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Product compliance on bol: what do you need to arrange for CE marking and legislation?

Lars Hurkmans·Co-founder·4 February 2026·Reading time 9 minutes

You don't comply with bol's rules, but with European product legislation: CE marking, GPSR and EPR. Arrange the documentation and tests first, lay down the requirements with your supplier, and only then buy the large batch. Make compliance and quality control a demonstrable part of your entire sourcing process, because the NVWA asks for it.

In our podcast we spoke with Francois from Instrux, a product compliance specialist. Francois has been selling on bol himself since 2019 and has a background in corporate law; with Instrux he guides sellers on CE marking and product legislation, and together we're recording a Knowledge Base on this topic. Below we've laid out the key insights from that conversation. You can also request a quote for your product compliance at Instrux. This is explanation, not legal advice.

Do you comply with bol's rules or with European legislation?

You comply with European legislation, not with bol's rules. That's the distinction Francois immediately makes when a client says they want to comply with bol's rules. His answer: you comply with European legislation, you just find out about it via bol. CE marking, the GPSR and EPR all come from the European Union. bol passes on those rules and checks whether you comply, because bol itself is bound by them too.

That also has an advantage. If you focus on European legislation instead of on one platform, you can immediately sell across all of Europe, not just on bol. The GPSR, the general product safety regulation for non-food consumer products, has applied across the whole EU since 13 December 2024. Under that regulation, bol requires you to state the manufacturer and the EU-based responsible economic operator on your items, with deadlines phasing in during 2026 (source: bol partner platform). In the Netherlands, the NVWA supervises this on behalf of the European Union.

If you run your own brand, in most cases you're the manufacturer in the eyes of the law yourself, even if a third party makes your product. That puts the responsibility for compliance on you. What that means compared to white label or reselling is covered in private label vs white label. Newer regulation also looks beyond product safety: for example, you need to be able to show where your raw materials come from and that you're not complicit in child labour or illegal labour. EPR is one of the abbreviations that comes up here.

Why has selling on bol gotten so much stricter in recent years?

Selling on bol has professionalised significantly since 2019. Francois started that year, when according to him it was still the wild west: there were far fewer rules, and departments such as quality, assortment and compliance barely existed. On top of that, you always spoke to the same twenty to twenty-five partner service staff, who recognised your name. Now that contact is more impersonal and the rules are stricter.

An example of how messy things were back then: someone registered a brand name many sellers used in their titles, and then sent mass removal requests to wipe out his competition in one go. That was simply a bol seller, with no connection to that brand.

According to Francois, the tightening comes from two directions. bol itself grew rapidly, started adding partners around 2012 already and professionalised along with that growth. On top of that comes European regulation, which bol simply has to comply with. You see it reflected in small things: "suitable for iPhone" or Samsung in your title was allowed, then not, then allowed again for large partners, and now only if your product works exclusively with that brand. The old subtitles under your product title have also been phased out. At the same time, competition from Temu, Shein and AliExpress plays a role; bol even built a tool that compares listings with those marketplaces.

Why does compliance need to be a demonstrable part of your sourcing process?

Because the NVWA can ask you for it. Somewhere in your entire sourcing process, from sourcing to sale, you need to be able to demonstrate what you do for compliance and quality control: how you make sure a product meets European legislation, and how you then check that it really does. That part needs to be written out in your process. Where in 2019 that was a small piece, it's now a fixed part of the whole chain.

Fully grasping the legislation itself is almost impossible. Francois, who studied law, says you spend two to three weeks just understanding the tip of the iceberg; product compliance and customs legislation aren't things you learn at university. On top of that, more keeps being added: he recently saw a list of ten new legislative proposals around products, and the European Commission is now working on a proposal to simplify the rules because there are simply so many of them.

Be careful with service providers who jump on this. If you search for "conformity declaration bol", according to Francois you also come across parties with no substance: AI photos, made-up reviews and claims that don't hold up. One such party was even called out by the NVWA because the declarations they supplied were incorrect.

In what order do you arrange compliance, and why does your container otherwise sit uselessly in Rotterdam?

Arrange the documentation and the tests first, only then buy the large batch. Once you know what you want to source, first determine which documentation and which tests you need, and lay down those requirements with the factory. So alongside your usual list of features and USPs, you make a list of requirements for documentation and information. Usually multiple factories make the same product, so you have enough choice to see who can meet those requirements. A good supplier can also help you here, because they often know what's happening in Europe.

If you do it in the wrong order, you run a concrete risk. Suppose you've already sourced the container and a retest shows the product isn't right, for example due to prohibited substances, then you're not allowed to sell anything and the whole container sits uselessly in Rotterdam. Francois sees this mistake even at listed companies; he mentions a company that had been selling a product for two years already containing a substance that's banned within Europe.

The individual steps of sourcing, comparing quotes, locking down specifications, testing samples and monitoring production are worked out in sourcing from China: step-by-step plan. And why you ask your supplier for a test report instead of a CE certificate is covered in CE certification on bol.

How big is your risk? Product risk times number of sales

Your risk is roughly the product risk times the number of sales. A product that's inherently dangerous and that you sell a lot of is a high risk; a harmless product you sell little of is a low risk. Francois gives the example of work boots: if you sell a thousand pairs a month, that's a thousand people who can break their toes if the boot doesn't do what it promises.

According to Francois, the NVWA is especially strict on anything involving babies and children; those products get flagged more often. You estimate the number of sales you expect beforehand in your market research; with MarktMentor you see the demand and the sales numbers within a niche, so you can back up that side of the risk assessment.

What does a recall cost, and why do companies go bankrupt over it?

A recall is the most expensive thing that can happen to you, and for many parties it's unbearable. You refund all consumers, including the VAT you get back yourself later but have to pay out first. On top of that come the return labels and your internal costs, think bookkeeping, management and overtime, and sometimes you still have to compensate a customer. The commission you paid bol you don't get back; bol keeps that.

The amounts add up quickly. In the podcast, Francois roughly calculates it with an example: ten thousand units of a forty-euro item means ten thousand times that forty euros back, plus ten thousand times a return label of roughly six euros, plus the internal costs. He mentions a client with nearly 175,000 euros in recall costs they were able to prevent, and a party that had to recall twenty thousand units and afterwards filed for bankruptcy. Treat those numbers as illustrations from his practice, not fixed amounts.

A recall can be short, but also long: phased over two months for a new batch, or over three years if you document poorly. Because your customer data on bol disappears after about a month, you need to request it from bol for a recall, which makes the action known internally at bol. Francois hasn't yet seen a deduction of policy points in this context. Such actions happen to big companies too: names like Action appear in the European warning system Safety Gate (source: Safety Gate). How a recall formally proceeds is covered by the NVWA.

What if a Chinese factory secretly swaps the material?

You can do little about it after the fact, so you lock down agreements and documentation beforehand. Francois describes a client who'd had a product tested against RoHS, the standard for certain metals that may only be present in a product to a limited extent or not at all. The sample was fine, the client bought twenty thousand units, and a later quality inspection rejected it. The Chinese factory had, without saying anything, used a different, cheaper material, in this example to save a few cents per unit.

At that point there's little you can do, Francois says honestly: it's bad luck. A sales department in China has to hit targets and won't shy away from lying about materials; if you complain, they'll block you if needed and label you a difficult customer to their manager. Europe has no jurisdiction over a factory in China, so you're somewhat at the mercy of fate. That's why the foundation needs to be right on your end: clear agreements, good documentation and a quality inspection before the container leaves. The risk partly lies with the factory, but you reduce it by laying down what you expect beforehand.

What's the most important practical lesson?

Model your compliance on an established A-brand, not on your competitor on bol. Francois gives this lesson more and more often these days: look, for example, at a Philips, a brand that's been around for years, and learn from what they do around product legislation. According to him it doesn't feel entirely fair, but it works. Because working through the legislation itself is nearly impossible, watching closely gets you a lot further, provided you understand what you're copying. That way you're at least doing something.

And treat compliance as a fixed part of your product research. Francois sees entrepreneurs on LinkedIn proudly sharing a launch, while he can already see from the product that they're actually not allowed to sell it, because they only looked at the revenue and not at the part that costs money. Looking at that part isn't fun, but for the reputation and lifespan of your business it matters; if it goes wrong, you can barely make up the costs afterwards. Which other skills belong here are bundled in what you need to succeed on bol.

Summary: what you arrange for product compliance on bol

In the Knowledge Base we're recording together with Francois from Instrux, we work these steps out further: which documentation you need per product, how you lay that down with your supplier, and how you check a test report.