Which Country’s Rules Apply When I Sell Across the EU?
GPSROmnibus DirectiveThe short answer: EU-wide regulations give you a single baseline that applies everywhere, but a number of national obligations follow the country you are selling into. When you ship across the EU, you meet the EU rules once, then add the destination country’s specifics for each market you serve.
EU-wide regulations are the baseline
Regulations such as the GPSR (product safety), the Omnibus rules (price transparency and reviews), the PPWR (packaging) and the European Accessibility Act apply across all 27 member states. Their core requirements – a safe product, a responsible person in the EU, honest price reductions, accessible e-commerce – do not change from one country to the next. Get these right and you have your common foundation for the whole single market.
National transposition adds detail
Where EU rules take the form of directives, each country writes them into national law and can add detail. Germany’s price-display rules sit in the Preisangabenverordnung; Italy’s consumer rules are in the Codice del Consumo; Spain uses the Texto Refundido consumer statute; France layers on strong consumer-protection practice. The substance is harmonised, but the exact wording, disclosures and enforcement bodies are national.
Language follows the customer
Consumer information must generally be in the language of the destination country: French for France (the Toubon law), Italian for Italy, Spanish (and sometimes co-official regional languages) for Spain, German for Germany. This covers product descriptions, safety warnings, instructions and the required pre-contractual information. A single English storefront is not enough for these markets.
EPR is per destination country
Extended Producer Responsibility registrations are national and depend on where your goods and packaging end up. If you ship to Germany, you register in the LUCID packaging register before selling. If you ship to France, you deal with the REP system and a unique identifier via ADEME, plus packaging EPR. Italy uses CONAI; Spain applies Royal Decree 1055/2022. You need the right EPR registration for each destination country you supply, not one blanket registration.
In practice
- Meet the EU-wide regulations once as your baseline.
- For each destination country, add local language, transposition detail and EPR registration.
- Confirm specifics with the named national authority, as they change over time.
See our country hubs for France, Italy, Spain and Germany for the destination-specific detail.