EU GPSR

The GPSR requires businesses to ensure that only safe products are made available to consumers. Compliance may involve product risk analysis, technical documentation, traceability information, consumer warnings, online product information and post-market safety procedures.

Enforcement is also becoming more active. In 2025, the EU Safety Gate system recorded 4,671 alerts concerning dangerous products—the highest annual total reported at that time. Authorities also reported a 35% increase in follow-up actions, including product withdrawals, recalls, border measures and the removal of online listings.

For manufacturers, importers and sellers, this means GPSR readiness should be built into product development and market-entry planning rather than addressed only after a marketplace or authority raises a question.

Under the GPSR, products covered by the relevant responsible-economic-operator requirement must be linked to an economic operator established within the European Union.

Depending on the supply-chain arrangement, this operator may be:

The term Responsible Person therefore describes the EU-established economic operator responsible for specified compliance functions. It does not always mean that a separate Authorised Representative must be appointed.

For example, an existing EU importer may already fulfil the relevant role. An Authorised Representative may be appropriate where a non-EU manufacturer needs an EU-based entity to perform specified tasks under a written mandate. The correct arrangement must be determined according to the product, applicable legislation and actual supply chain.

The terms should not be used interchangeably without assessing the legal arrangement.

An Authorised Representative is an EU-established person or organisation that has received a written mandate from a manufacturer to perform clearly defined tasks.

The Responsible Person under the GPSR is the qualifying EU economic operator connected to the product. Depending on the circumstances, that operator could be an importer, an Authorised Representative, an EU manufacturer or a fulfilment service provider.

Appointing an Authorised Representative does not transfer all manufacturer obligations. The manufacturer remains responsible for product safety, product design, risk analysis and the accuracy of the information and evidence supplied.

A reliable GPSR process should cover the complete product-information chain, from technical evidence to the information shown to consumers.

1. Product Scope and Regulatory Assessment

The first step is to identify:

• whether the product is intended for consumers or is reasonably likely to be used by consumers;
• which GPSR provisions apply;
• whether sector-specific EU legislation also applies;
• which risks are covered by that legislation; and
• which supply-chain party will place or make the product available on the EU market.

Products regulated by CE-marking legislation may still be affected by certain GPSR provisions where the relevant matter is not fully addressed by sector-specific rules. A product-specific assessment is therefore necessary.

2. Product Risk Analysis

Manufacturers should assess the product under normal and reasonably foreseeable conditions of use.

The analysis may need to consider:

• the product’s design and technical characteristics;
• foreseeable misuse;
• mechanical, electrical, chemical or thermal hazards;
• risks for children, older consumers or other vulnerable groups;
• the effect of packaging and instructions;
• interaction with other products;
• connected or software-related functions; and
• changes that could affect product safety.

The risk analysis should lead to documented control measures, appropriate warnings and sufficient evidence that the product meets the applicable safety requirements.

3. Technical and Safety Documentation

The required file depends on the product and applicable legislation. Relevant documentation may include:

• product descriptions and specifications;
• drawings, photographs and model information;
• product risk assessments;
• test reports;
• applicable standards;
• supplier declarations;
• material or component information;
• declarations of conformity where required;
• certificates;
• instructions for use;
• safety warnings; and
• records of corrective measures or product changes.

The documentation should be organised so that the appropriate economic operator can provide relevant information to a market-surveillance authority when legally required.

4. Product and Packaging Information

Product identification and operator information must be consistent across the product, packaging and accompanying documentation.

Depending on the applicable requirements, businesses should verify:

• product type, model, batch or serial identification;
• manufacturer name and contact information;
• EU Responsible Person details;
• postal and electronic addresses;
• required warnings;
• instructions for safe use;
• language requirements; and
• any additional information required by sector-specific legislation.

The Responsible Person’s details cannot compensate for missing manufacturer information, inadequate safety warnings or incomplete technical documentation.

GPSR compliance also applies to products offered through websites, applications and online marketplaces.

Before a consumer completes a distance purchase, the online offer should clearly display the required information, including:

• the manufacturer’s name and contact details;
• the EU Responsible Person’s information where the manufacturer is not established in the EU;
• information that allows the product to be identified;
• an image or other relevant product representation; and
• applicable warnings and safety information.

The information should be easy for consumers to find within the product offer. Providing the details only inside a downloadable manual, hidden tab or physical package may not meet the requirement for clear pre-purchase information.

Businesses should therefore compare their physical labels with their:

• company website listings;
• marketplace pages;
• distributor catalogues;
• product-data feeds; and
• translated product descriptions.

Model numbers, contact details and warnings should remain consistent across every sales channel.

GPSR obligations continue after a product has entered the market.

Businesses should establish a documented process for:

• monitoring complaints and safety reports;
• evaluating product accidents;
• identifying recurring defects;
• escalating potential safety risks;
• communicating with distributors and marketplaces;
• deciding whether corrective action is required;
• supporting withdrawals or recalls; and
• responding to market-surveillance authorities.

Where a notification is legally required, businesses use the European Commission’s Safety Business Gateway to report dangerous products and product-related accidents to the relevant Member State authorities.

The manufacturer, Responsible Person and other supply-chain partners should understand who reviews safety information, who approves notifications and who coordinates communication.

Frequent GPSR problems include:

• appointing an EU representative without defining the covered product range;
• assuming that an online marketplace automatically becomes the Responsible Person;
• using an EU address without a valid contractual arrangement;
• treating the appointment as a substitute for a product risk assessment;
• providing incomplete technical documentation;
• displaying different product identifiers across labels and online listings;
• omitting the Responsible Person’s electronic address;
• using warnings that are not available in the required language;
• failing to update information after changing an importer or representative; and
• lacking an internal procedure for complaints, accidents and authority requests.

A Responsible Person arrangement is effective only when it is connected to accurate product data, available safety evidence and clearly assigned responsibilities.

ComplyMarket supports non-EU manufacturers and other economic operators with structured EU market-access and Authorised Representative services.

Depending on the product, applicable legislation and agreed scope, ComplyMarket can support:

• assessment of the applicable EU product requirements;
• review of the proposed EU economic-operator structure;
• EU Authorised Representative arrangements under a written mandate where appropriate;
• organisation and review of technical documentation;
• support relating to declarations of conformity and compliance records;
• product-labelling and packaging reviews;
• identification of information required in online product offers;
• communication with EU market-surveillance authorities within the agreed mandate;
• support with regulatory or product-safety enquiries; and
• monitoring of relevant regulatory developments.

ComplyMarket publicly provides EU Authorised Representative services, documentation support, product-labelling assistance, official EU liaison and ongoing regulatory guidance. The exact responsibilities should always be defined in the service agreement and written mandate for the covered products.

GPSR compliance should be treated as a coordinated product-safety and market-access process—not simply an address requirement.

Manufacturers should confirm the applicable product rules, identify the correct EU economic operator, complete the required safety documentation and align physical and digital product information before offering products to EU consumers.

Contact ComplyMarket to assess your GPSR requirements, review your documentation and determine an appropriate EU representation and market-access approach.