E-commerce and Import: Why Online Channels Are Scrutinised
Online selling has changed how products reach the EU market — often straight from a foreign seller to the consumer. That convenience, however, creates enforcement gaps, which is why online channels face special scrutiny. The Digital Product Passport (DPP) covers them just as it covers traditional sales.
Why online draws more attention
In a classic supply chain, a product passes through an importer and a distributor, who act as compliance filters. In direct online sales, that chain is often shorter, and the product reaches the customer bypassing traditional control points.
The result is a risk that goods without the required passport reach the market. The regulator is aware of this and therefore treats digital channels with the same attention as shop shelves. The sheer scale of online trade makes it an area too large to overlook.
Online platforms have obligations too
Responsibility for the DPP does not end with the manufacturer and importer. The ESPR (Regulation (EU) 2024/1781) also covers online platforms that intermediate sales.
In practice this means online marketplaces cannot treat compliance as purely someone else's problem. Offering an in-scope product without a valid passport can create consequences on their side too. We discuss the division of roles further in Supply-chain responsibility for the DPP.
Import through e-commerce
A particular area of risk is import carried out through digital channels — including dropshipping models and order fulfilment from warehouses outside the EU. Here a non-EU product often reaches the consumer with minimal involvement from intermediaries.
Whoever places such a product on the EU market takes on the passport obligations. They cannot be shifted onto a distant non-EU manufacturer that is not directly subject to EU surveillance. This matters because in online models the line of responsibility is often blurred.
What enforcement looks like online
Controlling online channels combines market surveillance with border control. Authorities can analyse online offers, while import shipments are subject to risk-based customs mechanisms.
The passport makes these checks easier because it provides structured, verifiable data. A product without a working carrier and record is easier to catch both in an online listing and at the border. We cover this in The DPP and EU customs.
What online sellers should do
If you sell online into the EU, it is worth treating the DPP as part of the listing, not an add-on:
- make sure every in-scope product has a passport before it appears in an offer,
- in an import model, clearly establish who acts as the party placing it on the market,
- ensure the data carrier is available and correct in mail-order sales too.
This approach protects against goods being detained at the border and against an offer being challenged by surveillance authorities.
The marketplace as a participant in trade
An online platform is not just a passive intermediary between seller and customer. When it hosts offers and enables transactions, it becomes part of the system of responsibility for the products that reach the market through it. That is why it is expected to cooperate in ensuring compliance.
In practice this can mean requiring sellers to provide passport information, responding to signals about non-compliant products and working with surveillance authorities. The online channel stops being a grey zone and becomes a place where DPP rules also apply.
Dropshipping and fulfilment from outside the EU
Models in which goods are shipped directly from a warehouse outside the Union call for particular attention. The key question is: who in this chain is the party placing the product on the EU market and therefore responsible for the passport.
The answer is not always obvious, so it is worth settling in advance rather than only in reaction to an inspection. Clearly assigning this role avoids the situation where, formally, no one feels responsible for the compliance of imported goods.
How not to be caught out by an online check
Online selling is visible and easy for authorities to browse as well. An offer without information about the required passport can draw attention just as easily as a product detained at the border. That is why compliance is best treated as part of preparing the listing, not a problem to solve after the fact.
In practice this means a simple discipline: no in-scope product goes on sale before its passport is ready, complete and linked to a working carrier. This rule protects both the seller and the platform.
Key takeaways
- Online channels face special scrutiny because they bypass traditional control points.
- Online platforms that intermediate sales also have DPP-related obligations.
- Import through e-commerce shifts passport obligations onto the party placing goods on the EU market.
- Enforcement combines market surveillance with risk-based customs control.
- Treat the passport as part of the listing, not a later add-on.
See how CyfroPass helps online sellers have passports ready for every product. Visit cyfropass.pl and start with your first product.