Reviewed 10 November 2026 · Original publication date shown above
In this article we are going to discuss grey imports and who is responsible for conformity, using the TwoTrees laser engraving machine (Alert number A11/00034/22) which was reported on RAPEX as an example.
The fortress Europe myth
EU product rules set safety requirements, but market surveillance cannot inspect every product entering the market. A listing on a familiar marketplace, or a CE logo alone, is not evidence that a particular machine is compliant.
If no one is checking, how is conformance guaranteed?
Manufacturers, importers and distributors each have responsibilities under the legislation that applies to the product. An EU importer placing goods from outside the EU on the market must check the manufacturer's conformity work and the required documentation.
Ask who the responsible EU economic operator is and whether the exact machine model can be traced through the declaration, instructions and product markings.
Importers' responsibility
When importing from non-EU countries, importers must check that products fulfil all EU safety, health and environmental protection requirements before placing them on the market. The importer has to verify that:
the manufacturer outside the EU has taken the necessary steps to allow the product to be placed on the EU market
the necessary documentation such as the EU Declaration of Conformity and the technical documentation is available upon request
contact with the manufacturer is possible at any time
Direct-to-consumer purchases
Online marketplaces make it easy to buy a machine from outside the EU. Do not assume that a marketplace listing, delivery from a local warehouse or the presence of a CE logo means the product has been independently approved.
The legal role of a buyer depends on the transaction and applicable product legislation. A private purchase is not automatically the same as placing a product on the market as a commercial importer. Businesses importing machinery for their own use also need to check the obligations that apply before putting it into service.
The TwoTrees example and marketplace screenshots below document the situation discussed in the original 2022 article. They are historical evidence, not a statement about every current TwoTrees model or listing.
Before buying, request the exact model's EU Declaration of Conformity, identify the responsible supplier, and check the official Safety Gate record for any matching alert.
