GPSR for online sellers: what changed since December 2024

The General Product Safety Regulation, Regulation (EU) 2023/988 ("GPSR"), has applied since 13 December 2024, replacing the older General Product Safety Directive. If you sell physical products to consumers in the EU, whether or not your product carries a CE mark, GPSR almost certainly applies to you, and it introduced obligations that specifically target how products are sold online.

Who GPSR covers

GPSR applies to any consumer product placed on the EU market, whether or not it is also covered by sector-specific harmonised legislation like the Low Voltage Directive or RoHS. Where a product is covered by both GPSR and sector legislation, the sector rules take priority for the aspects they specifically regulate, and GPSR fills the gaps, most importantly the general requirement that a product must be safe under normal or reasonably foreseeable conditions of use.

This is the regulation that closes the loop for products with no dedicated EU directive: a candle, a piece of furniture, a textile item, a novelty gadget. None of those need CE marking, but all of them need to meet GPSR's general safety requirement, and its documentation and traceability duties.

The "responsible person" requirement

One of GPSR's most concrete new obligations is Article 16: a product cannot be placed on the EU market unless there is a manufacturer, importer or authorised "responsible person" established in the EU (or Northern Ireland, under its specific arrangements) whose name, contact details and, where applicable, a means of electronic contact appear on the product or its packaging. This mirrors the "authorised representative" concept already used for CE-marked goods, extending an equivalent economic-operator presence requirement to products that previously had no such rule. For a non-EU manufacturer selling directly to EU consumers online, this typically means appointing an EU-based responsible person, whether that is your own EU entity, a distributor, or a dedicated GPSR representative service, before you can legally list the product for EU buyers.

What changed specifically for marketplaces

GPSR places direct obligations on online marketplaces, not just on sellers. Marketplaces have to register a single point of contact for product safety authorities, run internal processes to receive and act on Safety Gate (the EU's rapid alert system for dangerous products) notifications, and implement a version of "Know Your Business Customer" checks: collecting and displaying key trader information (identity, contact details, responsible person, and a product safety statement) before allowing a listing to go live.

In practice, this is why sellers on major EU marketplaces have been asked, since GPSR's application date, to submit more identity, address and responsible-person information than before. It is not a marketplace-specific policy quirk; it is Article 22 of the regulation working as designed.

What GPSR requires the listing itself to show

Beyond the responsible person requirement, GPSR requires certain information to be available to the consumer before purchase where relevant: the manufacturer's identity and contact details, product identification (type, batch or serial), warnings and safety information in a language the consumer can understand, and, since the product is being sold online, that information generally needs to be visible on the listing itself, not just inside the box that arrives after purchase.

What manufacturers must do internally

GPSR's Article 9 places obligations on manufacturers that go beyond the product itself: carrying out an internal risk analysis before placing a product on the market, keeping technical documentation covering the product's characteristics relevant to its safety, maintaining a complaints register, and investigating complaints and any reported incidents involving the product, including keeping distributors informed of the monitoring being carried out. This documentation obligation exists whether or not the product carries CE marking, since it flows from GPSR's own general safety requirement rather than from sector-specific legislation.

Recalls and incident reporting got more specific

GPSR also standardises what a recall notice has to contain (a clear description of the product, the specific risk, a clear call to action, and how consumers can obtain a remedy: repair, replacement, refund) and requires manufacturers, importers and distributors to notify the Safety Business Gateway when they become aware a product they have placed on the market presents a risk incompatible with the general safety requirement. This obligation exists independently of whether an accident has actually occurred yet.

Traceability: batch, serial and identification

GPSR also reinforces a traceability expectation that runs through most product safety law: a product should carry a means of identifying it (type, batch, or serial number, as appropriate) so that if a safety issue is later discovered, the specific units affected can be identified rather than an entire product line being treated as suspect by default. For a small brand shipping limited runs, this is often as simple as printing a batch code on the product or its packaging and keeping records of which batch went to which customers or which sales channel, which also makes any future recall dramatically cheaper and more targeted than a blanket one.

What this means if you are a small online seller

If you are shipping consumer products into the EU from outside it, the practical checklist is: confirm you have a responsible person established in the EU whose details you can put on the product or packaging, make sure your marketplace listings and account information match what Article 22 requires the platform to collect, keep the manufacturer's technical documentation available even for products with no CE requirement, and have a plan for what you would do if a Safety Gate-style report ever named your product. None of this replaces reading Regulation (EU) 2023/988 directly for the specifics that apply to your exact situation, particularly around whether you personally need to be the responsible person or can rely on an existing EU-based partner, distributor or your own subsidiary. For products that also carry CE marking, see our CE marking requirements explainer and check your specific stack with the free requirements checker.