Byblos HorizonE-Commerce Growth and Operations
Dropshipping Into the EU Needs a Name and Address You Probably Do Not Have
Mohamad Haidar
Founder of Byblos Horizon
Published October 22, 2026 · 10 min read
Most arguments about dropshipping are about whether it is a good business. This is not that argument. This is about one specific legal requirement that applies to any product offered to a consumer in the European Union, and that the standard dropshipping setup structurally cannot satisfy.
It is not obscure, it is not pending, and it is not a proposal. It has applied since 13 December 2024.
What the Regulation says
The EU General Product Safety Regulation, Regulation (EU) 2023/988, has two provisions that matter here. We are quoting them rather than summarising because the wording is the whole point.
Article 16 creates the obligation. It states that a product covered by the Regulation shall not be placed on the market unless there is an economic operator established in the Union who is responsible for the tasks set out in Article 4(3) of Regulation (EU) 2019/1020 in respect of that product. In plain terms, every product needs a real party inside the EU who answers for it.
Article 19 puts it in your listing. Where economic operators make products available online or through other means of distance sales, the offer must clearly and visibly indicate at least four things:
- The name, registered trade name or registered trade mark of the manufacturer, together with the postal and electronic address at which they can be contacted.
- Where the manufacturer is not established in the Union, the name and the postal and electronic address of the responsible person.
- Information allowing identification of the product, including a picture of it, its type and any other product identifier.
- Any warning or safety information required to be affixed to the product, its packaging or an accompanying document.
Note what the second item does. It is written specifically for the case where the manufacturer is outside the EU, which is the case for most dropshipped goods, and it does not offer an exemption. It requires a different name instead.
Why the usual setup cannot satisfy it
Walk through a typical arrangement. The product is manufactured in China. The supplier is in China. The store owner is in Beirut, Dubai or London. The customer is in Germany. Now find the economic operator established in the Union who is responsible for that product.
There usually is not one. And nothing in the tooling creates one. A supplier app connects a catalogue to a storefront. It does not establish an EU entity, it does not assume product liability, and it does not give you a name and an address to publish. The gap is not an oversight in your setup, it is a feature of the model.
The listing requirement is what makes this concrete. Other compliance obligations are invisible until something goes wrong. This one is visible on the product page, to anyone, including a competitor, a marketplace, a consumer protection authority or a customer who has decided to be difficult. There is no version of a compliant EU-facing listing that does not name somebody, which means the question cannot be deferred.
What this does not mean
It does not mean dropshipping is illegal, and we are not going to pretend it does. There are three real answers to this requirement.
Appoint or become the responsible person. This is the honest route if the EU is a serious market for you. It means a real EU-established economic operator, with the obligations that come attached, and there are service providers whose entire business is acting in this role. It is a cost, not a formality.
Source from suppliers who already have one. Brands and distributors that already sell into the EU have solved this, and their products arrive with a responsible person you can name. This usually means paying more per unit than the cheapest catalogue listing, which is the trade you are actually making.
Do not advertise into the EU. Entirely legitimate, and frequently the right commercial answer for a store whose real market is the Gulf or Lebanon. The mistake is running broad advertising that reaches EU consumers without having decided to serve them.
The wider point about what the courses leave out
Product compliance is a cost of selling physical goods across a border. So is who is liable when a product injures somebody, so is who the importer of record is, so is what happens when a customer demands a refund for a product you have never physically touched. None of those are in the pitch, because the pitch is built around the one genuinely low number in the model, which is upfront inventory.
That is the same pattern we keep running into across this whole subject. The US company route is sold on the easy part and silent on the annual filing with a $25,000 penalty. The banking advice is sold on which app to download and silent on residence restrictions. The problem is not that any of these strategies are frauds. It is that they are presented without their obligations, and the obligations arrive anyway.
If you are choosing between models for a market in this region, our real cost of running e-commerce in Lebanon piece is the companion to this one, built on the same principle of counting what is actually there.
Questions people are asking
What does the EU General Product Safety Regulation require in a product listing?
Article 19 of Regulation (EU) 2023/988 requires that an online or distance sales offer clearly and visibly indicate at least four things: the manufacturer's name, registered trade name or trade mark with a postal and electronic address; where the manufacturer is not established in the Union, the name and postal and electronic address of the responsible person; information identifying the product including a picture, its type and any other identifier; and any applicable warning or safety information.
What is a responsible person under GPSR?
Article 16 states that a product covered by the Regulation shall not be placed on the market unless there is an economic operator established in the Union who is responsible for the tasks set out in Article 4(3) of Regulation (EU) 2019/1020. In practice it is a named party inside the EU who can be contacted about the product's safety and compliance. It has to be a real economic operator, not a forwarding address.
Why is this a particular problem for dropshipping?
Because the typical dropshipping arrangement has nobody in that role. The manufacturer is outside the Union, the supplier is outside the Union, and the store owner is frequently outside the Union too. Nothing in a supplier app creates an EU-established economic operator, so there is often no name to put in the listing, which is exactly what the Regulation asks for.
Since when has this applied?
The Regulation states that it applies from 13 December 2024. It is a regulation rather than a directive, which means it applies directly in every member state without needing national implementing legislation.
Does this mean dropshipping into the EU is illegal?
No, and nobody should read it that way. It means a compliant EU-facing offer has requirements that the common version of the model does not meet. Businesses solve this by becoming or appointing an EU responsible person, by sourcing from suppliers who already have one, or by not selling into the EU. What does not work is ignoring it and hoping the listing is not looked at.
What about selling to the Gulf or Lebanon instead?
Different markets, different rules, and no assumption carries across. The point of this article is not that the EU is uniquely strict, it is that product compliance is a real cost of selling physical goods across a border and it is almost never in a dropshipping course. Check the requirements of each market you actually advertise into.
Sources
- Regulation (EU) 2023/988 on general product safety, EUR-Lex. Article 16, Responsible person for products placed on the Union market, for the requirement of an economic operator established in the Union. Article 19, Obligations of economic operators in the case of distance sales, for the four items an online offer must clearly and visibly indicate. Article 52 for the application date of 13 December 2024.
- Regulation (EU) 2019/1020 on market surveillance and compliance of products, for the Article 4(3) tasks that the responsible person is responsible for, which Article 16 of the GPSR refers to rather than restates.
Quotations above are from the consolidated English text on EUR-Lex, read in October 2026. This is a summary of two provisions and not a complete account of the Regulation or of EU product law. We are a marketing and e-commerce studio, not lawyers, and nothing here is legal advice. Anyone selling physical products to EU consumers should take this to a qualified lawyer in the relevant jurisdiction.