Still blocked after sending your GPSR details: what keeps a listing down

A filled GPSR field does not by itself bring back a listing that is blocked, deactivated or inactive. The field is one of four items the offer must show, the contact in it must be established in the EU, and a marketplace runs other checks before it lets you sell to EU buyers.

The Digital Services Act asks the statement of reasons for “a reference to the legal ground relied on and explanations as to why the information is considered to be illegal content on that ground”, or “a reference to the contractual ground relied on and explanations as to why the information is considered to be incompatible with that ground” (Art. 17(3)(d)Regulation (EU) 2022/2065, Digital Services ActArticle 17, paragraph 3, point (d)Click opens the article on EUR-Lex., Art. 17(3)(e)Regulation (EU) 2022/2065, Digital Services ActArticle 17, paragraph 3, point (e)Click opens the article on EUR-Lex.). An authority’s order is outside that duty: “This Article shall not apply to any orders referred to in Article 9Regulation (EU) 2022/2065, Digital Services ActThe whole regulationClick opens the law on the EU Publications Office.” (Art. 17(5)Regulation (EU) 2022/2065, Digital Services ActArticle 17, paragraph 5Click opens the article on EUR-Lex.). The marketplace must still tell you it removed the offer (Art. 22(12)(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 12, point (b)Click opens the article on EUR-Lex.).

Why the field is only one of four items

Where you sell online, the offer itself must “clearly and visibly indicate at least” four things (Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex.):

• the name, registered trade name or registered trade mark of 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, with a postal and an electronic address;
• where the manufacturer is not established in the EU, the name, postal and electronic address of the responsible person;
• “information allowing the identification of the product, including a picture of it, its type and any other product identifier”;
• any warning or safety information that goes on the product, its packaging or an accompanying document, “in a language which can be easily understood by consumers, as determined by the Member State in which the product is made available on the market”.

The marketplace has to build a form that takes all four for each product (Art. 22(9)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 9Click opens the article on EUR-Lex.), and it has to make best efforts to assess whether you gave them before it lets you offer the product (Art. 31(3)Regulation (EU) 2022/2065, Digital Services ActArticle 31, paragraph 3Click opens the article on EUR-Lex.). An offer without the picture or the warnings is as incomplete, in law, as one without the contact.

Amazon’s GPSR announcement asks for the same items beyond the contact:

“Ensure each product carries a unique identifier for easy identification. Provide necessary warning and safety information, both physically and in online listings.”

“Resellers: Verify compliance, provide Responsible Person and manufacturer information, display product pictures and safety information.”

eBay ties the way back to all of the required information, and says other reasons can keep a listing hidden:

“Impacted listing(s) will have visibility restored when the required GPSR information is provided, unless there are other reasons the listing is hidden. There shouldn’t be any impact to that listing’s history or search ranking.”

Amazon gives a display time once your details are confirmed: “Responsible Person and manufacturer information, along with relevant images and safety documents, will be displayed on product detail pages within 24 hours of confirmation.”

Why the EU contact has to be in the EU

A product may not be placed on the market “unless there is an economic operator established in the Union” responsible for the market-surveillance tasks for it (Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex., which points to Art. 4(3)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020). A contact in Great Britain, the US or China does not meet that, whatever it is called. An EU 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, or an EU business holding the manufacturer’s written mandate, does. An EU company of your own counts only in one of the roles the law lists: as the manufacturer established in the EU, as the importer, as the holder of a written mandate, or, only where none of those is established in the EU, as a fulfilment service provider for the products it handles (Art. 4(2)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 2Click opens the article on EUR-Lex., which Art. 16(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex. applies). EU authorised representative separates the three names this role goes by.

Amazon puts it the same way in its announcement: “It’s mandatory to have a Responsible Person established within the EU for your non-food products.”

Which checks outside GPSR also block a listing

Your trader details. Before a marketplace lets you offer anything to consumers in the EU, it must hold your name, address, phone number and email, a copy of an identity document, your payment account details, your trade register and number where you are registered, and your self-certification that you offer only products that comply with EU law (Art. 30(1)Regulation (EU) 2022/2065, Digital Services ActArticle 30, paragraph 1Click opens the article on EUR-Lex.). It must make best efforts to assess whether they are reliable and complete (Art. 30(2)Regulation (EU) 2022/2065, Digital Services ActArticle 30, paragraph 2Click opens the article on EUR-Lex.). Where an item looks inaccurate, incomplete or out of date, it asks you to fix it, and if you do not, it must “swiftly suspend” your offers to EU consumers until you do (Art. 30(3)Regulation (EU) 2022/2065, Digital Services ActArticle 30, paragraph 3Click opens the article on EUR-Lex.). What each item is and how the marketplace checks it is on Digital Services Act trader checks.

Your EPR registration numbers. For packaging, a marketplace must obtain your registration in the producer register of the buyer’s EU country, with the number, and your self-certification, before it lets you sell there (Art. 45(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45, paragraph 4Click opens the article on EUR-Lex.). For batteries it must obtain the same: the register, your registration number and your self-certification (Art. 62(6)Regulation (EU) 2023/1542, Batteries RegulationArticle 62, paragraph 6Click opens the article on EUR-Lex.). Textiles and footwear join as each country’s scheme starts, due by 17 April 2028 (Art. 22a(13)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 13Click opens the article on EUR-Lex., Art. 22a(14)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 14Click opens the article on EUR-Lex.). For electrical and electronic equipment, whether a marketplace checks your registration is set by each EU country. EPR for online sellers covers each register.

A trader already selling on a marketplace on 17 February 2024 had 12 months to supply the trader details; where they were not supplied, the marketplace must suspend its service to that trader until they are (Art. 30(2)Regulation (EU) 2022/2065, Digital Services ActArticle 30, paragraph 2Click opens the article on EUR-Lex.). A refusal under Art. 30(1)Regulation (EU) 2022/2065, Digital Services ActArticle 30, paragraph 1Click opens the article on EUR-Lex. or a suspension under Art. 30(3)Regulation (EU) 2022/2065, Digital Services ActArticle 30, paragraph 3Click opens the article on EUR-Lex. carries the right to complain under Article 20Regulation (EU) 2022/2065, Digital Services ActArticle 20Click opens the article on EUR-Lex. and Article 21Regulation (EU) 2022/2065, Digital Services ActArticle 21Click opens the article on EUR-Lex. (Art. 30(4)Regulation (EU) 2022/2065, Digital Services ActArticle 30, paragraph 4Click opens the article on EUR-Lex.).

When an authority is behind the block

An EU country’s market surveillance authority can order a marketplace to remove an offer of a dangerous product, disable access to it or show a warning, and the marketplace must act within two working days of the order (Art. 22(4)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 4Click opens the article on EUR-Lex.). The marketplace must tell the relevant 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 of a decision to remove or disable an offer of a dangerous product (Art. 22(12)(b)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 12, point (b)Click opens the article on EUR-Lex.). Filling the GPSR field does not answer an order about the product’s safety. What follows a safety finding is product recall under GPSR, and where notified products are listed is Safety Gate.

What the marketplace owes you

A business established in the EU also has the platform-to-business rules: a statement of reasons on a durable medium “prior to or at the time of” a restriction or suspension, 30 days’ notice before the whole service is terminated, and a chance to clarify the facts in the marketplace’s complaint process (Art. 4(1)Regulation (EU) 2019/1150, platform-to-business relations (P2B Regulation)Article 4, paragraph 1Click opens the article on EUR-Lex., Art. 4(2)Regulation (EU) 2019/1150, platform-to-business relations (P2B Regulation)Article 4, paragraph 2Click opens the article on EUR-Lex., Art. 4(3)Regulation (EU) 2019/1150, platform-to-business relations (P2B Regulation)Article 4, paragraph 3Click opens the article on EUR-Lex.). The marketplace must also name two or more mediators it is willing to use (Art. 12(1)Regulation (EU) 2019/1150, platform-to-business relations (P2B Regulation)Article 12, paragraph 1Click opens the article on EUR-Lex.).

The statement of reasons is owed only where the marketplace knows your electronic contact details (Art. 17(2)Regulation (EU) 2022/2065, Digital Services ActArticle 17, paragraph 2Click opens the article on EUR-Lex.). The complaint system and the out-of-court body sit in a section that does not bind online platforms that are micro or small enterprises, unless the Commission has designated them very large online platforms (Art. 19Regulation (EU) 2022/2065, Digital Services ActArticle 19Click opens the article on EUR-Lex.); the same exclusion covers the trader-details and compliance-by-design duties (Art. 29Regulation (EU) 2022/2065, Digital Services ActArticle 29Click opens the article on EUR-Lex.). The platform-to-business complaint and mediation duties do not bind a marketplace that is itself a small enterprise (Art. 11(5)Regulation (EU) 2019/1150, platform-to-business relations (P2B Regulation)Article 11, paragraph 5Click opens the article on EUR-Lex., Art. 12(7)Regulation (EU) 2019/1150, platform-to-business relations (P2B Regulation)Article 12, paragraph 7Click opens the article on EUR-Lex.). Regulation (EU) 2022/2065Regulation (EU) 2022/2065, Digital Services ActThe whole regulationClick opens the law on the EU Publications Office. has applied since 17 February 2024 (Art. 93Regulation (EU) 2022/2065, Digital Services ActArticle 93Click opens the article on EUR-Lex.).

What you can skip

What the law leaves open

• Whether the complaint rights reach a seller established outside the EU. The Digital Services Act applies to services offered to recipients “that have their place of establishment or are located in the Union” (Art. 2(1)Regulation (EU) 2022/2065, Digital Services ActArticle 2, paragraph 1Click opens the article on EUR-Lex.), and the platform-to-business rules reach only business users established in the EU (Art. 1(2)Regulation (EU) 2019/1150, platform-to-business relations (P2B Regulation)Article 1, paragraph 2Click opens the article on EUR-Lex.). Neither text says whether a seller outside the EU, selling to consumers inside it, counts as such a recipient. One provision does not depend on it: a trader refused or suspended over its trader details has the right to complain under Article 20Regulation (EU) 2022/2065, Digital Services ActArticle 20Click opens the article on EUR-Lex. and Article 21Regulation (EU) 2022/2065, Digital Services ActArticle 21Click opens the article on EUR-Lex. (Art. 30(4)Regulation (EU) 2022/2065, Digital Services ActArticle 30, paragraph 4Click opens the article on EUR-Lex.). Meanwhile, file the complaint wherever you are established; it costs nothing.
• How fast a complaint is decided. The Digital Services Act asks for handling “in a timely, non-discriminatory, diligent and non-arbitrary manner” and a reasoned decision “without undue delay” (Art. 20(4)Regulation (EU) 2022/2065, Digital Services ActArticle 20, paragraph 4Click opens the article on EUR-Lex., Art. 20(5)Regulation (EU) 2022/2065, Digital Services ActArticle 20, paragraph 5Click opens the article on EUR-Lex.); the platform-to-business rules ask for “a reasonable time frame” (Art. 11(1)Regulation (EU) 2019/1150, platform-to-business relations (P2B Regulation)Article 11, paragraph 1Click opens the article on EUR-Lex.). Neither sets a number of days. The 90-day limit applies only once an out-of-court body has the dispute.