The General Product Safety Regulation has applied since 13 December 2024 to every consumer product with no threshold at all, and marketplaces enforce it themselves. These are the questions that come up once you are inside it; what the technical file has to contain, who may act as your Responsible Person, what an online listing must show, and what you report when something goes wrong.
Reference material, not legal advice. Every article number below is the number in the consolidated text of Regulation (EU) 2023/988 on EUR-Lex, and links to it.
In one paragraph: who, what, since when, and what if you do not
Who and what. GPSR covers every product placed or made available on the EU market for consumers, insofar as no other EU law regulates the same safety aspect (Article 2). There is no turnover threshold, no size threshold and no product list; if it reaches a consumer and no sector regulation covers the risk, GPSR is the whole of it. It applies to new, used, repaired and reconditioned goods alike, but not to products that are sold to be repaired or reconditioned before use and are clearly marked as such (Article 2, paragraph 3).
What is outside it. Article 2(2) is a closed list, running from point (a) to point (i): medicinal products for human or veterinary use; food; feed; living plants and animals, genetically modified organisms and genetically modified microorganisms in contained use, as well as products of plants and animals relating directly to their future reproduction; animal by-products and derived products; plant protection products; equipment on which consumers ride or travel where that equipment is directly operated by a service provider within the context of a transport service provided to consumers and is not operated by the consumers themselves; aircraft referred to in Article 2(3), point (d) of Regulation (EU) 2018/1139; and antiques. Nothing else is carved out.
Two of those nine are routinely read wider than they are written, and both misreadings cost money:
"In contained use" is part of point (d), not a footnote to it. Contained use means a closed laboratory or production environment. A consumer product you import and make available on the market is by definition not in contained use, so do not count on a genetically modified organism inside your product switching GPSR off; the exclusion will almost never reach you. The tail of the same point covers seed, semen and embryos, being products of plants and animals relating directly to their future reproduction.
Point (g) only bites inside a transport service. It requires equipment that is directly operated by a service provider within the context of a transport service provided to consumers, and that is not operated by the consumers themselves. Operation by a business is not on its own enough: fairground and amusement rides, and anything the consumer drives or steers, stay inside GPSR.
The roles, each with its own article. Manufacturer Article 9(2) and following; authorised representative Article 10; importer Article 11(1) and following; distributor Article 12; anyone who sells under their own name or substantially modifies a product becomes the manufacturer (Article 13); the responsible person established in the Union Article 16(1); the online marketplace Article 22. You can hold more than one of these at once.
Since when. 13 December 2024 (Article 52). Products placed on the market before that date in conformity with the old Directive 2001/95/EC may still be made available (Article 51), so stock that was already inside the Union on 12 December 2024 is not retroactively unlawful; everything you have imported since is.
What if you do not. The regulation itself sets no amounts: Article 44 leaves penalties to the member states, requiring them to be effective, proportionate and dissuasive. In practice the sanction that lands first is commercial, not administrative; a marketplace suspending your listings, or customs and market surveillance stopping the goods.
The paperwork
Is there such a thing as a GPSR certificate? no
No. GPSR has no certification scheme, no notified bodies and no certificate. Any document sold to you as a "GPSR certificate" is a supplier self-declaration or a test report with a marketing cover, and it does not discharge your obligation.
Full answer — the grounds, the numbers, the pitfalls
What the regulation actually requires is that the product is safe, that an internal risk analysis has been done, and that technical documentation exists and can be handed to an authority. There is no third party that signs that off.
The confusion is worth money to whoever sells the document, so it persists. Two things follow:
A supplier certificate is evidence, not compliance. It may be useful in your file. It does not replace your own risk analysis, and it does not transfer the duty.
If a marketplace asks for "the GPSR certificate", they mean the documentation. Sending a purchased certificate usually fails the check; sending the technical file and the Responsible Person details usually passes it.
Common mistake: paying for a certificate and treating the file as done. The same mistake as the REACH certificate; see why ECHA issues none either.
Source:Regulation (EU) 2023/988, Articles 5 and 9; no conformity-assessment regime is created by the regulation. Checked: 3 September 2026.
What has to be in the technical file? Article 9(2)
At minimum a general description of the product and the characteristics relevant to assessing its safety. Where the risks call for it, also an analysis of those risks and the solutions adopted, including the results of any tests carried out by you or on your behalf. It is kept for ten years from placing on the market.
Full answer — the grounds, the numbers, the pitfalls
The regulation does not prescribe a template, which is why so many files are thin. What an authority actually asks for, in the order they ask:
What the product is; description, photographs, materials, intended use, and the foreseeable misuse you considered.
The risk analysis; which hazards you identified, how you judged them, and what you changed or warned about as a result. A file with no risks identified reads as a file where nobody looked.
Test reports where testing was appropriate, with the standard applied.
Labels and instructions as they actually appear, in every language you sell into.
Who is who; manufacturer, importer, Responsible Person, with the mandate.
As an importer you keep your own copy. Pointing at the manufacturer is not enough: if the file is in a factory in another country and cannot be produced, the product is treated as undocumented.
Common mistake: assuming ten years runs from purchase. It runs from the day the product is placed on the EU market, so the clock on your last unit outlives the supplier relationship.
Can my fulfilment provider or freight forwarder be my Responsible Person? only in writing
Sometimes, but never by default. The Responsible Person must be established in the Union and must have accepted the role in a written mandate that expressly covers the tasks. A fulfilment service provider can take it on; a forwarder who merely moves your boxes has not, and assuming otherwise leaves you with no Responsible Person at all.
Full answer — the grounds, the numbers, the pitfalls
This is where listings get suspended, because the seller believed someone else was covering it. What has to be true:
Established in the EU. A UK entity does not qualify; the United Kingdom has not been part of the Union since 2021.
A written mandate. Where the role is taken by an authorised representative, the mandate has to specify the tasks they agree to carry out. A mandate that does not mention the GPSR tasks does not cover them.
Named where the buyer can see it. The name and address go on the product, the packaging or the accompanying document, and into the online offer.
The commercial question underneath: whoever holds this role carries real exposure, which is why it is priced per company or per catalogue rather than thrown in free. Published prices run from roughly €200 to €800 per year.
Common mistake: naming a company as Responsible Person without asking them. It is not a label you can apply to someone; it is a role they have to accept.
Source:Regulation (EU) 2023/988, Article 16(1) and (3) (responsible person for products placed on the Union market; name and contact details on the product, its packaging, the parcel or an accompanying document) and Article 10 (authorised representative; written mandate). Checked: 5 September 2026.
Selling online
What has to appear in an online listing? Article 19
In every single offer, before the buyer commits: the manufacturer's name and contact details, the Responsible Person's name and contact details, information identifying the product including an image, and any warning or safety information. Not on a linked page; in the offer.
Full answer — the grounds, the numbers, the pitfalls
Article 19 is the article most sellers have never read, and it is the one marketplaces automate against. It applies to distance selling generally, not only to marketplaces: your own webshop is caught too.
What that means in practice:
Warnings must be visible before purchase. A choking-hazard warning printed on the box and nowhere in the listing does not satisfy this.
Every language you sell into. A Dutch listing needs Dutch warnings; a German one needs German.
The image counts as product identification. Stock photography that does not show the actual product undermines it.
Where a marketplace supplies the fields, use them: their compliance check reads those fields, not your description text.
Common mistake: putting the Responsible Person only in the shop footer or the terms. The obligation attaches to the offer for each product.
Source:Regulation (EU) 2023/988, Article 19 (obligations in the case of distance sales). Checked: 3 September 2026.
My listing was suspended. How do I get it back? the file, not the certificate
By supplying what the check actually looks for: an EU-established Responsible Person recorded against the listing, the manufacturer details, and the safety information in the listing fields. Suspensions are almost never about whether the product is safe; they are about whether the required information is present.
Full answer — the grounds, the numbers, the pitfalls
The order that resolves it fastest:
Fix the Responsible Person first. Without an EU entity recorded, nothing else you upload will clear the check.
Fill the structured fields rather than the free-text description. Automated checks read the fields.
Have the technical file ready but do not lead with it. Send it when asked.
Marketplaces including Amazon and Kaufland have been enforcing this since 2025 and suspend listings that lack it regardless of the product. Reinstatement usually follows within days once the fields are complete; appeals that argue about the product rather than the information tend to stall.
Common mistake: buying a "GPSR certificate" in response to a suspension. It is not what the check reads, and the listing stays down.
Source:Regulation (EU) 2023/988, Articles 19 and 22 (obligations of providers of online marketplaces); marketplace enforcement practice since 2025. Checked: 3 September 2026.
Scope and what happens when it goes wrong
Does GPSR apply to second-hand and refurbished goods? usually yes
Yes, when an economic operator places or makes them available on the market. Used, repaired, refurbished and reconditioned products are in scope. Two carve-outs matter: products clearly marketed as needing repair or reconditioning before use, and antiques.
Full answer — the grounds, the numbers, the pitfalls
The distinction is what you tell the buyer. A refurbished appliance sold as ready to use is in scope in the ordinary way. The same appliance sold explicitly as a repair project, marked as such, is not treated the same.
Where this catches people:
"Used" is not a defence. Trading in second-hand goods as a business is placing them on the market.
Refurbishing can make you the manufacturer. Modify a product substantially and the obligations of a manufacturer attach to you, including the technical file.
Private sales between consumers are outside it. The regulation reaches economic operators.
Source:Regulation (EU) 2023/988, Article 2 (scope, including the exclusion for products to be repaired or reconditioned before use, and for antiques). Checked: 3 September 2026.
Something went wrong with my product. What do I report, and where? Safety Business Gateway
Two duties, and they do not run to the same address. An accident is notified through the Safety Business Gateway by the manufacturer, without undue delay from the moment it knows, to the authorities of the member state where the accident happened; an importer or distributor who learns of one informs the manufacturer, and the manufacturer then notifies or instructs one of them to do it (Article 20). A product you have yourself found to be dangerous is the other case, and there the notification is yours to make: Article 11(8) as importer, Article 12(4) as distributor.
Full answer — the grounds, the numbers, the pitfalls
The notification states the type and identification number of the product and the circumstances of the accident as far as they are known. "Without undue delay" means from the moment you know, not from the moment you have finished investigating.
What people get wrong here:
It is not only for recalls. A single accident triggers it. What counts is defined: occurrences associated with the use of a product that resulted in a person’s death or in serious adverse effects on that person’s health and safety, permanent or temporary, including injuries, other damage to the body, illnesses and chronic health effects.
Waiting for certainty is the error. The duty attaches to knowledge of the accident, not to a conclusion about fault.
For an accident, telling the manufacturer is exactly what you do. The notification itself sits with the manufacturer. An importer or distributor who knows of an accident informs the manufacturer without undue delay, and the manufacturer either makes the notification or instructs the importer or one of the distributors to make it. Where the manufacturer is not established in the Union, the responsible person (Article 16(1)) who knows of the accident has to ensure the notification is made.
For a dangerous product, telling the manufacturer is not enough. That is a different article, and there the Gateway notification is your own. As importer you inform the manufacturer; ensure the corrective measures are taken, and take them yourself where the manufacturer has not; ensure consumers are informed in accordance with Article 35 or 36, or both; and inform the market surveillance authorities of every member state where the product was made available, through the Gateway (Article 11(8)). That fallback, taking the measures yourself when the manufacturer will not, is the duty importers most often miss and the one they are themselves liable for. Article 9(8) is the manufacturer’s version of the same duty and is not your rule, unless you place the product on the market under your own name or trademark or substantially modify it, which makes you the manufacturer (Article 13); private-label importers usually are.
Where a product is dangerous, corrective measures follow; withdrawal or recall; and consumers have to be informed directly where the product can be traced to them.
Source:Regulation (EU) 2023/988, Article 20 (accidents; the manufacturer notifies through the Safety Business Gateway, importers and distributors inform the manufacturer, and where the manufacturer is not established in the Union the responsible person ensures the notification is made), Article 11(8) (importer who finds a product dangerous) and Article 12(4) (distributor), with Article 9(8) as the manufacturer’s equivalent; Articles 35 and 36 on recall and consumer information. Checked: 5 September 2026.
Does GPSR replace CE marking? no; it fills the gaps
No. Where specific EU legislation covers a product's safety; toys, machinery, low voltage, radio equipment, PPE; that legislation applies and GPSR covers only the aspects and risks it does not reach. For products with no sector legislation, GPSR is the whole of it.
Full answer — the grounds, the numbers, the pitfalls
So the two questions are separate and both have to be answered:
Is there sector legislation for this product? If yes, that comes first, with its own conformity assessment, declaration and CE mark.
Is there a residual risk it does not address? Then GPSR applies on top for that risk.
A product can therefore carry a CE mark and still have GPSR obligations, and a product with no CE regime at all; furniture, textiles, most homeware; is fully inside GPSR. Neither answer excuses the other.
Common mistake: "we have CE, so GPSR is covered". CE addresses the risks its directive addresses. Anything outside that is still yours.
Source:Regulation (EU) 2023/988, Article 2(1) (application to aspects and risks not covered by specific Union law). Checked: 3 September 2026.
Working through it product by product? The GPSR checklist has the fifteen checks, each linking back to the answer here and to the article on EUR-Lex.
The companies that act as EU Responsible Person are mapped on the providers page; editorial and unpaid, with what each one publishes about itself.
Check it yourself, at the source
Every answer above names the regulation and the article; the number links straight to the consolidated text on EUR-Lex. These are the official portals behind this page, each one checked on the date in the answers above.
EUR-Lex — consolidated text of every EU regulation and directive
Safety Business Gateway — where businesses notify accidents and dangerous products (GPSR Article 20)
NANDO — the EU list of notified bodies, per directive and per country
Check your EU Responsible Person or supplier
Nine official sanctions lists, one search. Free, no account.
Check this against your own situation
A consumer product is already filled in; The check then asks six more questions about origin, your role and where you sell, and names every regime that lands on you, each with the article behind it.