EU compliance guide

GPSR: What Brands Selling Into the EU Now Have to Get Right

4 November 2026 · Bearsource


GPSR: What Brands Selling Into the EU Now Have to Get Right

If you sell consumer products into the European Union, a law you may never have read is probably deciding whether your products can be listed, shipped and sold. Since 13 December 2024, the EU's General Product Safety Regulation — the GPSR, formally Regulation (EU) 2023/988 — has applied in every EU country. It replaced the old product safety directive from 2001, and it was written for the way people actually buy things now: online, cross-border, very often from sellers outside Europe.

Germany is where many brands feel it first. It is the EU's biggest consumer market, its market surveillance authorities are active, and Amazon enforces the rules on Amazon.de before any official gets involved. Whether you sell into Germany or anywhere else in the EU, here is what the GPSR actually asks of you, in plain terms.

What the GPSR covers

The GPSR is the EU's safety net for consumer products. It covers almost every product sold to consumers in the EU, including products sold online and shipped in from outside. Where a product has its own sector rules — toys, for example, or electrical products — those rules still apply, and the GPSR fills the gaps around them: the responsible person, online listing information, accident reporting and recall rules can still apply to CE-marked products.

A few categories sit outside it completely, such as medicines, food and medical devices. Products first placed on the EU market before 13 December 2024 are also outside. Everything you ship in now is inside.

The core idea is simple: every product needs a named business inside the EU that answers for its safety. No anonymous imports, no "the seller is somewhere overseas and cannot be reached".

The responsible person: one EU address on every product

This is the rule that catches most non-EU brands. Under Article 16 of the GPSR, a consumer product may only be placed on the EU market if there is an economic operator established in the EU responsible for it. That responsible person can be:

  • An EU importer who brings the product in
  • An EU manufacturer, if the product is made in the EU
  • An authorised representative you appoint in writing
  • In some cases, a fulfilment service provider handling the goods

The responsible person's name and postal and electronic address must appear on the product itself, on its packaging, on the parcel or on an accompanying document.

If you are a US brand selling direct — your own webshop, or Amazon shipped from the US or China — there is usually no EU importer in the chain. That gap is yours to close. Most brands in this position appoint a responsible-person service inside the EU. Expect to pay a few hundred euros per year for it. It is not a mailbox rental: a real responsible person keeps your documentation, answers questions from authorities and has to be able to act if a product is found to be dangerous.

One practical relief: one responsible person in any EU member state covers all 27 countries. You do not need a separate one for Germany, France and Spain.

There is also a border dimension. EU customs and market surveillance authorities work together, and goods that arrive with no responsible person, no manufacturer details or obvious safety problems can be held and refused release. The product does not have to hurt anyone first. Missing paperwork is enough. If your goods ship under DDP terms through an agent, be especially careful: whoever acts as importer carries duties too, and "my shipping agent handled it" has not proven to be a defence when a shipment is examined.

Traceability and labelling

The GPSR wants every product to be traceable back to who made it and which batch it came from. In practice that means:

  • Manufacturer name and address on the product or packaging (that can be you, if it's your brand)
  • A product identifier: type, batch or serial number — something that ties a unit to a production run
  • Importer details, where an importer is involved
  • Warnings and instructions in the language of the country of sale. For Germany, that means German. An English-only manual is one of the most common and most avoidable GPSR problems

The important operational point: all of this is decided before production, not at the warehouse. Labels, printed packaging and manuals are part of the production run. Brands that treat labelling as an afterthought end up reprinting, stickering, or holding stock they cannot legally sell.

Documentation: the file behind the product

Before a product goes on sale, the manufacturer is expected to carry out an internal risk analysis and build a technical file: what the product is, which standards apply to it, what testing was done and what risks were found and fixed.

Two duties catch people out:

  • The technical documentation and records of complaints must be kept for ten years
  • Complaints about safety have to be logged, investigated and recorded — an inbox folder of angry emails is not a system

Market surveillance authorities can ask for this file, and "the factory has it somewhere" is not an answer if you cannot produce it. Agree with your factory early on who creates which document and who keeps the original: test reports, material declarations and the risk analysis should be in your hands before the goods ship, not requested afterwards.

Selling online: your listing is now a label

The GPSR treats a web listing much like the printed label. Under Article 19, an online offer to EU consumers must show the manufacturer's contact details, the responsible person's details where the manufacturer is outside the EU, information identifying the product (including a picture), and any required warnings.

Marketplaces have their own duties under Article 22 — registering with the EU's Safety Gate portal, acting on takedown orders within two working days, and informing buyers when a product is recalled. The practical effect lands on you: platforms verify sellers because the law makes platforms responsible for policing their listings.

Amazon is the clearest example. In Seller Central, every EU listing needs manufacturer details, responsible person details and a safety attestation, plus supporting documents in the language of the marketplace. Listings with missing GPSR data get suppressed — the product still exists, but nobody can buy it. Two details matter: Amazon checks store by store, so fixing Amazon.de does not fix Amazon.fr, and a bulk upload can quietly overwrite good data. Check your compliance dashboard after every catalogue upload.

When something goes wrong

If your product causes an accident, you have to report it to the authorities through the EU's Safety Business Gateway. If a product turns out to be dangerous, the GPSR prescribes how recalls work: a clear recall notice, direct contact with buyers where possible, and a free remedy for consumers — repair, replacement or refund.

In Germany, enforcement runs through the market surveillance authorities of the federal states under the Produktsicherheitsgesetz (ProdSG). The tools they have are sales bans, recall orders, fines and customs stops on incoming goods. In practice, though, the first and most expensive hit for most brands is quieter: a suppressed Amazon listing and stock sitting in a warehouse that cannot be sold.

A practical GPSR checklist

  • Confirm the scope: is the product fully under the GPSR, or do sector rules (toys, electronics, cosmetics) apply as well?
  • Appoint an EU responsible person before the first shipment, not after the first blocked listing
  • Do the risk analysis and collect test reports against the relevant European standards
  • Set up the technical file and store it where you can reach it for ten years
  • Update the labels: manufacturer, responsible person, importer if any, and a batch or lot identifier on every unit
  • Translate warnings and instructions into German — and into the languages of every other EU market you sell in
  • Update your online listings with the Article 19 information, and complete Amazon's GPSR fields in every EU store you use
  • Start a complaints log and name one person who owns it
  • Agree document duties with your factory in writing, with dates — before production, not before shipment
  • Write a simple recall plan: who decides, who contacts customers, what remedy you offer
  • Check packaging and EPR separately. The GPSR does not cover it — in Germany, packaging registration (LUCID) is a separate duty that blocks listings just as effectively

The bottom line

The GPSR is not a paperwork hobby for lawyers. Its requirements — responsible person, labelling, traceability, documentation, translations — are all things that happen at the factory, during product development and production. Handled early, they are a few lines on a label and a folder of documents. Handled late, they are blocked listings, held stock and a recall with no system behind it.

Selling into the EU? This is part of the production work we manage. As a production-management partner, we build the GPSR file alongside the product: risk analysis and test reports, label and manual content including your responsible person, batch traceability, and the listing information Amazon EU asks for. You bring the product. We take it from idea to shipment, compliance included.

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