applies to the consumer the same as with a seller's own stock.