Amazon & marketplaces

Temu GPSR Requirements: Fully Managed vs Semi-Managed, Who Is Responsible and What Sellers Must Provide

Last checked against the official texts: 8 November 2026 · Based on Regulation (EU) 2023/988

Short answer

The GPSR knows nothing of Temu's fully managed or semi-managed models; it assigns duties by role: who markets the product under its name (manufacturer), who places it on the EU market from an EU base (importer), and who stores and ships it inside the EU (fulfilment service provider). In every model, each product offered to EU consumers needs a responsible person established in the EU, and the listing must show manufacturer, responsible person, product identification and warnings in the local language (Articles 16 and 19). Temu's public EU terms say the sales contract is between the consumer and the seller named on the product page; we found no public statement that Temu acts as importer or responsible person for fully managed sellers, so a written mandate with an EU authorised representative is the safe route.

Key points

Duties follow legal roles, not Temu's business models; who is who depends on the contract and on the seller named on the product page.
Temu's EU terms state that the contract is between the consumer and the listed seller, which may be a third-party merchant or Temu and its affiliates.
For parcels shipped from China, the consumer may be the customs importer; that does not make anyone a GPSR importer, so an authorised representative is usually the only option.
Article 19 listing data is the seller's own duty; Article 22 makes Temu provide the input fields, collect self-certifications and act on authority orders within two working days.
The Commission's €200 million DSA fine on Temu (May 2026) concerns Temu's own risk assessment, not sellers' GPSR obligations.

The short answer: the law looks at roles, not at Temu's models

Two myths circulate among Temu sellers: that in the fully managed model compliance is Temu's job, and that only semi-managed sellers need an EU representative. Neither has a basis in the law. The GPSR (Regulation (EU) 2023/988) assigns duties to economic operators: manufacturer, authorised representative, importer, distributor and fulfilment service provider (Article 3(8)–(13)). Providers of online marketplaces have their own, separate duties (Article 22).

Three questions settle your role on Temu:

Under whose name or trade mark is the product sold? If it is your brand, you are the manufacturer (Article 3(8), Article 13(1)), even if a factory makes it for you.
Who places the product on the EU market from inside the EU? Only a person established in the Union who places a third-country product on the Union market is an importer (Article 3(10)).
Who stores, packs or ships it inside the EU? Someone offering at least two of those services without owning the goods may be a fulfilment service provider (Article 3(12)); postal, parcel delivery and freight services are excluded.

The fully and semi-managed models only change the answers to questions 2 and 3. Whether a product may be sold to EU consumers at all depends on Article 16(1): there must be an economic operator established in the Union responsible for the tasks in Article 4(3) of Regulation (EU) 2019/1020. For CE-marked products such as toys and electrical goods, the basis is Article 4 of Regulation 2019/1020 directly, because Article 2(1)(b) GPSR disapplies Articles 9–18 for them; the Article 19 listing rules still apply.

What Temu states publicly (kept apart from the law)

The table lists only what Temu says on its own public pages. GPSR instructions inside the Seller Center require a login, and we found no publicly accessible official Temu GPSR help page, so this guide does not repeat menu paths; third-party descriptions of the back end may also be out of date. Always follow the latest Seller Center notices.

Temu public page	What it says	What it means for sellers
EU Terms of Use, section 1.2	The terms are with Whaleco Technology Limited, an Irish company; 'Sellers' are those indicated on the product listing page, including third-party merchandise partners and Temu and/or its affiliates	Who sells a product is shown per listing; 'fully managed means Temu sells' is not a safe assumption
Section 13.1	All sellers entitled to sell on Temu are professional traders; their name and contact details appear on the listing page	As a seller you are a trader and the GPSR applies to you
Section 13.2	The purchase contract is concluded solely between the consumer and the seller on the listing page; where applicable, the consumer may act as importer and authorises Temu to appoint a freight forwarder as direct representative for customs	The customs importer may be the consumer, which is not the same as a GPSR importer
Section 13.3	The respective seller is responsible for the accuracy of product information	Wrong manufacturer, responsible person or warning data is first of all the seller's problem
Product Safety Alerts and Recalls page	When notified of a recall, Temu says it will stop the trader selling the item as quickly as possible, notify customers who bought it and publish the information	Matches Article 22(12); recall notices reach your buyers through the platform

These are contract terms and platform practice, not law. A platform may ask for more than the law (label photos, for example), but it cannot release you from your legal duties.

Fully managed vs semi-managed: who is manufacturer, importer and responsible person

The table applies the legal definitions, assuming a brand owner in China with no EU subsidiary. For any specific product, who is the seller and who carries sales responsibility depends on your agreement with Temu and on the seller named on the listing page; have a lawyer review the contract if in doubt.

Situation	Manufacturer	GPSR importer	Fulfilment service provider	Safest responsible person
Fully managed: stock delivered to a platform-designated warehouse in China, cross-border delivery to EU consumers	You, if sold under your brand; otherwise the factory whose brand it carries	Usually none: under Temu's terms the consumer may be the customs importer, and a consumer is not an economic operator	Usually none: the warehouse is outside the EU; couriers and postal services are excluded	Written mandate with an EU authorised representative (Art. 4(2)(c) Reg. 2019/1020)
Semi-managed: shipped from your own or a third-party EU warehouse	As above	Only if your EU company or an EU wholesaler imports in its own name	A third-party EU warehouse offering two or more services may qualify, but only as a fallback (Art. 4(2)(d))	Authorised representative, or the importer where one exists
Semi-managed: shipped directly from China	As above	None	None	Authorised representative only
Listing names Temu or an affiliate as seller	Still decided by name or trade mark; your brand makes you manufacturer	Depends on how Temu's side imports; the contract should say	Depends on the arrangement	Do not assume the platform takes the role; get it in writing

Two further points. The Commission's GPSR guidelines (C/2025/6233, an interpretation, not law) note that one marketplace can be a mere online marketplace for some products, a fulfilment service provider for others and a manufacturer for its own-brand products, so the platform's role must be assessed product by product. And if you only resell another brand, you are a distributor (Article 3(11)) and must check before listing that the manufacturer and importer information is present (Article 12(1)); the responsible person is normally arranged by the brand owner.

For the responsible person's qualifications and tasks, see the EU Responsible Person guide; for the same analysis applied to Amazon, see FBA vs FBM under GPSR.

What the law requires on every EU-facing Temu listing

Article 19 requires every online offer to show at least four items clearly and visibly. This is the seller's own legal duty, whatever fields the back end offers:

Article 19	Content	Tip for Temu sellers
(a)	Manufacturer's name, registered trade name or trade mark, postal and electronic address	Use the company name on the business licence or the registered mark; the electronic address can be an email or a web contact section
(b)	If the manufacturer is outside the EU: name, postal and electronic address of the responsible person	Must match the responsible person on the physical label
(c)	Product identification, including a picture, type and other identifiers	Model and batch numbers must match the product (Article 9(5))
(d)	Warnings and safety information required on the product, in a language set by the Member State of sale	Temu sells into many Member States, so cover each sales language

On the product itself, the manufacturer must mark a type or batch number and its own name and address (Article 9(5)–(6)); the responsible person's name and contact details go on the product, packaging, parcel or an accompanying document (Article 16(3)); instructions and safety information must be in the local language (Article 9(7)). Fully managed stock must be labelled before it enters the warehouse in China; there is no later chance to fix it. See GPSR label requirements.

Separately, Article 30 of the Digital Services Act (DSA) makes the platform collect your own trader details: name, address, telephone number, email, an identification document, payment account details, trade register details and a self-certification that you only offer products complying with EU law. That verifies who you are; Article 19 data describes the product. Both must be true and consistent.

Article 22: what Temu must do as a marketplace, and how it affects you

For third-party offers, Temu is a provider of an online marketplace under Article 22. The parts that matter most to sellers:

Input fields (Art. 22(9)): the interface must let traders provide the Article 19 information and display it or make it easily accessible on the listing. Missing or wrong data can block or restrict an offer.
Self-certification (Art. 22(10)): internal processes must let traders submit responsible person data and a commitment to offer only compliant products. Ticking that box is a written commitment; make it truthfully.
Authority orders (Art. 22(4)–(5)): orders about dangerous products must be acted on within two working days, possibly for all identical content.
Safety notices (Art. 22(8)): processed within three working days.
Safety Gate (Art. 22(6)): offers matching Safety Gate alerts may be removed proactively.
Repeat offenders (Art. 22(11)): after a warning, traders that frequently offer non-compliant products are suspended for a reasonable period.
Recalls (Art. 22(12)): buyers are notified directly; the economic operator is told when an offer is removed.

None of these duties moves to the seller, and the platform meeting them does not release you from yours. For a cross-platform comparison, see GPSR information required for online selling.

The Commission's DSA enforcement against Temu: facts and relevance

Temu is designated a very large online platform under the DSA. According to the Commission's own press releases:

28 July 2025: the Commission preliminarily found Temu in breach of the DSA for failing to properly assess the risks of illegal products being sold on its marketplace.
28 May 2026: the Commission adopted a non-compliance decision and fined Temu €200 million for failing to diligently identify, analyse and assess the systemic risks of illegal products on its platform. A mystery shopping exercise in the investigation found that a very high share of selected chargers failed basic safety tests and a high share of tested baby toys posed medium to high risks (chemicals above legal limits, or detachable parts creating suffocation hazards). Temu said it disagreed with the decision.
26 October 2026: the Commission accepted Temu's action plan to remedy the breach, centred on its risk assessment.

These decisions rest on the DSA and concern Temu's own obligations as a platform; they are not GPSR penalties on sellers. Two lessons for sellers: authorities buy and test products themselves, with chargers and baby toys in focus, and platform risk controls are tied directly to seller compliance. Have test reports, technical documentation and labels ready before the platform asks; see GPSR technical documentation.

Temu seller GPSR self-check

Confirm for each product who the manufacturer is (whose name or trade mark it carries)
Check which seller the listing page names and confirm roles against your Temu agreement
Sign a written mandate with an EU authorised representative if the manufacturer is outside the EU
Enter manufacturer and responsible person data per the latest Seller Center guidance, matching the label
Show pictures, model and other identifiers that match the product
Provide warnings and instructions in every sales country's language
Label fully managed stock before delivery: type/batch number, manufacturer, responsible person, warnings
Keep risk analysis, technical documentation and test reports for at least 10 years
Monitor platform notices and answer document, removal and recall requests on time

Common mistakes

Assuming Temu is importer and responsible person in the fully managed model
Temu's public terms say the contract is between the consumer and the seller named on the listing, and we found no public commitment by Temu to act as importer or EU responsible person for fully managed sellers. The law asks who places the product on the market and who is established in the EU. Check the listing and your contract; without a written arrangement, appoint your own authorised representative.
Treating the customs importer as the GPSR importer
Under Temu's terms the consumer may be the customs importer for cross-border parcels. A consumer is not an economic operator and carries no GPSR importer duties, and freight forwarders or customs agents normally only handle formalities. For products shipped from China, an authorised representative is usually the only possible responsible person.
Completing the back end but not the physical label
Article 19 covers the online offer; Article 9 and Article 16(3) cover the product. A responsible person entered in the Seller Center does not help if the goods in the warehouse lack it and lack local-language warnings. Label fully managed stock before delivery and make sure it matches the back-end data exactly.

Frequently asked questions

Do fully managed Temu sellers still need an EU Responsible Person?

Yes. Article 16(1) GPSR requires an economic operator established in the EU for every product. Fully managed goods are usually shipped from China, leaving no EU importer and no EU fulfilment service provider, so a written mandate with an EU authorised representative is the safe route for a Chinese brand owner.

Is Temu the importer in the fully managed model?

Legally, the importer is whoever is established in the EU and places the product on the market in its own name. Temu's EU terms say the contract is between the consumer and the listed seller, and that the consumer may be the customs importer for cross-border parcels. We found no public statement that Temu acts as importer for fully managed goods; check your agreement and listing.

Are Temu's requirements the same as the law?

The core matches Article 19: manufacturer, responsible person, product identification and local-language warnings. Temu may also ask for label photos or test reports; that is platform policy, not a format set by law. You need to satisfy both, following the latest Seller Center rules.

I resell another brand on Temu. Whose details do I enter?

As a distributor, enter the brand owner's (manufacturer's) details and the responsible person the brand owner appointed, and check before listing that the product carries the model, manufacturer data and local-language instructions (Article 12(1)). If you sell it under your own brand, you become the manufacturer.

Does the Commission's fine on Temu affect sellers?

The €200 million fine of May 2026 was imposed under the DSA for Temu's own risk assessment failures, not on sellers. But the investigation's tests found high failure rates for chargers and baby toys, so sellers in those categories should have test reports and technical files ready.

Official sources

This guide explains Regulation (EU) 2023/988 in plain language. It is general information, not legal advice. Requirements can depend on your product, other EU laws and the member state — check the official text and, for your own case, a qualified adviser.