The first year selling into Europe, in the order things start to bite

Companies rarely fail in Europe because a rule was too hard. They fail because they did the right things in the wrong order, and discovered it at the point where going back meant redoing work already paid for. The packaging printed before the responsible party was appointed. The brand shown at a trade fair before the trade mark was filed. The first container sold before the collection scheme was joined. None of those is a difficult task. All of them are expensive out of sequence, and the sequence is the part nobody writes down.

In what order should a Chinese exporter tackle Europe?

1. Decide what you are selling and to whom. Not the catalogue: the references you intend to place on the European market, and the customer — a consumer, a professional, a public buyer. Everything downstream is scoped by this answer, because the rules that apply, the language obligations and the liability regime all change with the buyer. An exporter who skips this step ends up testing a catalogue instead of a product range, and pays for it in laboratory invoices.
2. Establish which product rules apply, and have tested what has to be tested. Several regimes can apply to the same product at once, and the overlap is the part that surprises. This step ends with test reports in your hands, issued against the standards that correspond to those rules, and with the knowledge of whether an independent body has to be involved in your case or whether you may assess conformity yourself.
3. Build the technical file and appoint the party responsible in Europe. The file gathers the design, the risk assessment, the standards used, the test reports and the instructions, and it is what the responsible party agrees to hold and produce on request. Appointing that party has a printing consequence: its name and address go on the product, on the packaging and in the manual, which is why it has to be settled before any artwork is finalised.
4. File the trade mark before you show anything. Europe works on first filing, not on first use, which means the name you have used at home for years protects you here not at all. Once the name is public — a fair, a marketplace listing, a distributor's catalogue — anyone who saw it may file it, and buying it back is slower and more expensive than the filing you skipped.
5. Choose the country of entry, then settle the customs and tax mechanics. The goods arrive somewhere, and that somewhere determines who declares them, under which tariff treatment, with which party named as importer, and where you register for value added tax. This is also where you decide whether you are selling to a European buyer who imports, or importing yourself and selling locally, which is a different business with a different balance sheet.
6. Register with the collection schemes of each country you will sell in. Packaging, electrical equipment, batteries and several other streams each require a registration, country by country, and each member state runs its own registers with its own forms and its own reporting. The registration produces a reference that marketplaces and distributors ask for, and that reference has to exist before the first sale rather than after it.
7. Only now open the sales channel. The listing goes live, the distributor agreement is signed, the first order is accepted. Everything that happens from here produces obligations in real time — a customer with rights, a consumer who may withdraw, a distributor with a territory — and every one of those obligations is easier to honour than to retrofit, which is the whole reason this step waited.
8. Organise after-sales and returns before you need them. Where a faulty product goes, who inspects it, who holds the spare parts, who answers in the customer's language and working hours, and who pays the return freight. This is the step exporters leave for later, and it is the one that decides whether the first orders become repeat orders or a dispute with the distributor who absorbed the cost.

Why this order and not another?

Because each step produces a document that the next step consumes, and a step performed without its input has to be performed again. The scope decision tells the laboratory what to test. The test reports are what the technical file is made of. The technical file is what the responsible party agrees to hold, and that party's name is what the packaging and the manual have to carry. The country of entry decides who is named as importer, and the importer's identity is what several registrations are made in. The collection scheme reference is what a marketplace asks for before it activates a listing. Follow the chain backwards and you can see why there is no shortcut: the sequence is not a preference, it is the shape of the paperwork.

The reversals have signatures you can recognise. Artwork printed before the responsible party was appointed means relabelling a shipment by hand in a warehouse, or reprinting a volume of boxes that was ordered in volume precisely to be cheap. A brand shown before it was filed means either paying someone for your own name or launching under a different one, after the distributor has already announced the first. Selling before joining the collection scheme means arrears calculated back to the first sale, and a marketplace that suspends the listing while you sort it out. Testing before scoping means a drawer of reports against standards that turned out not to apply. None of these is a catastrophe. All of them cost more than the step they skipped.

What can run in parallel, and what cannot

• The trade mark filing runs alongside everything. It depends on no other step, it is the cheapest item on the list, and it is the only one whose cost rises purely with delay. Start it the day the European name is chosen and let it proceed while the laboratory works.
• Customs classification and the tax setup run alongside testing. They involve different people and different documents, and knowing the tariff treatment early changes your landed cost and sometimes your choice of entry country, which is better discovered before you have committed to a distributor.
• Packaging design runs alongside the technical file, up to a point. Draw everything, choose the materials, size the print run — and leave the legal block, with the responsible party's name and address and the required markings, as the last thing filled in. Freezing that block early is the most common self-inflicted reprint.
• The declaration of conformity cannot precede the tests. It is a statement that rests on evidence, and signing it before the evidence exists is not an administrative shortcut; it is a false declaration, with the consequences that word carries in every member state.
• Selling cannot precede the collection scheme registration. The obligation attaches to the first unit placed on that country's market, not to the volume, and the registers are national — so entering a second country reopens the step rather than extending it.
• Showing the brand cannot precede filing it. A trade fair, a marketplace listing, a distributor's catalogue and a press release are all publication, and publication is what gives someone else the idea. This is the one irreversible item on the list.

The mistake that costs the most: selling first, documenting after

The temptation is understandable, because selling is the only step that brings money in and all the others look like expenses. The trap is that a sale creates a product on the market, and a product on the market is a subject of obligations that run from that moment and cannot be backdated. You now owe a conformity file you have not built, a registration you have not made, a manual in a language you have not translated, and an after-sales answer to a customer who already has rights. Worse, you owe them to a distributor who committed to its own customers on your word, and the conversation in which you explain the delay is the one that decides whether that distributor ever reorders. Documenting first is slower by weeks and cheaper by an order of magnitude, and the difference is not the fine — it is the relationship you cannot buy back.

How do we know the first year went well?

Not by the revenue, which in a first year says more about the distributor than about you. The signals are duller and they are more reliable. Orders renew without renegotiation, which means the goods arrived as described and nothing in the chain cost your customer money it had not planned to spend. No authority has written to you — no customs query held a container, no market surveillance letter arrived, no collection scheme asked why it had no report from you — and silence from those quarters is the only compliment they ever give. And the file maintains itself: a change in a part produces an updated declaration, a new country produces its registration, a new model enters the same process, without anybody having to remember. A company with those signals has built something; a company with a good number and none of them has had a good year and still has the first one ahead of it.

Write the sequence on a single sheet, with a name and a date beside every step, and put the name of the person who owns the whole sheet at the top. The steps are not hard; what fails is ownership, because each one belongs to a different function — engineering, quality, legal, logistics, finance, sales — and a task owned by everyone is owned by nobody. Review that sheet at a fixed moment each month and the sequence holds by itself. Review it when a customer asks a question and you will spend the year discovering the order the expensive way.

Where to read it yourself

Official pages, opened and checked on 15 October 2026. Where a rule changes, these are the addresses that change with it — this article does not.

• Building blocks of the single market for goods — European Commission