Export readiness · 02 of 10
4 min read
Who carries the responsibility: the economic operator, slowly
Somebody has to be answerable for a product sold in Europe. European law gives that role a name, the economic operator, and it is never the software you used to write the record down.
What the role actually is
The operator is whoever places the product on the EU market: the manufacturer selling under its own name, the importer bringing it in, or an authorised representative appointed in writing and established in the Union. ESPR Art. 27 puts the obligations there. If your buyer imports your goods, your buyer is very likely the operator. If you ship direct to European customers yourself, you need a representative.
Mula is never the operator
We say this early because it is the most misread thing in the whole subject. We hold data, we help you get it in order, and we build the page the code opens. We do not place your product on any market, and using us registers nothing anywhere. The declaration of conformity, the technical file, and the registry entry are yours. We track whether they exist and we never draft them for you.
What that means at the counter
Agree in writing who the operator is before the first shipment, not after a question arrives. A brand that assumed its buyer took the role, and a buyer that assumed the brand did, produce the same outcome: nobody prepared the file. One line in the purchase agreement removes the entire problem, and it is a much easier conversation to have while everyone is still cheerful about the order.
The claim you make is a separate duty
There is a second responsibility that travels with words rather than goods. Under Directive (EU) 2024/825, which applies from 27 September 2026, whoever makes an environmental claim to a European consumer has to be able to substantiate it. That duty sits with the party saying it, wherever they sit in the chain. It is one more reason our pages carry facts with their source attached rather than adjectives.
The essentials
- The operator is the manufacturer, the importer, or an appointed representative, under ESPR Art. 27.
- Mula is never the operator, and using Mula registers nothing.
- Put the role in writing before the first shipment.
Primary sources
- Regulation (EU) 2024/1781 (ESPR), Art. 27. Checked 17 August 2026
- Directive (EU) 2024/825 on empowering consumers, applies 27 September 2026. Checked 13 August 2026
Criteria here are drawn from the ESPR text and the JRC preparatory study. Sources last checked 17 August 2026, and re-checked at every JRC milestone. Binding requirements for textiles begin only after the textile act is adopted and its lead time has run.
Where we stand
Mula is not affiliated with the European Commission, the JRC, or any certification body. What we do is readiness: getting your own evidence into order. We are not an economic operator, we do not register products in any system, and we never state that a product meets a rule. That judgement belongs to the party placing the product on the market and to the authorities.
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