EU GPSR for Non-EU Sellers: Responsible Person, Product Labels and Online Listing Information

Who the GPSR applies to

The GPSR applies to products intended for consumers, or likely to be used by consumers, that are placed or made available on the EU market, including by online sales. It replaced the General Product Safety Directive and has applied since 13 December 2024; it also applies in Northern Ireland. Where a product is covered by specific EU harmonisation legislation with safety requirements, such as toys or cosmetics, that legislation applies to the risks it covers, and the GPSR applies to the remaining aspects and risks.

For a manufacturer outside the EU, the key change is that a product may not be placed on the EU market unless there is an economic operator established in the EU responsible for certain tasks, such as cooperating with market surveillance authorities, checking technical documentation and informing authorities of risks.

The economic operator in the EU

• The responsible operator can be a manufacturer established in the EU, an importer, an authorised representative appointed in writing by the manufacturer, or a fulfilment service provider that handles the goods in the EU.
• Its name, registered trade name or trade mark and its contact details, including postal and electronic address, must be on the product or its packaging, the parcel or an accompanying document.
• It must keep, or have access to, the technical documentation and give it to authorities on request; documentation must be kept for 10 years after the product is placed on the market.
• If you sell to an EU distributor that imports the goods, that importer is usually the responsible operator. If you sell directly to EU consumers, for example through a marketplace, you need an importer, authorised representative or fulfilment service provider in the EU.

What must be on the product or packaging

• A type, batch or serial number or other element that identifies the product, visible to consumers, or on the packaging or an accompanying document if the size or nature of the product does not allow it.
• The manufacturer's name, registered trade name or registered trade mark, and its postal and electronic address.
• If the manufacturer is not in the EU, the importer's or responsible operator's name and contact details.
• Clear instructions and safety information, in a language easily understood by consumers as decided by the Member State where the product is sold, unless the product can be used safely without them.

What online listings must show (Article 19)

Anyone offering products online or by other distance sales to consumers in the EU must show in the offer, clearly and visibly:

• The name, registered trade name or registered trade mark of the manufacturer, and the postal and electronic address at which it can be contacted.
• Where the manufacturer is not established in the EU, the name and postal and electronic address of the responsible person in the EU.
• Information identifying the product, including a picture of it, its type and any other product identifier.
• Any warning or safety information that has to be on the product, its packaging or an accompanying document, in a language easily understood by consumers.

Marketplaces and your documents

Online marketplaces must register with the EU Safety Gate, designate a single point of contact for authorities and act on authorities' orders within 3 working days, so they ask sellers for the GPSR information before listing products. For exporters, the practical steps are to agree who in the EU acts as the responsible operator, put the identification and contact details on labels and packaging, and give the importer or marketplace the technical documentation, test reports and warnings in the right languages. The commercial invoice and packing list should use the same product names and model or batch numbers as the labels.