Most people asking about EU compliance are asking about CE marking. It's the famous one, the one with a logo, the one every guide covers.
Meanwhile the regulation far more likely to stop you selling has no logo at all, applies to your product whether or not CE marking does, and almost nobody writes about it.
That's GPSR. And if a marketplace has ever pulled a listing of yours with a vague message about safety documentation, this is probably why.
What changed, and when
The General Product Safety Regulation — Regulation (EU) 2023/988 — has applied across every EU member state since 13 December 2024. It replaced the old General Product Safety Directive from 2001.
Two things about that make it different from what came before.
It's a regulation, not a directive. Directives get transposed into national law, member state by member state, with local variation. Regulations apply directly and identically everywhere. There is no national version to look up and no local interpretation to hide behind.
And it applies to essentially all consumer products placed on the EU market. Not a category. Not a risk class. There's no carve-out for small businesses, no threshold below which it stops mattering, and no exemption for selling only through a marketplace.
Which produces the sentence I'd most like you to take from this article:
No CE mark required does not mean no compliance required.
If your product is a plain cotton tote bag — no CE marking anywhere in sight — GPSR still applies to it.
The four obligations
1. An EU-based responsible person
This is the one that blocks sales, so start here.
A product covered by GPSR may not be placed on the EU market unless there is an economic operator established in the EU who is responsible for it. Not a preference. A precondition.
If you're established in the EU and importing, that's probably you. If you're outside the EU — UK, US, anywhere — you must designate someone inside it. This role goes by several names: EU responsible person, EU representative, authorised representative.
What they're for: holding the technical documentation, being the contactable party for market surveillance authorities, and cooperating if something goes wrong. They are a real legal function, not a mailbox.
Options in practice:
- An EU-established importer or distributor you already work with
- Your fulfilment partner if they offer the service
- A dedicated compliance service (prices vary widely)
This is a genuine pain point for small non-EU sellers — the market for affordable EU representation is thin. But without one, everything else is academic.
If you take one action after reading this article: establish who your EU responsible person is. Write it down. Get it in writing from them.
2. Labelling and traceability information
Your product or its packaging must carry:
- The manufacturer's name, postal address and electronic address
- A product identifier — type, batch or serial number
- The name and contact details of the EU responsible person
This is how a recall reaches the right units instead of your entire catalogue, and it's why "we'll sort the packaging later" is an expensive plan. Get these fields into the artwork brief before the factory prints five thousand boxes. Retro-fitting labels onto landed stock is a job nobody enjoys and everybody has done once.
Beyond the product itself, you're expected to keep traceability records — who you bought from, who you sold to — so a problem can be traced in both directions.
3. A documented risk analysis
You are expected to have carried out an internal safety assessment of your product and to be able to show it, along with technical documentation, to market surveillance authorities on request.
This intimidates people more than it should. For most consumer products it is not a laboratory exercise. It's a written record of:
- What the product is and how it's intended to be used
- How it could foreseeably be misused
- What could go wrong (materials, sharp edges, small parts, cords, electrical elements, chemical content)
- What you did about each of those
- Instructions and warnings provided
The reason to write it down isn't bureaucratic. It's that the act of writing it forces you to look at your product the way an unlucky customer will.
4. Incident reporting
If you discover your product is unsafe, you have an obligation to notify the authorities through the Safety Business Gateway, and to take corrective action.
You're also expected to keep an eye on the Safety Gate alert system for alerts matching products like yours. If something in your category is being recalled EU-wide, that's information you want before your customers have it.
The thing to understand about reporting: discovering a problem and reporting it is a manageable situation. Discovering a problem, saying nothing, and having an authority find out later is a materially worse one. GPSR is built to reward the first behaviour.
Why marketplaces are stricter than you expect
GPSR gives online marketplaces their own obligations — which they have handled, entirely rationally, by pushing the requirements onto sellers.
So Amazon, Etsy and eBay now ask for responsible person details and product safety information, and suspend listings that don't have them. Sellers experience this as the platform being difficult. It isn't. The platform is complying with a regulation that also applies to you, and it's simply enforcing earlier than any authority would.
This is worth internalising if you're planning to sell through marketplaces: your listing can be pulled for missing GPSR information even if your product is perfectly safe. Safe and compliant are different states.
It's also a quiet argument for not building your business entirely inside someone else's platform — but that's a separate article.
What this actually costs
Consistent with the pattern across EU product compliance: the paperwork is free, and the cost is time.
Free
Writing the risk analysis, compiling technical documentation, keeping traceability records, registering to report through the Safety Business Gateway, monitoring Safety Gate alerts. All of this is your attention, not your budget.
Costs money
An EU responsible person if you need to buy the service, and any testing your risk analysis tells you is necessary. Nothing else, for most products.
Costs time
Getting the labelling right before production, which means deciding it early. And the risk analysis itself, which is a couple of focused hours rather than a project.
The expensive version of GPSR is the one where you discover it after your stock has landed — because then it's re-labelling, a scramble for representation, and listings suspended during your launch window.
The GPSR compliance checklist
Work through this once per product.
Before you order
- Confirm who your EU responsible person will be. Get it in writing.
- Draft the label copy: manufacturer name, postal address, electronic address, product identifier, responsible person contact. Put it in the artwork brief.
- Decide your batch or serial numbering scheme. Even a simple one.
Before you sell
- Write the risk analysis. Intended use, foreseeable misuse, hazards, mitigations.
- Assemble the technical file — specifications, test reports, the risk analysis, supplier details.
- Write the instructions and safety warnings, in the language of each market you sell into.
- Check your product against Safety Gate for alerts on similar items.
While you're selling
- Keep traceability records — suppliers and customers, both directions.
- Register for and know how to use the Safety Business Gateway before you need it.
- Re-check when you change supplier, material or specification. A changed product is a new assessment.
GPSR Compliance Checklist for Small Sellers
The 10-point checklist in one printable page — what to do before you order, before you sell, and while you're selling. PDF, no email required.
Download checklist →Or join the course waitlist for the full compliance module with templates and scripts.
Where GPSR sits next to everything else
A quick map, because these get conflated:
| Regime | Applies to | What it demands |
|---|---|---|
| GPSR | Essentially all consumer products | Responsible person, traceability, risk analysis, incident reporting |
| CE marking | Only products covered by specific harmonisation legislation | Conformity assessment, Declaration of Conformity, the mark |
| REACH | Chemical content of products | Restricted substances, SVHC communication, SCIP notification |
They stack. A Bluetooth speaker needs all three. A cotton tote bag needs GPSR and the relevant parts of REACH, and must not carry a CE mark. Getting this wrong in the other direction — applying CE marking to a product outside its scope — is itself a breach.
On the UK: post-Brexit, Great Britain runs a separate regime with its own rules. GPSR does apply in Northern Ireland. If both markets are in your plan, treat them as two workstreams.
FAQ
Does GPSR apply if my product doesn't need CE marking?
Yes. GPSR applies to essentially all consumer products regardless of whether CE marking does. It's the floor underneath everything, and it's the more common reason for a listing to be suspended.
Who is the EU responsible person, exactly?
An economic operator established in the EU who takes legal responsibility for the product — holding technical documentation, being contactable by market surveillance authorities, and cooperating on corrective action. It can be an EU importer, a distributor, a fulfilment partner or a dedicated compliance service.
Do I need one if I'm based in the UK?
Yes, if you sell into the EU. Post-Brexit a UK business is a non-EU business for these purposes.
Is there an exemption for small businesses?
No. GPSR has no small-business exemption and no volume threshold.
When did GPSR start applying?
13 December 2024, across all EU member states, replacing the 2001 General Product Safety Directive.
What happens if I don't comply?
Market withdrawal, fines, and customs problems. In practice most sellers meet enforcement first through a marketplace suspending a listing for missing safety information.
Do I need a lab test for the risk analysis?
Not usually. For most consumer products the risk analysis is a documented reasoning exercise. It may tell you a test is needed — that's rather the point of doing it.
Where this fits
GPSR is one layer of a bigger problem: developing a product with a factory you've never met, in a category you're new to, without getting taken. That's what Private Label from Zero teaches end to end.
Related reading: Do I Need CE Marking to Sell in the EU? · REACH Compliance for Small Importers
This is one module of a much bigger problem
Developing a product with a factory you've never met, in a category you're new to, without getting taken. That's what Private Label from Zero teaches end to end.
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