GPSR: what it requires if you sell into the EU from outside it

Most GPSR guides explain what the General Product Safety Regulation is - see our GPSR overview for that part. That is the easy half. The half that decides what you actually do on Monday is whether it reaches you, and which parts of it do not. This page answers that first and explains second.

Every claim below carries the article it comes from, taken from the published text of Regulation (EU) 2023/988. Where we have not verified something, it is marked as unverified instead of being smoothed over.

Does GPSR apply to you?

The sections below answer it, starting with the first question: whether your sales target the EU.

What GPSR is, in one paragraph

Regulation (EU) 2023/988 is the EU’s general safety net for consumer products. It has applied since 13 December 2024 (Art. 52). Its core command is one sentence: economic operators shall place or make available on the market only safe products (Art. 5). Everything else in the Regulation is machinery hung off that sentence - who must document what, whose name goes on the box, who tells the authorities when someone gets hurt.

It is a general net, which is the detail most guides skip. GPSR applies to a product only insofar as no other Union law regulates the same safety aspect. Where a product is subject to specific safety requirements under Union law, GPSR applies only to the risks and categories of risk those requirements do not cover (Art. 2(1)).

The first question is targeting, not shipping

An online offer counts as making a product available on the EU market if the offer is targeted at consumers in the Union. An offer is treated as targeted if the economic operator directs its activities, by any means, to one or more Member States (Art. 4).

That is the trigger. Not where your warehouse is, not where your company is registered, not whether you personally ship the parcel. If you direct your selling activity at an EU country, your products are on the EU market for the purposes of this Regulation.

You are not the importer

This is the single most useful thing a business outside the EU can learn about GPSR, and almost every vendor guide blurs it, because blurring it sells more services.

An importer is defined as a person established within the Union who places a product from a third country on the Union market (Art. 3(10)). If you are not established in the EU, you cannot be the importer. The importer duties in Art. 11 are not yours. They belong to whoever in the EU places your product on the market - your EU distributor, your EU subsidiary, or in a direct-to-consumer sale, potentially nobody in that role at all.

What you may well be instead is the manufacturer. The definition is wider than it looks: a manufacturer is any person who manufactures a product, or has a product designed or manufactured, and markets that product under that person’s name or trademark (Art. 3(8)). And Art. 13(1) makes it explicit - anyone who places a product on the market under their own name or trademark is deemed a manufacturer and carries the Art. 9 obligations.

So the private-label business sourcing from a factory and selling under its own brand is the manufacturer, not the importer. Getting this the wrong way round sends people shopping for the wrong service.

The three duties that actually bite

1. An EU-established responsible person must exist

A product covered by GPSR 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) of Regulation (EU) 2019/1020 in respect of that product (Art. 16(1)).

Their name, registered trade name or trademark, and contact details including postal and electronic address must be indicated on the product, its packaging, the parcel or an accompanying document (Art. 16(3)).

That operator also has to check, regularly and where appropriate to the risk, that the product matches its technical documentation and complies with Art. 9(5), (6) and (7), and must give market surveillance authorities documented evidence of those checks on request (Art. 16(2)).

2. Your offer page must carry four things

Where products are made available online or through other distance sales, the offer must clearly and visibly indicate at least (Art. 19):

the manufacturer’s name, registered trade name or trademark, and postal and electronic address;
where the manufacturer is not established in the Union, the name, postal and electronic address of the responsible person;
information allowing identification of the product, including a picture of it, its type and any other identifier;
any warning or safety information that has to be affixed to the product, its packaging or an accompanying document, in a language easily understood by consumers as determined by the Member State where the product is made available.

Point 4 is the one that costs money, because “a language easily understood by consumers, as determined by the Member State” is decided per country, not per business.

3. Accidents must be notified

Where a product placed or made available on the market causes an accident, the manufacturer must ensure it is notified through the Safety Business Gateway to the competent authorities of the Member State where the accident occurred, without undue delay from the moment it knows (Art. 20(1)).

Art. 20(2) is the trigger for notification, not a definition - narrow and serious: occurrences associated with the use of a product that resulted in a person’s death, or in serious adverse effects on health and safety, permanent or temporary, including injuries, other damage to the body, illnesses and chronic health effects (Art. 20(2)).

Where the manufacturer is not established in the Union, the responsible person who has knowledge of an accident must ensure the notification is made (Art. 20(4)).

Who owes what

Duties by role under Regulation (EU) 2023/988. A business outside the EU usually sits in the last row - and often in the first.
Role	What it must do	Source
Manufacturer	Design to the general safety requirement; internal risk analysis and technical documentation kept 10 years; product identifier; name and postal and electronic address on the product; instructions and safety information; corrective action and authority notification for dangerous products; a public complaints channel and an internal complaints register.	Art. 9
Anyone selling under own brand	Deemed to be the manufacturer and subject to all of Art. 9. The same applies to anyone who substantially modifies a product - for the part of the product affected by the modification, or for the entire product if the modification has an impact on its safety.	Art. 13(1)-(2)
Importer (EU-established only)	Before placing on the market, verify the product meets the general safety requirement and that the manufacturer met Art. 9(2), (5) and (6); do not place a non-conforming product; put own name and postal and electronic address on the product; ensure instructions and safety information are present.	Art. 11
Distributor	Before making available, verify the manufacturer and where applicable the importer complied with the labelling and instruction requirements; protect conformity during storage and transport; do not make available where there is reason to believe the product is non-conforming.	Art. 12
Online marketplace	Single contact points for authorities and for consumers; registration on the Safety Gate Portal; act on takedown orders within two working days; process product safety notices within three working days; provide interface fields so traders can supply the Art. 19 information; suspend repeat offenders after a warning.	Art. 22
Non-EU business targeting EU consumers	Ensure an EU-established responsible person exists and is named on the product or packaging; carry the full Art. 19 information in every offer; ensure accident notification happens via the responsible person. Plus all of Art. 9 where you sell under your own brand.	Art. 16, 19, 20(4)

Scroll the table sideways to see the source column.

What you can skip

You can skip this

If your product is covered by sector-specific EU law, most of GPSR does not apply to it - and the carve-out is bigger than one chapter. Art. 2(1) applies “with regard to products subject to specific requirements imposed by Union harmonisation legislation,” and splits the carve-out in two. Art. 2(1)(a): Chapter II - the general safety requirement, Articles 5 to 8 - does not apply insofar as the risks or categories of risks covered by the sector law are concerned. Art. 2(1)(b): four more chapters do not apply at all - Chapter III, Section 1 (Articles 9 to 18: the manufacturer, importer, distributor, own-brand and market-surveillance-cooperation duties), Chapter V (Articles 23 to 24: market surveillance and implementation), Chapter VII (Articles 28 to 32: the Commission’s role and enforcement coordination), and Chapters IX to XI (Articles 40 to 52: international cooperation, financial provisions and final provisions). Chapter XI is where the penalties duty at Art. 44 and the transitional rule at Art. 51 live, so a sector-regulated reader may be carved out of those two as well - see the Penalties section below. Sector-specific EU law can displace GPSR for the aspects it covers - check your own product type before you assume GPSR is the whole answer. So do not build a GPSR technical file under Art. 9 for a toy, and do not appoint a GPSR Art. 16 responsible person for one. Comply under the sector law instead, which has its own equivalents. This is not a free pass - it is a redirect, and it saves you paying twice for the same job.

Three more things you genuinely do not have to do:

And two exclusions worth checking before you do any work at all: food and medicinal products for human or veterinary use are outside GPSR entirely, as are feed, living plants and animals, plant protection products, certain aircraft, and antiques (Art. 2(2)).

Second-hand, used and refurbished

There is one narrow exit in the same paragraph, and its conditions matter. GPSR does not apply to products to be repaired or reconditioned prior to being used, where those products are placed or made available on the market and are clearly marked as such (Art. 2(3)). Both halves are required: the product must genuinely be sold for repair or reconditioning before use, and it must be clearly marked that way. Separately, antiques are excluded outright (Art. 2(2)(i)).

Penalties: what the text actually says

If your product is carved out under Art. 2(1)(b) (see “What you can skip” above), this whole section may not apply to you: Chapter XI, which holds both Art. 44 and Art. 51, is one of the chapters that carve-out switches off.

The Regulation sets no fine amounts. It requires Member States to lay down the rules on penalties for infringements and to take the measures needed to implement them, and requires those penalties to be effective, proportionate and dissuasive (Art. 44(1)-(2)). Member States had to notify the Commission of those rules by 13 December 2024 (Art. 44(3)).

There is also a transitional rule worth knowing: Member States may not impede the making available on the market of products that complied with the old Directive 2001/95/EC and were placed on the market before 13 December 2024 (Art. 51). Stock already placed on the market before that date is not retroactively unlawful.

What we have not verified

Stated plainly, so you know the edges of this page:

Whether you are a “producer” under EPR. Extended producer responsibility for packaging, electricals and batteries, and the national registrations that come with it, sit in different instruments from GPSR. We have not read them for this page, and the answer varies by Member State. Nothing here tells you whether you must register.
Which sector-specific Union regimes apply to which product categories. Art. 3(27) defines Union harmonisation legislation by reference to an Annex that is not in the text we read, so we cannot say which regime covers which product.
How Art. 9 applies to plain resale of second-hand goods, as set out in the section above.
National penalty figures, for the reason given above.
What any individual marketplace requires of you contractually. Art. 22 sets the floor for what a marketplace must do; a marketplace can and does ask the businesses on it for more than the Regulation requires, and that is a contract question, not a GPSR question.

Who can do this for you

Nobody is listed here yet.When this page lists providers, it will say exactly which job each one does.We would rather show an empty box than fill it with names we have not checked.

Disclosure, in advance. When providers are listed here, each entry will show whether we earn from it. Any entry that has paid for its placement will be labelled as paid placement in the entry itself - not in a footnote, and not on another page. Listings will never change what the guide above says you do or do not have to do.