EU GPSR: Exxos, do you have an EU point of contact?

[exxos]

Bloody hell! Then this truly is madness.

Yes exactly...

This is why the eBay sellers etc are are up in arms because it is basically ruining them all. There are plenty of videos of eBay sellers trying to navigate through the eBay boxes and the information they want is just complete madness and basically impossible.

Like I keep saying, the EU with this law have basically written off all small sellers and businesses. A lot of them are not even aware of this law and could potentially get sued and risk imprisonment... Now imagine if the EU did that for every single business which is still operating (soon to be) illegally... Now imagine the ramifications to the UK or the world as a whole... The more you look into it more totally insane the whole thing is!

While you can represent yourself within the EU, they are still bound by the same laws and still face the same problems. If I actually lived in the EU and had to adhere to these new laws then I would literally be forced to close my shop because there is no way I could operate under those conditions. The only saving grace is that we are in the UK and do not have adhere (at least currently) with that new EU law .

[stephen_usher]

The only saving grace is that we are in the UK and do not have adhere (at least currently) with that new EU law .

Unless you are in Northern Ireland or sell to someone within Northern Ireland.

[exxos]

The only saving grace is that we are in the UK and do not have adhere (at least currently) with that new EU law .

Unless you are in Northern Ireland or sell to someone within Northern Ireland.

Indeed NI is problematic as well as Europe. Though I don't think I have any customers in Ireland or at least only ever shipped once or twice since my store went live. I do need to remove Ireland from the store as well though, as there is nothing to differentiate between Ireland and Northern Ireland.

[exxos]

So battling this out with GPT4....

I remember dealing with the LVD in my old job. A lot of the multiplexed lamp matrix used 50VDC at the time. Later PSUs had lower voltages and had a green LVD sticker on them.

Parts seem to be excempt from CE approval even though the CE regulations state all devices.. but that isn't true on subsections . So GPT4 thinks selling direct to the customer is fine and don't need a EU representative. In effect the buyer or importer is responsible for himself...

I need to figure out why GPT4 thinks these things next...

Your understanding is correct. If you’re selling parts for old computers, the Low Voltage Directive (LVD) and other CE marking requirements may not apply to your products, provided they meet certain criteria. Here's why:


1. Parts vs. Standalone Products

• Standalone Products: CE marking is required for standalone products that have their own function (e.g., complete devices, appliances).
• Parts or Components: If the items you sell are not standalone products and are instead intended to be integrated into or used as parts of existing systems (e.g., upgrades for old computers), they typically do not require CE marking.
  • Example: A replacement chip or an upgrade board for an Atari ST computer would likely fall under "components" rather than standalone products.

2. Low Voltage Directive (LVD) Applicability

• The LVD applies to electrical equipment designed for direct use within a specified voltage range (50V to 1,000V AC or 75V to 1,500V DC).
• If your parts operate below these voltage ranges (e.g., 5V or 12V typical for computer components), the LVD does not apply.

3. General Product Safety Regulation (GPSR)

• Your products must comply with the GPSR, which ensures that goods placed on the EU market are safe for their intended use.
• Unlike CE marking, GPSR compliance does not require you to affix a CE mark or appoint a Responsible Person (RP). Instead, you are expected to:
  • Ensure the product is safe.
  • Provide appropriate instructions or warnings to avoid misuse.

4. Selling to End Users

• Because you sell directly to end users for personal use, and your parts are not marketed as standalone devices, your products may fall outside the scope of CE marking entirely.
• End users are not classified as importers or distributors, so there is no expectation for them to ensure compliance beyond basic safety.

5. Key Considerations for Compliance

• Even if CE marking isn't required, you should:
  • Clearly label your products as "spare parts" or "components for integration" to clarify their intended use.
  • Include any necessary safety instructions or disclaimers (e.g., "Not for standalone use" or "Intended for use in Atari ST systems").
  • Ensure the products do not present safety hazards (e.g., overheating, electrical faults) when used as intended.

6. When a Responsible Person (RP) Is Not Needed

• If your products do not require CE marking (because they are parts, not standalone devices), you do not need to appoint an EU Responsible Person.
• The absence of CE marking means your products are not subject to customs checks for CE compliance when entering the EU.

Recommendation
To minimize any potential issues when selling to EU customers:

1. Label Clearly: Ensure your products are labeled as parts for specific systems, not standalone devices.
2. Provide Safety Information: Include basic safety guidance to comply with GPSR.
3. Communicate with Customers: Make it clear to EU customers that the products are intended as parts or upgrades and do not fall under CE marking requirements.

By following these steps, you can confidently sell your parts without needing CE marking or an EU Responsible Person.
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Almost made myself chuckle, what if I put a warning label on everything and say that this product should not be used under any circumstances and should be immediately returned to the manufacturer for safe disposal.... Surely that would cover every eventuality of use and misuse ??

[Steve]

Sounds like a win to me

[exxos]

Sounds like a win to me

I have to prove it yet... I don't know where GPT4 got this information from...

It is also still confusing because why are things my girlfriend getting from Temu having the representative stickers on stuff... They don't need CE approval...

Edit:

The information about not requiring an EU Responsible Person (RP) for items that do not require CE marking comes directly from EU product compliance laws and guidelines,

It might explain why one eBay seller said the EU rep box was optional...

But doesn't really explain why eBay and other online platforms are forcing information when it doesn't seem to be needed... So a lot of stuff still doesn't add up...

And there's no apparent escape from the EU packaging laws either...

[exxos]

I've been looking into all that EU packaging crap. Ive found a company which is a "one stop shop" so contacted them. But looks like the cost per year will be about £400 That's a LOT of goods to sell to recover that amount of profit.

More annoying is it seems I would have to stick recycling labels on the boxes... Which are all different across EU states Isn't it ironic that we have recycling schemes and then we generate even more huge waste with additional labeling

This basically results in a lot more work and expense to deal with EU orders. it would likely add about £2 extra per EU order minimum.

I also find the whole thing perplexing. I mean, EU customers would be paying me recycling costs for their rubbish. This would be like me paying France money to take away my rubbish.. I mean WTF ?? We have to pay for our own rubbish to be taken away in the UK.. and now I would be paying for other people's rubbish to be taken away ?! It doesn't really make much sense to me. In my view, the customer purchased the complete package , they should deal with the rubbish as they paid for it. But I know nothing.... The whole thing just seems backwards to me. It's not like I'm dumping 100s of tonnes of rubbish into the country each year but I get treated the same as big business anyway in some states

The issue really becomes if I even make £400 profit to break even on EU orders. Likely not. Again the only solution is to unfortunately add a EU tariff to pay for it all. Even so, I would need 200 EU orders to break even with the extra costs.. again this is unlikely..so it could add up to £5 per EU order. The whole situation is unavoidable if I am to try selling to EU customers. This new cost may further limit orders... It's a bit of a no-win situation. In particular low value goods.

Some EU states do not have this package "tax". But these are generally very low volume states anyway.

This almost certainly will have added charges..

Austria, Bulgaria, Croatia, Cyprus, Denmark, Finland, France, Germany, Greece, Hungary, Luxembourg, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden.

It may be similar simply not to ship to those destinations but some like Germany, France etc are likely the best customers.

Always seems, damned if do and damned if don't all the time

[exxos]

Sidestep to this vat thread viewtopic.php?p=122564#p122564

That's another problem. EU people will also be hit with import VAT (assuming they don't already) plus the "package fees" it will double the cost of them buying small items. People will moan no doubt but likely not buy again. So it's back to losing sales again. Plus if people don't pay the tax, packages will bounce back and I'll have to deal with the fallout of all that .

I could do with knowing if people have been hit with import costs already or not... But I really don't trust people to pay the fee and ignore it. Then blame me when their package doesn't arrive.

However I look at all this, it just seems a no win situation. I mean it seems hopeful I could reopen EU sales.. but I fear it's going to end up short lived in multiple ways . It's going to result in more work and costs for myself and EU buyers... What a total mess all this is!

So if someone in EU buys a £10 item. It's about £15 postage. Plus the packing fee of say £5. Plus VAT which would I assume be £10+£15 + 20% = £5 tax + £5 packing fee.+ £15 postage. basically means a £10 item will cost £25 in "postage" .

[HomeLate]

We always pay VAT if a shop isn't IOSS registered. On top of that, we pay a customs and handling fee, depending on the value of the item. VAT in my case is 21%, calculated on the total amount: value of the item and shipping costs.

It also depends on who is the shipper. If the item is send by Royal Mail and bPost and handled by our local post operator, it's a hit or miss. Meaning, we don't always pay taxes/vat or whatever. It depends on what's in the package and how big it is.
It also can take a long time before an item passes customs. Right now I'm waiting on a Dragon64 which is at customs for over a month.

If shipped by UPS/Fedex/..., they handle everything and charge you before they want to deliver the package. The main difference: it's going a lot faster than the Royal Mail/bPost. But we have to pay more for shipping of course (which in my case, I'm happy to pay).

Sidestep to this vat thread viewtopic.php?p=122564#p122564

That's another problem. EU people will also be hit with import VAT (assuming they don't already) plus the "package fees" it will double the cost of them buying small items. People will moan no doubt but likely not buy again. So it's back to losing sales again. Plus if people don't pay the tax, packages will bounce back and I'll have to deal with the fallout of all that .

I could do with knowing if people have been hit with import costs already or not... But I really don't trust people to pay the fee and ignore it. Then blame me when their package doesn't arrive.

However I look at all this, it just seems a no win situation. I mean it seems hopeful I could reopen EU sales.. but I fear it's going to end up short lived in multiple ways . It's going to result in more work and costs for myself and EU buyers... What a total mess all this is!

So if someone in EU buys a £10 item. It's about £15 postage. Plus the packing fee of say £5. Plus VAT which would I assume be £10+£15 + 20% = £5 tax + £5 packing fee.+ £15 postage. basically means a £10 item will cost £25 in "postage" .

[Darklord]

Something odd I've noticed lately. At least I don't remember it being this way before...

Okay, everyone knows that I run an irregular "prize giveaway" at DarkForce!, my BBS.

For the last few months (6-8?), whenever I send something to Europe, the Postal clerk
on my end (this is USPS), shows me a pop-up window proclaiming that even though I've paid
the shipping charges, the recipient will probably have to pay an additional fee on their
end before they can take possession of the package I'm sending.

Have you all seen that before or know why that is? It's fairly new. Thanks.

PS Oh, and it won't let me pay that charge on my end.