There is no GPSR certificate: what to hand over

Anyone selling you a GPSR certificate is selling you something Regulation (EU) 2023/988Regulation (EU) 2023/988, General Product Safety RegulationThe whole regulationClick opens the law on the EU Publications Office. never asks for.

The page on whether GPSR applies to you settles whether GPSR reaches your product at all, and the Regulation itself is in the GPSR guide.

Why there is no GPSR certificate

Nobody issues one. GPSR’s duties on business are documentation, identification, marking your own details, instructions, complaint handling and corrective action (Art. 9Regulation (EU) 2023/988, General Product Safety RegulationArticle 9Click opens the article on EUR-Lex. to Art. 18Regulation (EU) 2023/988, General Product Safety RegulationArticle 18Click opens the article on EUR-Lex.). None of them is a document an outside body hands you.

The phrase “declaration of conformity” appears nowhere in the Regulation. Third-party certification is mentioned in one place only: Art. 8(1)(d)Regulation (EU) 2023/988, General Product Safety RegulationArticle 8, paragraph 1, point (d)Click opens the article on EUR-Lex. lists “voluntary certification schemes or similar third-party conformity assessment frameworks” among the elements that are taken into account, when available, when someone assesses whether a product is safe and the presumption of Art. 7Regulation (EU) 2023/988, General Product Safety RegulationArticle 7Click opens the article on EUR-Lex. does not apply. That is an input to an assessment, not a requirement, and not a thing you must hold.

So a business selling you a “GPSR certificate” is not selling you a requirement of this Regulation. What it may be selling is a real service under another name - a responsible person, or help writing the file - and both of those are covered below.

Where a declaration of conformity does come from

Where a declaration of conformity is required, it comes from Union harmonisation legislationArt. 3(27)Union legislation listed in Annex I to Regulation (EU) 2019/1020 and any other Union legislation harmonising the conditions for the marketing of products to which that Regulation appliesClick the term for the full definition: the EU’s product-specific laws, defined as the legislation listed in Annex I to Regulation (EU) 2019/1020 and any other Union legislation harmonising the conditions for marketing products to which that Regulation applies (Art. 3(27)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 27Click opens the article on EUR-Lex.). GPSR defines the term and stops there. The duty to draw up a declaration, and the right to put a CE marking on the product, sit in whichever of those laws covers your product, where that law sets them.

Where your product’s own EU law requires a declaration of conformity (toys, low-voltage, radio, machinery, personal protective equipment and others), the declaration and any CE marking come from that law. Some product laws, such as cosmetics, REACH and textile labelling, require none. A harmonised product still falls under parts of GPSR (Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex. offer information, the marketplace and recall rules) and still needs an EU operator where its law is on the list in Art. 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office..

The list is Annex I to Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office., headed “List of Union harmonisation legislation”. It runs from crystal glass (point 1) to packaging (point 75). It holds, among others, toys (Directive 2009/48/ECDirective 2009/48/EC, Toy Safety DirectiveThe whole regulationClick opens the law on the EU Publications Office.), low-voltage electrical equipment (Directive 2014/35/EUDirective 2014/35/EU, Low Voltage Directive (consolidated text of 30 May 2026)The whole regulationClick opens the law on the EU Publications Office.), radio equipment (Directive 2014/53/EUDirective 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)The whole regulationClick opens the law on the EU Publications Office.), cosmetics (Regulation (EC) No 1223/2009Regulation (EC) No 1223/2009, Cosmetic Products RegulationThe whole regulationClick opens the law on the EU Publications Office.), medical devices (Regulation (EU) 2017/745Regulation (EU) 2017/745, Medical Devices Regulation (consolidated text of 19 July 2026)The whole regulationClick opens the law on the EU Publications Office.), REACH, CLP, textile labelling (Regulation (EU) No 1007/2011Regulation (EU) No 1007/2011, Textile Labelling RegulationThe whole regulationClick opens the law on the EU Publications Office.) and packaging (Directive 94/62/EC). Each of those laws sets its own paperwork.

The Official Journal text of 2019 has 70 numbered entries. The consolidated text of 12 August 2026 replaces point 21 with the Batteries Regulation (EU) 2023/1542 and adds point 71 (Regulation (EU) 2024/1252 on critical raw materials) and points 74 and 75 (Directive (EU) 2019/904Directive (EU) 2019/904, Single-Use Plastics DirectiveThe whole regulationClick opens the law on the EU Publications Office. and Regulation (EU) 2025/40Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationThe whole regulationClick opens the law on the EU Publications Office., the PPWR): 73 entries. Two more acts each add a point 72 of their own, which the consolidation does not show yet: the Cyber Resilience Act, Regulation (EU) 2024/2847 (Art. 66Regulation (EU) 2024/2847, Cyber Resilience ActThe whole regulationClick opens the law on the EU Publications Office.), whose own declaration and CE marking for connected products are in Cyber Resilience Act, and the non-road mobile machinery Regulation, Regulation (EU) 2025/14 (Art. 51). Both texts: Official Journal and consolidated. A consolidated text is documentation only and has no legal effect.

What a declaration of conformity contains

Where a product law asks for one, the declaration follows the 8-point model in Annex III of Decision No 768/2008/EC, or the model annexed to that law. The points one by one are on what goes into a declaration of conformity.

What a filled-in declaration looks like

A blank template and a sample filled in for a product under three directives are on the declaration of conformity template. Where your product’s own law sets a different model, that law’s annex wins.

From the Blue Guide: a notified body “verifies and attests that it meets the requirements of the legislative instrument that apply to it by issuing an EU-type examination certificate” (section 5.1.7). “When a conformity assessment body delivers a test report it is in its capacity as a conformity assessment body; only in its capacity as notified body can it deliver EU-type examination certificates” (section 5.2.2). Where a module gives the notified body that task, Annex 4 lists it as: “issues a certificate of conformity”.

When the declaration must travel with the product

Most laws ask you only to show the declaration to an authority on request, while radio equipment, machinery and personal protective equipment, among others, come with it or with its web address. Which laws do, and what a marketplace may ask for, is on who gets a copy of the declaration.

What Great Britain asks: a UK declaration of conformity

For the UKCA route, Great Britain has its own UK declaration of conformity, which “can reference either UK legislation, or recognised EU product regulations” (UK government). What it contains, and the UK government’s template, are on the UKCA declaration of conformity.

The mechanics are short. GPSR applies only where there are no specific provisions with the same objective in Union law regulating the safety of the product concerned (Art. 2(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 1Click opens the article on EUR-Lex.). Where a product is subject to specific requirements imposed by Union harmonisation legislation, Art. 2(1)(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 1, point (b)Click opens the article on EUR-Lex. switches whole parts of GPSR off for it: Chapter IIa, Chapter III Section 1, Chapters V and VII and Chapters IX to XI - that is Art. 8aRegulation (EU) 2023/988, General Product Safety RegulationArticle 8aClick opens the article on EUR-Lex. to Art. 8cRegulation (EU) 2023/988, General Product Safety RegulationArticle 8cClick opens the article on EUR-Lex., Art. 9Regulation (EU) 2023/988, General Product Safety RegulationArticle 9Click opens the article on EUR-Lex. to Art. 18Regulation (EU) 2023/988, General Product Safety RegulationArticle 18Click opens the article on EUR-Lex., Art. 23Regulation (EU) 2023/988, General Product Safety RegulationArticle 23Click opens the article on EUR-Lex. to Art. 24Regulation (EU) 2023/988, General Product Safety RegulationArticle 24Click opens the article on EUR-Lex., Art. 28Regulation (EU) 2023/988, General Product Safety RegulationArticle 28Click opens the article on EUR-Lex. to Art. 32Regulation (EU) 2023/988, General Product Safety RegulationArticle 32Click opens the article on EUR-Lex. and Art. 40Regulation (EU) 2023/988, General Product Safety RegulationArticle 40Click opens the article on EUR-Lex. to Art. 52Regulation (EU) 2023/988, General Product Safety RegulationArticle 52Click opens the article on EUR-Lex. (Chapter IIa, the emergency procedures, was added by Regulation (EU) 2024/2748; consolidated text of 29 May 2026). Chapter II does not apply either, as far as the risks are ones that legislation already covers (Art. 2(1)(a)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 1, point (a)Click opens the article on EUR-Lex.). The split runs per risk. Those same switched-off articles are exactly the ones that reach a product with no law of its own. What still reaches a harmonised product includes Chapter III Section 2 (Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex. to Art. 21Regulation (EU) 2023/988, General Product Safety RegulationArticle 21Click opens the article on EUR-Lex.), the online marketplace rules of Chapter IV (Art. 22Regulation (EU) 2023/988, General Product Safety RegulationArticle 22Click opens the article on EUR-Lex.), the Safety Gate chapter (Art. 25Regulation (EU) 2023/988, General Product Safety RegulationArticle 25Click opens the article on EUR-Lex. to Art. 27Regulation (EU) 2023/988, General Product Safety RegulationArticle 27Click opens the article on EUR-Lex.) and Chapter VIII, recalls included (Art. 33Regulation (EU) 2023/988, General Product Safety RegulationArticle 33Click opens the article on EUR-Lex. to Art. 39Regulation (EU) 2023/988, General Product Safety RegulationArticle 39Click opens the article on EUR-Lex.). The accident, marketplace, consumer-information and recall provisions among them apply as far as that legislation has no specific provisions with the same objective (Art. 2(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 1Click opens the article on EUR-Lex., first subparagraph; recital 8).

Switching off Art. 16Regulation (EU) 2023/988, General Product Safety RegulationArticle 16Click opens the article on EUR-Lex. does not remove the EU contact. For a product under one of the acts listed in Art. 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office., the product “may be placed on the market only if there is an economic operator established in the Union who is responsible for the tasks set out in paragraph 3” (Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex.). That operator is, in this order: an EU manufacturer; the importer, where the manufacturer is outside the EU; an authorised representative with a written mandate; or, only where none of those is in the EU, an EU fulfilment service providerArt. 3(12)any natural or legal person offering, in the course of commercial activity, at least two of the following services: warehousing, packaging, addressing and dispatching, without having ownership of the products involved ...Click the term for the full definition for the products it handles (Art. 4(2)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 2Click opens the article on EUR-Lex.). Its name and contact details, postal address included, go on the product, its packaging, the parcel or an accompanying document (Art. 4(4)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 4Click opens the article on EUR-Lex.). The Official Journal text of Art. 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex. lists 18 acts; the consolidated text of 12 August 2026 adds the Batteries Regulation (EU) 2023/1542Regulation (EU) 2023/1542, Batteries RegulationThe whole regulationClick opens the law on the EU Publications Office. and Regulation (EU) 2024/1252, making 20. A harmonised product outside that list follows its own law. Some laws set their own EU contact outright: medical devices need a sole EU authorised representative (Regulation (EU) 2017/745, Art. 11Regulation (EU) 2017/745, Medical Devices Regulation (consolidated text of 19 July 2026)Article 11Click opens the article on EUR-Lex.), and cosmetics need a responsible person named on the container and packaging (Regulation (EC) No 1223/2009, Arts. 4Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 4Click opens the article on EUR-Lex., 5Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 5Click opens the article on EUR-Lex. and 19(1)(a)Regulation (EC) No 1223/2009, Cosmetic Products RegulationArticle 19, paragraph 1, point (a)Click opens the article on EUR-Lex.); what a cosmetic needs step by step is in EU Cosmetics Regulation.

Why standards are the nearest thing to a proof

GPSR gives one way to be presumed safe rather than argue it. A product is presumed to be in conformity with the general safety requirement of Art. 5Regulation (EU) 2023/988, General Product Safety RegulationArticle 5Click opens the article on EUR-Lex. where it conforms to relevant European standards, or parts of them, for the risks those standards cover, and the references of those standards have been published in the Official Journal (Art. 7(1)(a)Regulation (EU) 2023/988, General Product Safety RegulationArticle 7, paragraph 1, point (a)Click opens the article on EUR-Lex.). Where there is no such European standard, the product is presumed in conformity where it meets the national health and safety requirements of the EU country it is made available in, provided that law complies with Union law (Art. 7(1)(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 7, paragraph 1, point (b)Click opens the article on EUR-Lex.).

That presumption is not a certificate. Nobody signs it and nobody issues it: you claim it by conforming to the standard and recording which one in your file (Art. 9(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 2Click opens the article on EUR-Lex., second subparagraph, point (b)).

It is not final either. A market surveillance authority may still act where there is evidence the product is dangerous despite the presumption (Art. 7(3)Regulation (EU) 2023/988, General Product Safety RegulationArticle 7, paragraph 3Click opens the article on EUR-Lex.).

What the document actually is

The file GPSR does require is your own. Before placing a product on the market, a manufacturerArt. 3(8)any natural or legal person who manufactures a product or has a product designed or manufactured, and markets that product under that person’s name or trademarkClick the term for the full definition carries out an internal risk analysis and draws up technical documentation containing at least a general description of the product and the essential characteristics relevant for assessing its safety (Art. 9(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 2Click opens the article on EUR-Lex.). Where the risks make it appropriate, that documentation also contains the analysis of possible risks and the solutions adopted, any test reports, and the list of European standards or other elements applied (Art. 9(2)(a)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 2, point (a)Click opens the article on EUR-Lex. and (b)). It is kept up to date, held at the disposal of market surveillance authorities for 10 years after the product was placed on the market, and handed over on request (Art. 9(3)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 3Click opens the article on EUR-Lex.). An importerArt. 3(10)any natural or legal person established within the Union who places a product from a third country on the Union marketClick the term for the full definition keeps a copy available for the same 10 years (Art. 11(6)Regulation (EU) 2023/988, General Product Safety RegulationArticle 11, paragraph 6Click opens the article on EUR-Lex.). Nobody validates it in advance. What it must contain, how the risk assessment is written and who keeps it is GPSR technical documentation.

The second thing behind the ask is a person, not a paper. A product covered by GPSR may not be placed on the market unless an economic operatorArt. 3(13)the manufacturer, the authorised representative, the importer, the distributor, the fulfilment service provider or any other natural or legal person who is subject to obligations in relation to the manufacture of products or making them available on the market ...Click the term for the full definition based in the EU is responsible for the tasks in Art. 4(3)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020 for that product (Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex.). That operator regularly checks that the product matches the technical documentation and carries the required identification, contact details and instructions (Art. 16(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 2Click opens the article on EUR-Lex.), and its name and postal and electronic address go on the product, its packaging, the parcel or an accompanying document (Art. 16(3)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex.). Who may hold that role, and what it costs, is the EU Responsible Person.

What a marketplace means when it asks

None of the three big marketplaces asks for a certificate. Each asks for contact details and listing information, in its own words, and each uses a different name for the same slot. The three passages below are their wording as it stood on 6 October 2026: marketplace policy, not law, and it changes without notice.

eBay’s Seller Center lists what a business listing must carry: “The product manufacturer’s name and contact information[;] If the manufacturer isn’t located in the EU or NI, you’ll have to indicate an EU-based Responsible Person or entity, along with their name and contact details[;] Any relevant product information like model number, pictures, and type[;] Product safety and compliance information like warnings and safety information (which can be included in labels and product manuals) in the local language[;] The CE marking when required by the related regulations applicable to your product.” Even eBay ties the CE marking to “the related regulations applicable to your product”, not to GPSR.

Etsy asks you to “Add an Economic Operator to your account and/or update the Manufacturers field in your listing forms” and to “Add applicable information to the Product safety info field in your listing forms.”

Amazon’s public GPSR announcement, posted by a staff account in its Seller Forums, says: “Responsible Person: It’s mandatory to have a Responsible Person established within the EU for your non-food products. Make sure to label your products with their contact information in one of the EU’s official languages.” Amazon shows its own GPSR help article only to signed-in sellers; the announcement is its public statement.

That list is Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex. almost line for line. A distance offer has to indicate clearly and visibly the manufacturer’s name and postal and electronic address, the responsible person’s name and address where the manufacturer is outside the EU, information identifying the product including a picture of it, and any warning or safety information, in a language easily understood by consumers in the EU country where it is made available (Art. 19(a)Regulation (EU) 2023/988, General Product Safety RegulationArticle 19, point (a)Click opens the article on EUR-Lex. to (d)). The Regulation makes the marketplace build the fields (Art. 22(9)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 9Click opens the article on EUR-Lex.); filling them is yours.

One thing a marketplace does collect sounds like a certificate and is not one. Its internal processes must let traders provide “their self-certification committing to offer only products that comply with this Regulation”, under Art. 30(1)Regulation (EU) 2022/2065, Digital Services ActArticle 30, paragraph 1Click opens the article on EUR-Lex. of Regulation (EU) 2022/2065 (Art. 22(10)(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 10, point (b)Click opens the article on EUR-Lex.). That is a tick-box promise you make about yourself, not a document anybody issues to you. What each marketplace asks for, field by field, is GPSR marketplace requirements.

What happens if you go looking for a certificate instead

The risk here is not a fine for lacking a document that does not exist. It is time and money spent on the wrong thing while the real gap stays open, and the listing stays down.

The consequence arrives from the channel first. eBay’s Seller Center GPSR page says that if you do not comply “your listings may not be visible or purchasable to buyers in the EU and Northern Ireland”, with visibility restored once the required information is provided. Amazon’s announcement says “Non-compliant listings risk removal and ineligibility for flash sales.” Etsy’s Help Center states no penalty for an empty field, and it offers an exit: “You can opt out of selling your products to GPSR countries.” Etsy’s Seller Handbook says that where an authority notifies it that a product is non-compliant, it will take appropriate action, “which may include removing your listing and/or suspending your account”.

Beyond the channel, penalties are laid down by each EU country, which must make them effective, proportionate and dissuasive; the Regulation sets no figure of its own (Art. 44Regulation (EU) 2023/988, General Product Safety RegulationArticle 44Click opens the article on EUR-Lex.). What each country actually sets is GPSR fines.

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