To sell consumer products in the European Union, EU GPSR requirements oblige your business to place only safe products on the market, keep technical documentation for ten years, label the product and every online listing with specified information, designate an EU-based responsible person if you manufacture outside the Union, report serious incidents through the Safety Business Gateway, and run any recall using the prescribed notice format and consumer remedies. Regulation (EU) 2023/988 applies uniformly across all member states, so there is no national variation to fall back on.1GOV.UK. EU Regulation 2023/988 on General Product Safety Factsheet
What Products Are Covered
The regulation reaches every non-food consumer product sold in the EU, whether in a physical store, on a marketplace, or by any other form of distance selling. It also captures products not originally designed for consumers but likely to end up in their hands, along with used, repaired, and reconditioned items.2Access2Markets. EU General Product Safety Regulation (GPSR) – A New Era of Consumer Protection
Where a sector-specific EU law already covers a product, the GPSR fills the gaps rather than duplicating it. If those specialist rules regulate some risks but not others, the GPSR governs the leftovers.3International Trade Administration. EU Consumer Goods General Product Safety Regulation
Some categories sit entirely outside the regulation: medicinal products for human or veterinary use; food and animal feed; living plants, animals, and GMOs in contained environments; animal by-products; plant protection products; aircraft and equipment operated directly by transport service providers; antiques, works of art, and collector’s items; and items clearly labelled as requiring repair or reconditioning before use. If your product falls into one of these buckets, the GPSR is not what governs it.
Who Carries the Legal Duty
The regulation splits obligations across four “economic operators”: manufacturers, importers, distributors, and authorized representatives. Enforcement follows the failure, so whichever operator dropped the ball is the one authorities pursue.
Manufacturers carry the most. They must design and produce products that meet the general safety requirement, run an internal risk analysis, prepare technical documentation, and keep production procedures consistent enough that safety does not drift between batches.4EUR-Lex. Regulation (EU) 2023/988 on General Product Safety – Article 9 Importers bringing goods in from outside the EU have to verify the manufacturer has done all of that before distribution starts. Distributors must act with due care and stop supplying anything they know or should suspect is non-compliant. Physical location does not matter; what matters is whether the product reaches an EU consumer.
The Responsible Person for Non-EU Manufacturers
If you manufacture outside the EU, you cannot place a product on the market unless an economic operator established inside the Union is legally responsible for it. Article 16 requires this before a sale can happen at all.5EUR-Lex. Regulation (EU) 2023/988 on General Product Safety – Article 16
The role can be filled by an EU-based manufacturer, an EU importer, an EU authorized representative acting under a written mandate, or, as a last resort, a fulfilment service provider. Whoever takes it on must:
- Regularly verify that the product matches its technical documentation and labelling requirements.
- Keep the technical documentation available for market surveillance authorities for ten years and hand it over on request.
- Cooperate on corrective actions to eliminate risks, and notify national authorities immediately if the product turns out to be dangerous.
The responsible person’s name, postal address, and electronic address must appear on the product, its packaging, the parcel, or an accompanying document. Skipping this step does not just invite a fine; it makes the product illegal to sell in the EU.
What “Safe” Means Under Article 6
A product being safe under the GPSR involves more than working without breaking. Article 6 lists the factors authorities and businesses weigh: the product’s characteristics, packaging, instructions, and appearance, together with which consumers are likely to use it, with particular attention to vulnerable groups such as children and the elderly.6EUR-Lex. Regulation (EU) 2023/988 on General Product Safety – Article 6
Cybersecurity and connectivity now count. If a connected product can be compromised in a way that causes a physical safety hazard, that vulnerability is a product safety issue. Anyone making smart devices, connected toys, or products with software components has to assess whether updates or design changes could introduce new risks over the product’s expected lifespan.
Using Harmonised Standards to Show Compliance
The regulation does not prescribe specific technical solutions. It relies on harmonised standards developed by CEN, CENELEC, and ETSI. Once the European Commission publishes a reference to one of those standards in the Official Journal, any product conforming to it is presumed to meet the general safety requirement.7EUR-Lex. Regulation (EU) 2023/988 on General Product Safety – Article 7
That presumption is the fastest route to compliance. Testing is still needed, but you avoid building a safety case from scratch. If no harmonised standard exists for your product, safety is judged against the Article 6 factors, relevant national standards, Commission recommendations, codes of good practice, the state of knowledge, and what consumers can reasonably expect.
Technical Documentation You Have to Keep
Before a product goes on the market, the manufacturer must run an internal risk analysis and put together technical documentation. At minimum, that means a general description of the product and its essential safety characteristics. When the risk profile calls for more, the file has to identify the specific hazards, the solutions adopted, and the results of any testing.4EUR-Lex. Regulation (EU) 2023/988 on General Product Safety – Article 9
If harmonised standards were used, list them. If they were only partly applied, say which parts and explain how the remaining safety aspects were handled.
The file has to stay current and be produced for market surveillance authorities on request for ten years after the product was placed on the market.8Your Europe. Preparing Technical Documentation That duration does not shrink when a product line is discontinued. Treating documentation as a one-off checklist rather than a living file tends to catch businesses out during enforcement.
Labelling on the Product
Every product placed on the EU market must carry a type, batch, or serial number that is easily visible and legible to consumers. Where the product’s size or nature makes that impractical, the identifier can go on the packaging or an accompanying document.4EUR-Lex. Regulation (EU) 2023/988 on General Product Safety – Article 9
The manufacturer’s name, registered trade name or trademark, and both a postal and an electronic address must also appear on the product, with the same fallback to packaging or a document if space does not allow. Safety instructions and warnings have to be in a language easily understood by consumers in the member state of sale.3International Trade Administration. EU Consumer Goods General Product Safety Regulation
What Every Online Listing Must Show
Article 19 layers additional disclosure duties onto anything sold online or through other distance channels. The point is that an online shopper should see what a shelf shopper would see.9EUR-Lex. Regulation (EU) 2023/988 on General Product Safety – Article 19 Each listing must clearly and visibly show:
- The manufacturer’s name, registered trade name or trademark, and postal and electronic contact details.
- For products manufactured outside the EU, the name and contact details of the EU-established responsible person.
- Product identification, including an image, the type, and any batch or serial numbers.
- Any warnings or safety information required by the GPSR or sector-specific legislation, in a language easily understood by consumers in the member state where the product is sold.
If the required safety information is readable in the product images, it does not have to be repeated in the text. Relying on that carve-out is risky; low-resolution images or small label print can easily fail the “clearly and visibly” test in an enforcement check.
Extra Duties if You Run an Online Marketplace
Article 22 puts direct legal duties on marketplace providers. Platforms have to designate a single contact point for market surveillance authorities and a separate one for consumers on product safety issues, both registered through the Safety Gate portal.10European Commission. Safety Gate – The EU Rapid Alert System for Dangerous Non-Food Products The interface has to be designed so sellers can supply, and the platform can display, all mandatory product information.
When authorities order removal of a dangerous listing, disabling access to it, or display of a warning, the platform has two working days to comply. Product safety notices from other parties must be processed within three working days. Platforms have to suspend traders who repeatedly list non-compliant products, after a prior warning. And when a recall is issued, the platform has to directly notify every affected consumer who bought that product through its interface, where it holds the relevant purchase data.
Reporting Incidents Through the Safety Business Gateway
If a product causes or is likely to cause a serious risk to consumers, economic operators must report it through the Safety Business Gateway, the Commission’s digital portal linking businesses to national market surveillance authorities.11European Commission. Safety Business Gateway The GPSR makes that portal mandatory; other channels do not satisfy the duty.
Reports must be filed “without undue delay” from the moment the operator becomes aware of the problem. There is no fixed hour-count in the regulation, but authorities judge timeliness against when the operator actually learned of the issue. The notification covers a detailed product description, the nature of the hazard, and any corrective actions already taken or planned.
Recall Notices and Consumer Remedies
Article 36 sets a standard format for recall notices. Every written notice has to carry the heading “Product Safety Recall” and include a clear description of the recalled product with images, the specific risk, and the steps consumers should take. Language that plays down the danger, such as “voluntary” or “in rare situations,” is specifically identified as inappropriate because it discourages consumers from acting. Operators have to try to reach affected consumers directly through purchase records or digital accounts, and where that is not possible, use other effective channels.
Article 37 sets the remedies. Consumers must be offered a choice between at least two of the following three:
- Repair of the recalled product.
- Replacement with a safe product of the same type and at least the same value and quality.
- Refund of at least the full price paid.
Every remedy must be free of charge, delivered without significant inconvenience, and completed in a timely manner. Consumers cannot be charged for shipping or returns. For large or non-portable products, the operator has to arrange collection. If repair or replacement is impossible or would cost disproportionately, the operator can limit the offer to one remedy, but consumers keep the right to a refund whenever a repair or replacement is not completed within a reasonable time.
Penalties and Enforcement Reach
There is no single EU-wide fine schedule. Article 44 requires each member state to set its own penalties and make them effective, proportionate, and dissuasive.12EUR-Lex. Regulation (EU) 2023/988 on General Product Safety – Article 44 Member states had to notify the Commission of their rules by 13 December 2024, and actual fines differ significantly depending on which national authority pursues the case.
Money is not the only exposure. Market surveillance authorities can order withdrawals, require recalls, demand corrective measures, and in serious cases order dangerous products destroyed. They can require online platforms to remove listings and access platform interfaces to identify non-compliant products, including by scraping seller pages when sellers obstruct enforcement. A product flagged through the Safety Gate is visible to every market surveillance authority in the EU at once, so a single compliance failure in one member state can quickly turn into a problem across the whole single market.