Does GPSR apply to me? The answer, and the three duties that follow

Your targeting is the trigger: not where your warehouse sits, not where your company is registered, not who hands the parcel to the courier. An offer targeted at consumers in an EU country is making a product availableArt. 3(6)any supply of a product for distribution, consumption or use on the Union market in the course of a commercial activity, whether in return for payment or free of chargeClick the term for the full definition on the EU market (Art. 4Regulation (EU) 2023/988, General Product Safety RegulationArticle 4Click opens the article on EUR-Lex.).

What the Regulation puts on each role once it reaches you - manufacturer, importer, distributor, marketplace - is set out in GPSR: what it is, and who it reaches.

You are almost certainly not the 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. An importer has to be based in the EU (Art. 3(10)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 10Click opens the article on EUR-Lex.), so those duties belong to somebody else. If you sell under your own name or trademark you are the 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 instead, and you carry the Art. 9Regulation (EU) 2023/988, General Product Safety RegulationArticle 9Click opens the article on EUR-Lex. obligations (Art. 3(8)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 8Click opens the article on EUR-Lex., Art. 13(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 13, paragraph 1Click opens the article on EUR-Lex.). Getting that pair the wrong way round is how businesses end up buying the wrong service.

Two things can take the Regulation back off your product before you do any work at all. EU product law of the kind the EU calls Union harmonisation legislation, such as the toy, electrical or cosmetics law, switches most of GPSR off for the products it covers (Art. 2(1)(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 1, point (b)Click opens the article on EUR-Lex., Art. 3(27)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 27Click opens the article on EUR-Lex.); any other EU law with safety rules for your product takes over only the risks it covers (Art. 2(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 1Click opens the article on EUR-Lex., first and second subparagraphs). And food, medicines and antiquesArt. 3(28)products, such as collectors’ items or works of art, in relation to which consumers cannot reasonably expect that they fulfil state-of-the-art safety standardsClick the term for the full definition sit outside GPSR altogether (Art. 2(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 2Click opens the article on EUR-Lex.).

Whatever survives those two tests has bound you since 13 December 2024 (Art. 52Regulation (EU) 2023/988, General Product Safety RegulationArticle 52Click opens the article on EUR-Lex.), and it comes down to three duties: an EU-established responsible person must exist (Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex.), every offer must carry four specific items (Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex.), and accidents must be notified (Art. 20Regulation (EU) 2023/988, General Product Safety RegulationArticle 20Click opens the article on EUR-Lex.). For a toy, an electrical product or another product whose own EU law is on the Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. list, the first of the three comes from that Regulation instead of GPSR (Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex., Art. 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex.); the EU Responsible Person says which rule covers yours.

Where GPSR applies: the EU and Northern Ireland

GPSR covers sales to consumers in the 27 EU countries and in Northern Ireland. A UK, Swiss, Norwegian, Icelandic or Liechtenstein address changes nothing: an offer aimed at EU consumers is inside GPSR wherever you are based (Art. 4Regulation (EU) 2023/988, General Product Safety RegulationArticle 4Click opens the article on EUR-Lex.).

Which three duties actually bite

Once GPSR reaches your product, these three are where the real work is.

An EU responsible person must exist

A product covered by GPSR, in the law’s own words, “shall not be placed on the market unless there is an economic operator established in the Union” who is responsible for the tasks set out in Art. 4(3)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3Click 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. for that product (Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex.).

Its name, registered trade name or trademark, and contact details including the postal and electronic address go on the product, its packaging, the parcel or a paper that travels with it (Art. 16(3)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex.).

You cannot hold that role yourself from outside the EU: it is a closed list of four EU-based operators. Who qualifies, what they owe and what really drives the price is in the EU Responsible Person.

For a product with its own EU law, Art. 16Regulation (EU) 2023/988, General Product Safety RegulationArticle 16Click opens the article on EUR-Lex. does not apply (Art. 2(1)(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 1, point (b)Click opens the article on EUR-Lex.). Where that 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., such as toys, electrical and radio equipment, machinery and protective equipment, that Regulation asks for the same EU company (Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex.), and its name and postal address go on the product the same way (Art. 4(4)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 4Click opens the article on EUR-Lex.).

Your offer page must carry four things

Where products are offered online or at distance, the offer has to show clearly and visibly at least this much (Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex.):

1. the manufacturer’s name, registered trade name or trademark, and postal and electronic address;
2. where the manufacturer is not based in the EU, the name, postal and electronic address of the responsible person;
3. information that identifies the product, including a picture of it, its type and any other identifier;
4. any warning or safety information that has to be affixed to the product, its packaging or an accompanying document, in “a language which can be easily understood by consumers, as determined by the Member State” where the product is made available.

Accidents must be notified

Where a product placed or made available on the market causes an accident, the manufacturer has to see that it is notified through the Safety Business Gateway to the competent authorities of the EU country where the accident happened, without undue delay from the moment it knows (Art. 20(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 20, paragraph 1Click opens the article on EUR-Lex.).

Where the manufacturer is not based in the EU, the responsible person who learns of an accident has to see that the notification is made (Art. 20(4)Regulation (EU) 2023/988, General Product Safety RegulationArticle 20, paragraph 4Click opens the article on EUR-Lex.).

Why GPSR has no size threshold

GPSR applies from the first product you supply as a business. It sets no minimum size, turnover or number of sales: the test is any supply “in the course of a commercial activity, whether in return for payment or free of charge” (Art. 3(6)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 6Click opens the article on EUR-Lex.). A private person selling their own things is not supplying in the course of a commercial activity.

A “gift” label does not take a business sale out of GPSR

There is no gift route. GPSR asks whether you supply the product in the course of a commercial activity, and the label on the order, the parcel or the customs form does not enter into it (Art. 3(6)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 6Click opens the article on EUR-Lex.). A buyer who orders your product to give to somebody else is still a consumer buying from you (Art. 3(17)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 17Click opens the article on EUR-Lex.). A free item a business sends is covered too: making available is a supply “in the course of a commercial activity, whether in return for payment or free of charge” (Art. 3(6)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 6Click opens the article on EUR-Lex.).

What stays outside is a private person giving their own things to a friend. That is no commercial activity.

When a business-only product falls outside GPSR

GPSR covers products meant for consumers, and also products “likely, under reasonably foreseeable conditions, to be used by consumers even if not intended for them” (Art. 3(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 1Click opens the article on EUR-Lex.). A product sold only to businesses, and not likely to reach consumers, is outside. Selling to a business that resells to consumers does not help: the product still reaches them.

GPSR and digital products: the Regulation has no exclusion for them

GPSR has no exclusion for digital products. Its definition of productArt. 3(1)any item, whether or not it is interconnected to other items, supplied or made available, whether for consideration or not, including in the context of providing a service, which is intended for consumers ...Click the term for the full definition is “any item” (Art. 3(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 1Click opens the article on EUR-Lex.), and the Commission reads that as “tangible or non-tangible”, naming apps and software (C/2025/6233, section 2.1). Neither the Regulation nor the guidelines name an ebook, a printable or a course, so none of the three is ruled in or out by name.

What the text settles:

• A physical medium is a physical item. A USB stick, DVD or memory card carrying a file is a product like any other (Art. 3(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 1Click opens the article on EUR-Lex.). The recitals treat it that way: in a recall of “the tangible medium for digital content”, the refund covers “all sums paid by the consumer under the contract” (recital 91).
• Anything you ship with a digital product is a physical product. A printed workbook or a kit that comes with a course is covered on its own terms.
• Services are outside, products supplied with a service are inside. “Services should not be covered by this Regulation”, but products supplied to consumers in the context of providing a service fall within it (Art. 3(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 1Click opens the article on EUR-Lex.; recital 17; C/2025/6233, section 2.3).

What it leaves open: whether content with no physical carrier, such as an ebook, a printable or a recorded course, is a product in the same way as an app or software. The words “any item” and the Commission’s reading point to yes. The guidelines cover non-tangible apps and software. No provision, recital or guideline says whether content is a product in the same way. The Regulation does not define a service either, so it does not say whether a recorded course is one. If such content is a product, the duties in this guide are written for it as they stand, with no lighter version for digital goods: an EU-established responsible person (Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex.), the four items on the offer (Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex.), accident notification (Art. 20Regulation (EU) 2023/988, General Product Safety RegulationArticle 20Click opens the article on EUR-Lex.).

Why handmade and dropshipped products are inside GPSR

GPSR has no rule for handmade or dropshipped goods. The nine exclusions are a closed list, and neither is on it (Art. 2(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 2Click opens the article on EUR-Lex.).

• Handmade. You made it and sell it under your name, so you are the manufacturer. Why handmade is no exemption: GPSR exemptions.
• Dropshipping. The offer decides it. If your offer targets EU consumers, the product is on the EU market (Art. 4Regulation (EU) 2023/988, General Product Safety RegulationArticle 4Click opens the article on EUR-Lex.). If the goods carry your name or brand, you are the manufacturer (Art. 13(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 13, paragraph 1Click opens the article on EUR-Lex.). An EU-established operator must still exist for each product (Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex.). For a product with its own EU law, such as a toy or an electrical product, that rule comes from Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. or from the product’s own law instead (Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex., Art. 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex.). A supplier shipping from outside the EU does not remove it.

GPSR for art prints, handmade and made-to-order goods: you are the manufacturer

A print, a handmade item and a made-to-order item are all products, and selling them under your own name makes you the 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, whether you make the item, have it printed or have it made (Art. 3(8)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 8Click opens the article on EUR-Lex., Art. 13(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 13, paragraph 1Click opens the article on EUR-Lex.). GPSR has no category for made to order or one-off goods: the exclusions are a closed list (Art. 2(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 2Click opens the article on EUR-Lex.), and GPSR exemptions shows why handmade is not on it.

Three things sellers of prints ask:

• Do I need a “paper cut” warning in every language? The Regulation names no warning for prints or for any ordinary product. The offer has to carry only a warning or safety information that the Regulation or the product’s own EU law requires to be affixed (Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex., point (d)). The manufacturer must supply instructions and safety information, except where the product can be used safely and as the manufacturer intended without them (Art. 9(7)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 7Click opens the article on EUR-Lex.). Whether a print needs a warning is a safety judgement the manufacturer makes; warnings are one of the aspects the Regulation lists for that judgement (Art. 6(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 6, paragraph 1Click opens the article on EUR-Lex., point (d)). Where a warning is needed, it goes in a language consumers easily understand, as set by each EU country where the print is sold (Art. 9(7)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 7Click opens the article on EUR-Lex.).
• How is a one-off identified? The product must bear a type, batch or serial number “or other element enabling the identification of the product”. Where its size or nature does not allow that, the information goes on the packaging or in a document that comes with it (Art. 9(5)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 5Click opens the article on EUR-Lex.).
• How much paperwork does a print need? You always carry out an internal risk analysis before placing the print on the market, and the technical documentation always holds a general description of the product and its essential characteristics relevant to its safety. Writing the analysis of possible risks and the solutions adopted into that documentation is required “where appropriate with regard to possible risks related to the product” (Art. 9(2)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 2Click opens the article on EUR-Lex.). It is kept for 10 years (Art. 9(3)Regulation (EU) 2023/988, General Product Safety RegulationArticle 9, paragraph 3Click opens the article on EUR-Lex.). The full manufacturer list is in what GPSR requires of you, by role.

Goods made or listed before 13 December 2024 are judged by when they were placed on the market

Making a product before 13 December 2024 does not exempt it, and neither does the listing date as such: Art. 51Regulation (EU) 2023/988, General Product Safety RegulationArticle 51Click opens the article on EUR-Lex. turns on when the product was placed on the market. What Art. 51Regulation (EU) 2023/988, General Product Safety RegulationArticle 51Click opens the article on EUR-Lex. protects is a product that was placed on the marketArt. 3(7)the first making available of a product on the Union marketClick the term for the full definition before that date and conforms to Directive 2001/95/EC: EU countries may not impede it. Placing on the market is the first making available on the Union market (Art. 3(7)Regulation (EU) 2023/988, General Product Safety RegulationArticle 3, point 7Click opens the article on EUR-Lex.), and the Commission counts it for “every specific unit of the product” (C/2025/6233, section 2.1).