GPSR for importers, answered

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.

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.

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.

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.

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.

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.

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 serious accident triggers it.
• Waiting for certainty is the error. The duty attaches to knowledge of the accident, not to a conclusion about fault.
• Telling your supplier is not reporting. The notification goes to the authorities through the Gateway, and separately you inform the manufacturer and take corrective measures.

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.

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.