GPSR for online sellers: what the EU General Product Safety Regulation requires
The GPSR covers non-food consumer products sold to people in the EU. It applies to your own online store as much as to Amazon or eBay: if your store targets EU consumers, your products count as placed on the EU market.
Which products the GPSR covers
The General Product Safety Regulation, Regulation (EU) 2023/988, replaced the General Product Safety Directive on 13 December 2024. As a regulation it applies directly in every member state, with no national transposition.
- Consumer products with no specific EU safety legislation (homeware, clothing, jewellery, outdoor gear, most everyday goods): the GPSR applies in full.
- Products with sector legislation (toys, electrical equipment, cosmetics): the GPSR fills the gaps, for example product page information and accident reporting.
- Medicines, food, feed, live plants and animals, and antiques are out of scope.
Why your own store counts
Article 4 says a product offered online is made available on the EU market when the offer targets consumers in the EU. Shipping to EU countries, pages in an EU language and prices in euros are typical signs of targeting.
A Shopify store run from China, the US or the UK with no EU company still has to meet the GPSR for its EU customers. Marketplaces now enforce this at listing time; for your own store nobody checks in advance, but market surveillance authorities and customs can.
The EU responsible person
Article 16 says a product covered by the regulation may only be placed on the market if an economic operator established in the EU carries out the tasks in Article 4 of the Market Surveillance Regulation (2019/1020). That operator can be:
- a manufacturer established in the EU;
- an importer;
- an authorised representative with a written mandate from the manufacturer;
- where none of these exists, a fulfilment service provider established in the EU, for the products it handles.
Sellers shipping directly from outside the EU usually have no EU manufacturer or importer, so they appoint an authorised representative in writing. The responsible person checks the technical documentation and labelling, keeps records, cooperates with authorities and informs them of risks.
Its name, postal address and electronic address must appear on the product, its packaging, the parcel or an accompanying document (Article 16(3)).
What the product and packaging must show
| Information | Article | Where |
|---|---|---|
| Type, batch or serial number, or another identifier | Art. 9(5) | On the product, or on packaging or an accompanying document if it does not fit |
| Manufacturer name or trade mark, postal and electronic address | Art. 9(6) | On the product, or on packaging or an accompanying document |
| EU responsible person name, postal and electronic address | Art. 16(3) | Product, packaging, parcel or accompanying document |
| Instructions and safety information | Art. 9(7) | In a language consumers in the country of sale easily understand |
What every product page must show
Article 19 is the requirement online stores miss most often. A distance-selling offer must clearly show:
- the manufacturer’s name, postal address and electronic address;
- if the manufacturer is outside the EU, the name, postal address and electronic address of the EU responsible person;
- information identifying the product, including a picture, its type and other identifiers;
- warnings and safety information, in a language consumers in that country easily understand.
On Shopify this is usually a “Product safety” block on the product template filled from metafields per product, with warnings translated for each language version of the store.
Risk analysis and technical documentation
Before placing a product on the market, the manufacturer carries out an internal risk analysis and draws up technical documentation, including a general description of the product and its essential safety characteristics (Article 9(2)). The documentation is kept for 10 years (Article 9(3)) and handed to authorities on request. The responsible person checks it periodically.
Accidents and recalls
If a product causes death or serious harm to someone’s health, the manufacturer reports it through the EU Safety Business Gateway without delay (Article 20); when the manufacturer is outside the EU, the responsible person makes sure this happens. If a product is found to be dangerous, corrective action, withdrawal or recall follows immediately, and consumers are informed (Article 9(8)). Recall notices follow Articles 35 and 36.
Penalties and enforcement
Penalties are set by each member state (Article 44). Germany’s revised Product Safety Act (ProdSG), in force since 19 February 2026, allows fines of up to €100,000 for serious breaches and €10,000 for others.
Enforcement is rising. The European Commission reports that Safety Gate, the EU rapid alert system for dangerous products, recorded 4,671 alerts in 2025, 13% more than the year before and a record, and that follow-up actions, including removals from online platforms, rose by 35%.
Checklist for your store
- List the products you sell to EU consumers.
- Appoint an EU authorised representative with a written mandate covering all of them.
- Make sure each product or its packaging carries a type, batch or serial number.
- Add manufacturer and responsible person names, postal and electronic addresses to the product or packaging.
- Translate instructions and safety information into the languages of the countries you sell to.
- Show manufacturer, responsible person, identifiers and warnings on every product page.
- Keep a risk analysis and technical file per product for 10 years.
- Decide who reports accidents in the Safety Business Gateway.
Questions
We already have an EU responsible person for Amazon. Can our own store use the same one?
The responsible person is appointed per product, not per sales channel. If the mandate covers the products you sell on your own store, the same representative generally works; the store’s product pages and labels must show it too. Check the scope of your mandate.
Our products carry the CE mark. Does the GPSR still apply?
Yes, for the parts sector legislation does not cover, such as product page information, the responsible person and accident reporting.
Can our EU fulfilment warehouse act as responsible person?
Only when there is no EU manufacturer, importer or authorised representative, and only for the products it handles. Agree it in writing; most sellers appoint a representative instead.
Is there an exemption for small sellers?
No. The GPSR has no size threshold.
Sources
- EUR-Lex: Regulation (EU) 2023/988 on general product safety (GPSR)
- EUR-Lex: Regulation (EU) 2019/1020 on market surveillance (Art. 4 economic operators)
- European Commission (March 2026): Increased action against dangerous products in the EU in 2025
- Baker McKenzie (March 2026): Germany aligns product safety law with EU GPSR
This article summarises technical requirements and public data. It is not legal advice; for legal obligations and lawsuits, consult a qualified attorney.