A year of GPSR in practice
The General Product Safety Regulation – Regulation (EU) 2023/988, better known as GPSR – has applied since 13 December 2024. On that day it replaced the 2001 General Product Safety Directive, and for the first time the same text applied word for word in every Member State.
A year later, most sellers of consumer products have met GPSR not as a legal text but as a series of requests: a marketplace asking for a responsible person before a listing goes live, a form asking for product identifiers and warnings, or a market surveillance authority asking to see the documentation behind a product. This article is not a count of those requests. It is the checklist behind them: what the law asks for first, and which article each question comes from.
If you need the basics of the regulation first, start with our introduction to GPSR and the GPSR regulation guide.
1. Who is your EU responsible person? (Article 16)
The first question is almost always the same: who in the EU answers for this product?
Article 16(1) is short and strict. A product covered by GPSR shall not be placed on the market unless there is an economic operator established in the Union who is responsible for the tasks in Article 4(3) of the Market Surveillance Regulation (EU) 2019/1020. Article 16 applies Article 4(2) of that regulation, which sets the possible candidates: a manufacturer established in the EU, an importer, an authorised representative with a written mandate, or – only where none of those is established in the EU – a fulfilment service provider for the products it handles.
GPSR adds duties on top of the Article 4(3) tasks. Under Article 16(2), the responsible person must, where appropriate to the risks, regularly check that the product matches its technical documentation and carries the identification, contact details, instructions and safety information required by Article 9(5)–(7) – and must provide documented evidence of those checks when an authority asks.
Article 16(3) requires the name, registered trade name or trade mark, and contact details, including postal and electronic address, of that operator on the product or its packaging, the parcel or an accompanying document.
Checklist: one named EU operator per product, a written mandate if it is an authorised representative, a record of the periodic checks, and the contact details printed where the law allows. If you are unsure who that operator should be, see who is the responsible person on a marketplace.
2. Where is the technical documentation? (Article 9)
The second request goes to the file behind the product. Under Article 9(2), the manufacturer must carry out an internal risk analysis and draw up technical documentation before placing the product on the market. At minimum it contains a general description of the product and its essential characteristics relevant to safety. Where the risks call for it, it also contains the analysis of possible risks and the solutions adopted, the outcome of test reports, and the list of European standards or other references applied.
Article 9(3) adds two practical rules: the documentation must be kept up to date, and it must be available to market surveillance authorities for 10 years after the product has been placed on the market. Importers must keep a copy for the same period (Article 11(6)).
Checklist: a risk analysis per product, the standards or references used, test reports, and a version history that shows the file is current. Our guide to audit-ready documentation shows one way to organise it.
3. What does the listing show? (Article 19)
For anyone selling online, Article 19 is where GPSR becomes visible. Every distance-sales offer must clearly and visibly indicate at least:
- the manufacturer’s name, registered trade name or trade mark, and postal and electronic address;
- where the manufacturer is not established in the EU, the name, postal and electronic address of the responsible person;
- information that identifies the product, including a picture, its type and any other product identifier;
- any warning or safety information that must be on the product, its packaging or accompanying documents, in a language consumers can easily understand.
This mirrors what must be on the physical product under Article 9(5)–(7): a type, batch or serial number, the manufacturer’s contact details, and instructions and safety information.
Checklist: for each listing, compare the four Article 19 elements with the physical label. A listing that shows less than the product does is the most common gap. If a listing has already been taken down, see what to do when a marketplace removes a listing.
4. Why marketplaces ask before you sell (Article 22)
Sellers often experience marketplace requests as platform policy. Much of it is GPSR. Article 22 gives providers of online marketplaces their own obligations:
- they must designate a single point of contact for authorities and register with the Safety Gate Portal (Article 22(1));
- they must design their interface so that traders can provide the Article 19 information for each product and so that it is displayed on the listing (Article 22(9));
- their internal processes must let traders provide that information and a self-certification that they offer only compliant products (Article 22(10));
- they must act on an authority’s order to remove or disable content offering a dangerous product within two working days (Article 22(4)) and process product safety notices within three working days (Article 22(8)).
That is why the data fields appear at onboarding: the marketplace has to be able to collect and show them. It does not move the obligation away from the seller – the economic operators’ own duties under Articles 9, 11 and 16 remain.
5. Accidents and dangerous products (Articles 9(8) and 20)
The last item on the checklist is the one most sellers hope never to use. Under Article 20, the manufacturer must notify an accident caused by its product to the competent authorities of the Member State where it occurred, through the Safety Business Gateway, without undue delay. This covers occurrences that resulted in death or serious adverse effects on a person’s health and safety. Importers and distributors who learn of an accident must inform the manufacturer, and where the manufacturer is outside the EU, the responsible person must ensure the notification is made.
Where a manufacturer believes a product it has placed on the market is dangerous, Article 9(8) requires it to take corrective measures immediately, inform consumers and inform the authorities through the Safety Business Gateway.
Checklist: a named owner for accident reports, access to the Safety Business Gateway, and a written procedure for withdrawals and recalls.
How Conphora helps
GPSR’s first-year questions all come back to the same data: who the EU operator is, where the documentation lives, and whether every listing shows what the product shows. Conphora keeps that data in one place:
- One record per product with the manufacturer, the EU responsible person and the contact details that must appear on the product and the listing.
- Technical documentation with versions – risk analysis, test reports and standards – ready to share when an authority asks.
- Listing checks that compare the Article 19 information with the label data before a product goes live.
- Reminders for periodic responsible-person checks and document reviews.
Starting year two of GPSR? Make the answers to these five questions a standard part of every product file. See plans and pricing →