Product safety and market access compared: EU and China
What product safety and market access rules apply in the EU and China?
The EU sets one general safety duty with named economic operators and a liability regime behind it. China works through compulsory certification and origin rules at the border.
Rows read against the registers 2026-08-26.
European Union
- General Product Safety Regulation — Regulation (EU) 2023/988, 32023R0988: General safety requirement, a responsible person in the Union and duties per economic operator.
- Product Liability Directive — Directive (EU) 2024/2853, 32024L2853: Liability for defective products, extended to software and to digital components.
- Market Surveillance Regulation — Regulation (EU) 2019/1020, 32019R1020: Market surveillance powers and the requirement that a person in the Union is reachable for compliance.
Open the European Union register
United States
No US row in our register for this topic. That is a gap in the register, not a statement that no rule exists.
Open the United States register
China
- Regulations on Compulsory Product Certification (CCC), Compulsory product certification, CCC mark: Named product categories require certification before they may be sold on the Chinese market.
- Regulations on the Origin of Import and Export Goods, State Council Order No. 416: Determines the origin of goods, which decides duty treatment and labelling at import.
What they ask for in common
- Both sides require a named party that authorities can reach about the product.
- Both sides tie market access to documentation that exists before the first sale.
Where they differ
- The EU duty is a general safety requirement. China works from a list of certified categories.
- EU liability now reaches software. The Chinese route in our register is certification and origin, not liability.
- Our register holds no US row for this topic, so the page shows the gap rather than guessing.
What companies usually do first
- Name the responsible person in the Union before the first shipment, not after a complaint.
- Check whether the product category sits on the Chinese certification list.
- Keep the technical file and the origin documents in the same place.
This page describes what the registers say and what is common practice. It is a reading of published sources, not legal advice, and it is not a compliance verdict.
Does this apply to us
- Do product safety rules apply to an online marketplace?
- Do product safety rules apply to an online seller?
- Do product safety rules apply to a manufacturer?
- Do product safety rules apply to an importer?
- Do product safety rules apply to a cloud provider?
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