For years, a Chinese company could sell into Europe while keeping almost everything – staff, documentation and operations – in China.
That model is becoming harder to sustain.
Depending on what it sells, imports or plans to build, a company may now need a responsible economic operator, an EU importer, a customs representative, local fulfilment or, in the case of a major industrial investment, a far deeper presence inside Europe.
A marketplace seller, an aluminium importer and a battery manufacturer planning a European factory operate under very different rules. Yet they increasingly face the same underlying reality: Europe can no longer be treated simply as the place where the goods arrive.
There is no single regulation driving this shift. Several changes are pushing in the same direction, moving more of the work, documentation and responsibility associated with selling into Europe inside Europe itself.
Three Companies, Three Different Obligations
The Consumer-Goods Seller
Since 1 July 2026, consignments valued below €150 have been subject to a flat customs duty of €3 per separate tariff item. For a product selling for little more than €10, that can remove a substantial part of the margin.
It does not make direct-from-China e-commerce impossible. Sellers can raise prices, consolidate shipments or move inventory into Europe, but each response changes the operating model.
Once stock sits in a European warehouse, the issue is no longer just shipping. VAT registrations, import arrangements, returns and responsibility for the goods all move closer to the centre of the business.
Product safety adds another layer. Under the EU’s General Product Safety Regulation, in force since 13 December 2024, covered products must have a responsible economic operator established in the Union. Depending on the supply chain, this may be an EU manufacturer, importer, authorised representative or, in certain cases, a fulfilment provider.
This is more than an address on a label. The role can carry obligations concerning documentation, communication with authorities and product risks.
None of this means that every Chinese manufacturer needs a European subsidiary. In many cases, the required role can be provided externally; what changes is that part of the compliance structure can no longer remain entirely in China.
The Aluminium or Steel Importer
CBAM shows the same shift from another angle.
Since 1 January 2026, the Carbon Border Adjustment Mechanism has operated under its definitive regime. Importers exceeding the 50-tonne annual threshold for covered goods must generally obtain authorised CBAM declarant status.
That formal responsibility sits in Europe, yet much of the information required to meet it originates in China. If an importer wants to report actual rather than default emissions, it needs reliable production data from the manufacturer.
The first annual declaration covering 2026 imports is due by 30 September 2027.
The Chinese producer holds the production data. The European importer carries the reporting obligation. Between them, someone has to turn one into the other.
That requires an understanding of the product, CBAM methodology, customs documentation and the expectations of European authorities. The commercial opportunity lies in making that process work.
The Investor Planning Battery or Vehicle Production
The third case is much larger.
In March 2026, the European Commission proposed the Industrial Accelerator Act. It is not yet law, and its final form may still change.
The proposal would cover manufacturing investments above €100 million in batteries and energy storage, electric vehicles, photovoltaics and critical raw materials, where the investor comes from a country with more than 40% of global manufacturing capacity in the relevant sector.
Such projects would have to meet a series of conditions relating to areas such as equity participation, joint ventures, technology transfer, R&D and EU procurement. One proposed requirement would be mandatory: at least 50% of the workforce would have to come from the EU.
These rules are not aimed at ordinary exporters, but they reveal the direction of European industrial policy.
For the largest projects, it may no longer be enough simply to build a factory in Europe. The question will increasingly be how much employment, technology, procurement and economic value remain there.
Law firms, recruitment companies, tax advisers, engineering firms and compliance specialists cannot satisfy those requirements for the investor. They will, however, be needed to make the investment work.
Three Different Kinds of Local Support
The mistake would be to treat all these cases as the same opportunity. They are not.
In practice, European service providers may perform three quite different roles.
Formal responsibility.
A responsible economic operator, tax representative, customs representative or authorised CBAM declarant may take on obligations assigned directly by law.
Support with the client’s obligations.
A law firm, accountant, CBAM adviser or compliance specialist may prepare documentation and manage the process without becoming the importer or responsible entity.
Operational support.
A warehouse, fulfilment company, payroll provider or returns operator performs the work needed to run the business locally even when the legal responsibility remains with the client.
The distinction matters. A formal role should not be sold as a convenient add-on: it may require insurance, procedures, access to documentation and the ability to reject clients or products that create unacceptable risk.
What This Means for European Service Providers
Many of the services Chinese companies need in Europe already exist. What is changing is the client, the context and the way those services are bought.
A law firm may help with company formation, distribution agreements, product liability, import structures or major investments.
An accounting or tax firm may handle VAT and IOSS registrations, multi-country reporting, fiscal representation or payroll.
A customs agency or freight forwarder may help move a client from individual parcels to bulk imports, handle customs clearance and support CBAM.
A warehouse or fulfilment provider can give a Chinese company a real European operating presence without requiring it to build its own logistics infrastructure.
A product-compliance specialist can support technical documentation, labelling and communication with market-surveillance authorities.
And recruitment, HR and payroll firms may see demand from both small local sales teams and large industrial projects.
The Chinese client, in other words, is not always looking for someone to “take over compliance”. It may need a formal European role, a properly designed process or simply someone to do work that cannot realistically be done from China.
Can a Chinese Company Find You?
For European service providers, capability is only part of the equation; the service also has to be understandable.
Can you explain exactly what problem you solve, what documents you need, what the outcome is and how long the process takes?
Can you define where your responsibility begins and ends?
Can you work with a client remotely, across languages, jurisdictions and payment systems?
And, crucially, can a Chinese company actually find and understand your service?
That last question is easy to underestimate. A potential client may not know the European name of the role it needs, or even what type of company normally performs it.
Before choosing a provider, it first has to understand the problem.
What This Does Not Mean
This shift should not be exaggerated.
Not every Chinese company selling into Europe needs a subsidiary, office or employees. External providers, importers and distributors will remain sufficient in many models.
Nor is this a mass market. Demand is specialised, fragmented and often triggered only by a change in sales model, regulatory scrutiny or an investment decision.
Regulation does not automatically create clients. Sales cycles can be long, payment risk matters, and formal responsibility can create substantial liability.
A European company should not become an importer, representative or responsible economic operator merely to win business. Those roles make sense only where the provider can control the risk, obtain complete documentation and enforce the conditions under which it agrees to act.
Conclusion
EU regulation does not prescribe a single way to enter Europe, but it is steadily moving work away from the border and deeper into the supply chain and operating structure of the company.
One product needs a responsible economic operator; another requires an importer capable of dealing with emissions reporting. A major industrial project may depend on employment, technology, ownership and the share of the supply chain located within Europe.
Each creates a different demand for local expertise.
Not everything can be handled from Shenzhen.
Not because Chinese companies lack the capability to operate internationally, but because European rules increasingly assign certain functions to entities inside the EU — and because some forms of business simply require infrastructure on this side of the market.
For European service providers, the key question is therefore not only whether Chinese demand exists.
It is whether a Chinese company can find their service, understand what it does and begin working with them when the need arises.
EnterChina helps European B2B service providers become visible to Chinese companies planning or expanding their activities in Europe. Through the Chinese-language Xijinmenhu (西进门户) platform, we present their services, help Chinese companies identify the right specialist and support the first contact between the parties. We do not act as an intermediary in the trade of goods and do not provide legal advice.
Sources
Council of the European Union; European Commission; EUR-Lex — sources covering the 2026 customs changes, GPSR, CBAM and the proposed Industrial Accelerator Act.