The European Union is set to introduce the "European Product Act" (with the draft expected to be officially released on October 6, 2026) to comprehensively tighten import regulations for cross-border e-commerce. For European import buyers, this legislation will introduce all-around compliance pressures and rising costs, primarily reflected in the following four core dimensions:
Significantly Higher Thresholds for Procurement and Supplier Management
The new regulations mandate that all non-EU products circulating within the EU must have an importer or authorized representative based within the EU to assume ultimate liability, effectively closing loopholes that allowed foreign sellers to evade oversight. Consequently, import buyers can no longer rely solely on low-cost suppliers with unclear compliance credentials. They must strictly verify product certifications and responsible party information; otherwise, they face the risk of customs clearance blockages.
Surging Costs for Product Traceability and Digital Compliance
The legislation introduces a "Digital Product Passport" (DPP) mechanism. Before placing goods on the EU market, import buyers and online platforms must verify whether the products possess a DPP or the manufacturer's liability registration records. This requires buyers to implement penetrating supply chain management to ensure that data across the entire lifecycle-from raw materials to finished products-is fully traceable, significantly increasing compliance auditing and data management costs.
Further reading:
EU Customs New Regulations 2026: What Impact Will They Have on Your Imports from China?
Direct Increase in Import Taxes and Operational Costs
The new rules establish a "market surveillance fee mechanism" for products entering from third countries. This fee is proportional to the costs incurred by market surveillance authorities in fulfilling their inspection duties and will ultimately be borne by the importer. Furthermore, the legislation proposes abolishing the VAT and customs duty exemptions for cross-border parcels valued under €150, while introducing a "deemed importer" liability mechanism that requires platforms or logistics service providers to assume importer compliance obligations. These measures will directly elevate buyers' import taxes and overall operational costs.
Joint Legal Liability and Supply Chain Penetration Risks
As the revised Product Liability Directive (PLD) and regulations such as the "Prohibition of Products Made with Forced Labour" take effect, import buyers face expanding legal risks. The new directives include authorized representatives and fulfillment service providers within the scope of potential liable parties. Meanwhile, forced labor regulations mandate full-chain penetration inspections. If non-compliance in labor practices is found at any stage of the product's assembly or components, the entire shipment may face detention, return, or permanent bans. Buyers must ensure labor and production compliance throughout their entire supply chain (including multi-tier upstream suppliers) to mitigate joint legal liabilities.
The implementation of the "European Product Act" and its supporting regulations marks a shift in EU market regulation from "post-hoc accountability" to "pre-market access and full-chain traceability." European import buyers must proactively restructure their supply chain compliance systems and integrate compliance reviews into the procurement and product design phases to adapt to increasingly stringent market entry requirements.
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