EU MARKET PLACEMENT CHECKLIST
For Indian Manufacturers Entering the EU Market
Manufacturer: _____________________________________________
Product Name: _____________________________________________
Product Category: _____________________________________________
HS Code (EU CN): _____________________________________________
Target EU Market: _____________________________________________
Sales Channel: [ ] B2B wholesale [ ] EU retailer [ ] Online marketplace [ ] Direct EU consumer
Date: _____________________________________________
This checklist guides an Indian manufacturer through every compliance and placement step required before a product can be legally placed on the EU market. It is organised by product type and sales channel. Items marked (*) are legal prerequisites — the product cannot lawfully enter the EU market without them.
MODULE 1 — PRODUCT CLASSIFICATION AND TARIFF
MODULE 2 — CE MARKING (FOR PRODUCTS WITHIN SCOPE)
Complete if your product is within the scope of one or more EU CE marking Directives or Regulations. Skip to Module 3 if not applicable.
MODULE 3 — GENERAL PRODUCT SAFETY (GPSR)
Complete for all consumer goods not fully covered by specific CE marking legislation.
MODULE 4 — CHEMICALS, REACH AND RoHS
Complete for chemicals, mixtures, articles, and electrical/electronic equipment.
MODULE 5 — FOOD SAFETY (FOR FOOD AND AGRICULTURAL PRODUCTS)
Complete for food, food ingredients, beverages, and agricultural products only.
MODULE 6 — COSMETICS AND AYURVEDIC BEAUTY
Complete for cosmetic products and personal care preparations.
MODULE 7 — TEXTILES, LEATHER, AND FASHION
Complete for textile products, garments, leather goods, and footwear.
MODULE 8 — LABELLING, PACKAGING, AND MARKING (ALL PRODUCTS)
MODULE 9 — ONLINE MARKETPLACE AND E-COMMERCE
Complete if selling directly to EU consumers via Amazon, eBay, Zalando, Cdiscount, or other online platforms.
PLACEMENT READINESS SUMMARY
* Items marked with an asterisk are legal prerequisites. All asterisked items must be Complete before placing product on the EU market.
Doc 83 — Product Compliance and EU Market Placement Checklist — Neutral Template
| Item | Done | Notes |
|---|---|---|
| * 8-digit EU CN code confirmed on EU TARIC — correct classification verified. | [ ] | |
| * MFN import duty rate identified. GSP / FTA preferential rate confirmed (if applicable). | [ ] | |
| Anti-dumping duty status checked — no ADD applies to product from India on this CN code. | [ ] | |
| CBAM applicability confirmed — not applicable (or carbon data collection initiated for covered sectors). | [ ] | |
| Applicable EU non-tariff measures identified on TARIC — import licence, quotas, or SPS requirements noted. | [ ] | |
| EU Access2Markets product requirements report printed and reviewed for target market. | [ ] |
| Item | Done | Notes |
|---|---|---|
| * All applicable EU CE marking Directives / Regulations identified (Machinery, LVD, EMC, RED, PPE, Toys, PED, MDR, etc.). | [ ] | |
| * Applicable harmonised EN standards identified for each Directive — list compiled. | [ ] | |
| * Conformity assessment procedure determined: self-declaration (low risk) or Notified Body required (higher risk). | [ ] | |
| * Product tested against applicable harmonised standards — test reports from accredited laboratory obtained. | [ ] | |
| * Technical File compiled: product description, design drawings/schematics, risk assessment, harmonised standards used, test results, DoC copy. | [ ] | |
| * EU Declaration of Conformity (DoC) drawn up — all required fields completed. Signed by manufacturer or EU Authorised Representative. | [ ] | |
| * CE mark affixed to product or its packaging — minimum 5mm height, legible, indelible, and visible. | [ ] | |
| Notified Body certificate obtained (where NB involvement required) — NB number appears after CE mark. | [ ] | |
| * Technical File retained for 10 years from last manufacture date — storage location designated. | [ ] | |
| * EU Authorised Representative appointed (if manufacturer has no EU establishment) — AR's name and address on product. | [ ] |
| Item | Done | Notes |
|---|---|---|
| * Confirmed product is a consumer good within GPSR scope — Regulation (EU) 2023/988 applies. | [ ] | |
| * EU Responsible Person identified — EU importer, Authorised Representative, or third-party RP service provider. | [ ] | |
| * RP's name and contact address appear on product label, packaging, or accompanying document — in language of destination EU member state. | [ ] | |
| * Manufacturer's name and postal address appear on product or packaging. | [ ] | |
| * Batch / serial / type number on each product unit for traceability. | [ ] | |
| * Product safety technical documentation compiled and stored for 10 years. | [ ] | |
| * Safety assessment completed — product is safe for intended and reasonably foreseeable use. | [ ] | |
| * Instructions for use and safety information prepared in language(s) of destination EU member state(s). | [ ] | |
| Product safety complaints register established — RP briefed on monitoring obligation. | [ ] | |
| Safety Gate Business Gateway account created — serious risk reporting procedure established (3-working-day deadline). | [ ] |
| Item | Done | Notes |
|---|---|---|
| ECHA SVHC Candidate List checked — SVHC presence/absence declaration prepared. | [ ] | |
| * REACH Annex XVII restrictions checked — no restricted substance above permitted limit. | [ ] | |
| REACH Annex XIV — no authorisation-listed substance without authorisation. | [ ] | |
| REACH-compliant SDS prepared (for substances/mixtures) — Regulation (EU) 2020/878 format, in destination member state language. | [ ] | |
| Only Representative (OR) appointed (if substance registration required by EU importer at ≥1 tonne/year). | [ ] | |
| * RoHS (for EEE): All 10 restricted substances confirmed below MCV. RoHS Declaration of Conformity prepared. | [ ] | |
| Nickel release test completed (for jewellery/skin-contact articles) — <0.5 μg/cm²/week confirmed. | [ ] | |
| Chromium VI test (for leather goods) — <3 mg/kg confirmed. | [ ] | |
| Azo dye test (for textiles/leather) — carcinogenic aromatic amines absent above limits. | [ ] | |
| Phthalate testing (for toys, childcare articles, articles in prolonged skin contact) — within REACH limits. | [ ] | |
| Food contact safety testing (for ceramics, plastics, paper) — migration limits for Pb, Cd, and applicable substances confirmed. | [ ] |
| Item | Done | Notes |
|---|---|---|
| * EU MRL compliance: Multi-residue pesticide screening by NABL/ISO 17025 lab — all residues below EU limits. | [ ] | |
| * Aflatoxin testing (for groundnuts, spices, cereals, dried fruits) — below EU limits. | [ ] | |
| * EU food labelling compliance (Reg. 1169/2011): All 14 allergens declared in bold; net quantity; best before; storage; EU FBO details; nutrition declaration. Label in language of destination member state. | [ ] | |
| FSSAI licence current — Central FSSAI licence for manufacturer. | [ ] | |
| HACCP system implemented and certified (BRC/FSSC 22000 preferred by EU retail buyers). | [ ] | |
| Organic certification from EU-recognised Indian certifying body (if marketing as organic). | [ ] | |
| GI certificate from issuing body (if GI-protected product — Tea Board, Spices Board, GI Registry). | [ ] | |
| Enhanced border check status (EU 2019/1793) checked — if applicable, TRACES NT pre-notification process established. | [ ] | |
| EU Novel Food status checked — confirm product is not a novel food requiring EU authorisation. | [ ] | |
| Health claims: If any health or nutrition claim is made — confirmed it is listed on EU authorised health claims register (Reg. 1924/2006). | [ ] |
| Item | Done | Notes |
|---|---|---|
| * Product Safety Assessment (PSA) completed by qualified cosmetic safety assessor. | [ ] | |
| * Product Information File (PIF) compiled — retained by EU Responsible Person. | [ ] | |
| * CPNP notification filed for each product on EU Cosmetic Products Notification Portal before placing on market. | [ ] | |
| * EU Responsible Person appointed — details on product and PIF. | [ ] | |
| * Prohibited and restricted substances check: All ingredients verified against EU Cosmetics Regulation Annexes II (prohibited) and III (restricted). Traditional Ayurvedic ingredients (heavy metals, certain herbs) verified as permissible. | [ ] | |
| * Product label compliance: INCI names for all ingredients; net quantity; best before / period after opening (PAO); warnings; EU RP details; country of origin. In destination language. | [ ] | |
| Claim substantiation: All marketing claims (e.g. "natural," "organic," "anti-ageing") substantiated. | [ ] | |
| Nanomaterial notification filed (if product contains nanomaterials) — at least 6 months before market placement. | [ ] |
| Item | Done | Notes |
|---|---|---|
| * Textile fibre composition label prepared — all fibres declared by EU standardised name in destination language. Pashmina labelled as "cashmere." | [ ] | |
| * Azo dye compliance: No carcinogenic aromatic amines released above limits (EN ISO 14362 test). | [ ] | |
| Nonylphenol ethoxylate (NPE) surfactant check: No NPE above limit in treated textiles. | [ ] | |
| * Leather — Chromium VI: <3 mg/kg (EN ISO 17075 test). | [ ] | |
| Leather — DMF (dimethyl fumarate): Absent — no anti-mould sachets containing DMF. | [ ] | |
| * REACH SVHC in articles: Any SVHC above 0.1% w/w declared. | [ ] | |
| REACH Annex XVII phthalates: For products with plastic components — phthalate content within limits. | [ ] | |
| Care instructions: International care symbols (ISO 3758) or written instructions in destination language. | [ ] | |
| Size labelling: EU size convention used where applicable (clothing and footwear). | [ ] | |
| Footwear — composition labelling (Directive 94/11/EC): Materials used for upper, lining/sock, and outer sole declared using standard pictograms. | [ ] |
| Item | Done | Notes |
|---|---|---|
| * Country of origin marking: "Made in India" (or equivalent in destination language) on product and outer packaging. | [ ] | |
| * Language: All mandatory product information in the official language(s) of the target EU member state(s). | [ ] | |
| * Metric units: Net quantity in metric units (kg, g, ml, l). | [ ] | |
| * EU food business operator / EU Responsible Person / EU Authorised Representative: Contact details on product. | [ ] | |
| Barcode / EAN: Correct format applied and scannable. | [ ] | |
| * WEEE symbol (crossed-out wheelie bin): On EEE — indicates separate collection requirement. | [ ] | |
| * Battery symbol: On products containing batteries — chemical content and crossed-out bin symbol. | [ ] | |
| * Energy label: For products covered by EU Energy Labelling Regulation — correct label in place. | [ ] | |
| ErP (Ecodesign): For products in scope — minimum energy efficiency requirements met. | [ ] | |
| Packaging: Recyclability and recycled content requirements under EU Packaging Regulation assessed. Excessive packaging avoided. | [ ] | |
| Digital labelling: If using QR code for any mandatory information — physical fallback available. | [ ] |
| Item | Done | Notes |
|---|---|---|
| * EU Responsible Person details on product listing — marketplace platform requirement from December 2024. | [ ] | |
| * Manufacturer's name, address, and contact details on product listing. | [ ] | |
| * Batch / model / type reference on listing for traceability. | [ ] | |
| Safety Gate Business Gateway account active — marketplace listings monitored for Safety Gate alerts. | [ ] | |
| Consumer rights compliance: EU distance selling rules (Directive 2011/83/EU) — 14-day right of withdrawal applies. Return policy and withdrawal form available. | [ ] | |
| VAT registration in each EU member state of sale — or EU One Stop Shop (OSS) VAT registration used. | [ ] | |
| GPSR: Marketplace platform briefed on RP details and product safety documentation — platform compliance obligations under GPSR noted. | [ ] | |
| Platform terms compliance: Each marketplace's product listing requirements and prohibited items policy reviewed. | [ ] |
| Module | Status | Actions Outstanding |
|---|---|---|
| 1 — Tariff / Classification | Complete / Partial / N/A | |
| 2 — CE Marking (if applicable) | Complete / Partial / N/A | |
| 3 — GPSR | Complete / Partial / N/A | |
| 4 — REACH / RoHS / Chemicals | Complete / Partial / N/A | |
| 5 — Food Safety (if applicable) | Complete / Partial / N/A | |
| 6 — Cosmetics (if applicable) | Complete / Partial / N/A | |
| 7 — Textiles / Leather (if applicable) | Complete / Partial / N/A | |
| 8 — Labelling / Packaging | Complete / Partial / N/A | |
| 9 — Online / E-Commerce (if applicable) | Complete / Partial / N/A |