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Six EU Changes That Increase Chinese Exporters’ Need for Local Support

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5 days ago

Law stated as at 11 September 2026.

EU regulations adopted over the past two years have had a common effect for Chinese exporters, even though this is rarely their stated purpose: a growing share of the work involved in selling Chinese products in Europe now has to be carried out in Europe.

In some cases, EU law requires a company or other economic operator established in the Union. In others, the formal obligation falls on the European importer, who then needs data and documents from the supplier. Other changes increase the cost of shipping directly from China or create new requirements around accessibility and product data.

Below are six changes, grouped by the way they create demand for local services.

1. GPSR: products need a responsible economic operator in the EU

Mechanism: EU law requires an economic operator established in the Union.

Article 16 of Regulation (EU) 2023/988 on general product safety states that a product covered by the GPSR cannot be placed on the EU market unless there is an economic operator established in the Union responsible for specific tasks related to that product. The operator’s name and contact details must appear on the product, packaging, parcel or accompanying documentation.

The operator’s responsibilities include checking that the manufacturer has prepared the required technical documentation and complied with information and labelling requirements, providing documents to market surveillance authorities and cooperating with authorities on product safety issues.

A manufacturer in China therefore needs to appoint an operator that is genuinely present in the EU and able to carry out these tasks in dealings with European authorities.

Online marketplaces also enforce this requirement. If the responsible economic operator is missing or incorrectly identified, a product listing can be restricted or removed. Compliance therefore has a direct impact on the ability to sell.

2. PPWR: EPR obligations remain national

Mechanism: packaging registration and reporting are handled at Member State level, while the rules on authorised representatives have to be checked market by market.

Regulation (EU) 2025/40 on packaging and packaging waste has applied since 12 August 2026. It creates a common framework for extended producer responsibility, but many practical obligations still remain tied to individual Member States.

A manufacturer in China therefore has to check each market in which it first makes packaging or a packaged product available. Registration, quantity reporting, fees and the way producer responsibility is handled are linked to the national EPR system.

The PPWR allows Member States to require producers established outside the EU to appoint an authorised representative for extended producer responsibility. It does not create one automatic rule requiring every non-EU producer to appoint such a representative in every EU country.

A Chinese seller targeting Poland, Germany, France, Spain and Italy therefore enters five national systems. For each market, the company has to check registration requirements, reporting rules, fees and whether local law requires an authorised representative.

The Commission has also proposed suspending part of Article 45(3) until 1 January 2035. The proposal remains in the legislative process. It would still allow Member States to impose requirements on non-EU producers or use other measures to ensure traceability and enforcement of EPR obligations.

In practice, each market still has to be handled separately.

3. The €3 duty on low-value parcels: a change already in force

Mechanism: the economics of direct shipping from China are changing.

Since 1 July 2026, low-value e-commerce consignments worth up to €150 have been subject to a temporary flat customs duty of €3. The amount applies to each separate tariff classification contained in a parcel, rather than to the parcel as a whole.

If a package contains five identical T-shirts classified under the same code, the duty is €3. If it contains a T-shirt and a watch under two different classifications, the duty is €6.

The temporary system is due to remain in place until 1 July 2028, when low-value goods will move to standard tariff rates under the reformed EU customs system. From 1 November 2026, product identifiers will also become mandatory in e-commerce customs declarations. An EU-wide handling fee for e-commerce parcels has also been agreed, although the Commission has not yet set its level.

For orders containing several different types of goods, the cost therefore rises with the number of tariff classifications rather than with the value of the order. This has the biggest impact on business models based on shipping large numbers of low-priced products directly from China to European consumers.

An alternative becomes more attractive: importing goods in larger batches, clearing them in Europe and fulfilling individual orders from stock already held in the EU.

That model creates local demand for warehousing, fulfilment, returns handling, customs services, VAT registrations and the right OSS setup. Goods already stored in the EU do not fall under IOSS, because IOSS applies to import sales of consignments up to €150 shipped from a third country directly to the consumer.

Moving stock to Europe also changes the way payments are handled between the seller, importer, marketplace, payment provider and other parties involved in the transaction. Depending on the business model, local payment arrangements and financial flows may also need to be reorganised.

For Polish service providers, this is probably the most tangible source of new demand among the six changes discussed here. Poland has both the expertise and the physical infrastructure, including warehouse capacity, logistics networks and experience in handling goods distributed across several European markets.

4. CBAM: the obligation sits with the importer, but the supplier feels the pressure

Mechanism: the European importer needs data from the Chinese manufacturer.

The definitive CBAM regime has applied since 1 January 2026. Importers exceeding the 50-tonne threshold for goods covered by the mechanism must obtain authorised CBAM declarant status, report embedded emissions and purchase the required number of certificates.

The legal obligation sits with the European importer or, in certain cases, its indirect customs representative. The Chinese manufacturer does not become a reporting entity towards EU authorities simply because its products are covered by CBAM.

The importer still needs to know the embedded emissions of the products it buys and depends on information supplied by the manufacturer. A supplier that cannot provide this data in the required format and according to the applicable methodology makes compliance more difficult and more expensive for the European customer.

The work is therefore divided between both sides. The manufacturer needs to collect, prepare and verify emissions data. The European importer has to manage declarant status, reporting and CBAM certificates.

5. EAA: accessibility also applies to online stores

Mechanism: new compliance work for companies selling directly to European consumers.

The European Accessibility Act, Directive (EU) 2019/882, has applied since 28 June 2025. It covers, among other things, e-commerce services offered to consumers in the EU, including an online store operated by a Chinese company selling directly into the European market.

The requirements concern the way customers use the store, including the interface, purchasing process, presentation of information and customer service. Compliance may require an accessibility audit, technical changes and documentation of the measures taken.

The exact scope has to be assessed case by case. The Directive includes an exemption for micro-enterprises providing services and is implemented through national legislation. Detailed obligations, supervision procedures and penalties can therefore differ between Member States.

A Chinese seller has to assess its store against the requirements of the markets in which it operates instead of treating accessibility as one standard EU-wide audit.

6. Digital Product Passports: the first binding deadlines are already set

Mechanism: companies need to collect, organise and make available more product data.

The Ecodesign for Sustainable Products Regulation provides the framework for gradually introducing Digital Product Passports for different product groups. Specific obligations will be introduced through legislation covering individual categories.

The first binding deadline is 18 February 2027. From that date, battery passports will be mandatory for batteries for light means of transport, industrial batteries with a capacity above 2 kWh and electric vehicle batteries.

For other product groups, the timetable is still being developed. Steel, textiles, tyres and furniture are included in the ESPR Working Plan for 2025 to 2030, but the precise obligations and application dates will depend on future legal acts.

The work begins before the passport itself becomes mandatory. Manufacturers need to know where the required data comes from, who holds it within the supply chain, how it will be stored and who is responsible for keeping it up to date.

Demand for services related to product data, documentation and compliance processes therefore appears before the formal obligation reaches a particular product category.

What does this mean for European service providers?

The six changes work in different ways, but they lead to a similar business outcome. A growing share of the work involved in Chinese exports requires local European expertise, including knowledge of local rules, registers, procedures, infrastructure and official languages.

Some of this work is required directly by law. Some starts with the European importer and is passed back to the supplier through commercial requirements. Other services become necessary when the most economical way of delivering goods to European customers changes.

This translates into several clear service categories:

  • Law firms and legal advisers: GPSR, representation, documentation, EPR obligations and communication with authorities.
  • Tax and accounting advisers: VAT registrations, OSS, import and sales settlements, and CBAM-related obligations.
  • Logistics, warehousing and fulfilment providers: bulk imports, customs clearance, EU warehousing, last-mile delivery and returns.
  • Compliance and certification specialists: product safety, accessibility, documentation and preparation of data for Digital Product Passports.
  • Payments and settlement providers: financial flows for local sales, marketplace operations and operations across several European markets.

One important caveat

Acting as a responsible economic operator for a product or as a representative under an EPR system can involve direct obligations towards authorities, requirements to retain and provide documentation, and risks linked to the quality of cooperation with the manufacturer.

For law firms, advisers and other service providers, entering these areas therefore requires a clear assessment of responsibility and risk. The existence of demand does not automatically make these services a simple extension of an existing offer.

Why Chinese companies may still struggle to find these services

The capabilities needed to handle these requirements already exist across Europe. From the perspective of a Chinese company, the more difficult question is often which firm has the right expertise and how to find it.

Chinese managers look for partners through Chinese search engines and industry media, WeChat, chambers of commerce, local advisers and recommendations from existing business contacts. Increasingly, they also ask Chinese-language AI models.

A Polish service provider usually describes its expertise in Polish and English, on its own website, Google and LinkedIn. The two sides therefore rely on different information sources and often describe the same business problem in different terms.

This can already be seen at the level of a single search query. A search for 清关 and a search for “customs clearance” lead to different sets of companies. A Chinese-language search for EPR support may not surface a Polish law firm that provides exactly that service if its expertise is absent from Chinese-language information channels.

Expertise alone is therefore not always enough for a firm to appear in front of a Chinese client. The language used to describe the service and the channel in which it can be found also matter.

EnterChina presents European B2B service providers to Chinese companies planning or expanding their operations in Europe. Through the Xijinmenhu (西进门户) platform, their services are available in Chinese, together with a direct channel for initial contact.

This article reflects the legal position as of the publication date and is provided for informational purposes only. It does not constitute legal or tax advice.

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