The EU General Product Safety Regulation (GPSR), Regulation (EU) 2023/988, has applied since 13 December 2024. It replaced the older General Product Safety Directive and significantly tightened obligations for consumer products sold into Europe — especially for non-EU sellers on marketplaces and direct-to-consumer websites. If you source from China and sell into the EU, GPSR is now a baseline compliance requirement, not a nice-to-have. This guide explains what it covers, the EU responsible person requirement, the documentation, and the practical checklist for your products.
What GPSR Applies To
GPSR covers almost all consumer products placed on the EU market for non-professional use. It applies to products that are not already covered by specific EU harmonized legislation — but in practice, it fills gaps even for regulated products. Products already covered by sectoral EU law — medical devices, vehicles, cosmetics, food, chemicals under REACH — follow their own rules, but GPSR still sets the general safety net for consumer goods.
If your product is a physical consumer item sold to end users in the EU — toys, home goods, electronics, textiles, furniture, sports equipment — GPSR is in scope.
The EU Responsible Person Requirement
This is the headline change. For every product covered by GPSR, there must be an established responsible economic operator inside the EU before the product can be placed on the market. In priority order, that person is:
- the manufacturer, if established in the EU;
- an authorised representative written-mandated by the manufacturer;
- the importer, if the manufacturer is non-EU and no representative exists;
- a fulfilment service provider, if none of the above is established in the EU.
For a China-based manufacturer selling to EU customers through a website or marketplace, the practical solution is to appoint an EU authorised representative or to use an authorised fulfilment service provider. The responsible person’s name and address must appear on the product, its packaging, or accompanying documents. Without this information, market-surveillance authorities can require the product to be withdrawn.
Manufacturer Obligations Under GPSR
- Safe by design: conduct a risk assessment and ensure the product meets general safety standards.
- Technical documentation: keep a file describing the product, its hazards, test results, and compliance route, available to authorities on request.
- Traceability marking: the product must carry the manufacturer’s name and address, a serial or batch number, and the responsible person’s contact details.
- Incident and recall handling: report serious incidents to authorities, and organize recalls when a product is unsafe.
- English or local-language instructions and safety information where applicable.
Relationship to CE Marking
CE marking is the sign that a product follows a specific EU directive — for example, the Toy Safety Directive, EMC, or LVD. GPSR is not a CE directive; it is a horizontal safety regulation. A product may carry CE under its sector directive and still need to satisfy GPSR’s responsible-person, traceability, and documentation rules. Do not treat CE compliance as a GPSR substitute.
Practical Checklist for China Importers
- Confirm whether your product is in scope and whether it already has sectoral EU legislation.
- Appoint an EU responsible person (authorised rep or fulfilment provider) and record their details.
- Ensure the product and packaging carry manufacturer identity, batch number, and the EU responsible person address.
- Assemble a technical file: risk assessment, applicable standards, test reports from an accredited lab.
- Set up a process to report incidents and recalls, and monitor market-surveillance alerts.
- Ask your Chinese supplier to support these markings and documentation; most export factories know the requirements but need you to specify them.
GPSR enforcement has increased since the end of 2024, and marketplace platforms now require sellers to upload the responsible-person details before listings go live. Treat it as a launch prerequisite.
Marketplace Enforcement and Timeline
Since GPSR took effect, major EU marketplaces — including Amazon’s EU stores — require sellers to provide the responsible-person details before listings remain active. Listings without valid EU responsible-person information are being delisted. If you already sell into Europe, check whether your listings show the required contact; if not, appoint a representative now rather than after a takedown.
GPSR also strengthens market-surveillance cooperation across member states. A product recalled in one country can trigger alerts in the Rapid Exchange of Information system, and non-compliant products are being removed from warehouses and marketplaces EU-wide. For China-based sellers, the practical move is to treat GPSR as part of the product launch checklist alongside CE and RoHS. Ask your factory for the technical file, test reports, and batch marking; without those, neither you nor your EU representative can defend the product if an authority asks.
Also remember that GPSR requires instructions in the language of the destination country, not just English. Product labels, safety warnings, and user manuals must be translated into each EU language where the product is sold. Plan for that translation cost at launch, not after a market-surveillance notice. For online sellers, GPSR also requires that product pages show the responsible person’s identity and contact details.