Esc

Site search arrives with the platform catalogue. Until then, start from one of these:
Role 5 of 7

The online marketplace role in EU product compliance

The provider of an online marketplace runs an online interface where consumers buy products from traders. It does not place the products on the market, but Article 22 of the General Product Safety Regulation gives it duties of its own: contact points for authorities and consumers, an interface that shows the mandatory product information, action on authority orders within two working days and on other notices within three, and cooperation in recalls. The Digital Services Act applies alongside.

Try the demo with The online marketplace role in EU product compliance — freeNot sure this is your role?

Free account · no card · opens in the Demo Company

Reviewed 5 October 2026 by the Conphora compliance team · Not legal advice

Am I the online marketplace?

What the law asks of you

The references name the General Product Safety Regulation (GPSR) and, as the example of a CE act, the Low Voltage Directive (LVD). For products under a product-specific harmonisation act, such as the Low Voltage or Toy Safety Directive, the GPSR's Chapter III, Section 1 (Articles 9 to 18) does not apply, and the act's own duties take its place (Article 2(1), third subparagraph, point (b)). The GPSR's safety requirement still covers risks the act does not (point (a)), and Articles 19 to 22, on online offers, accidents and online marketplaces, apply to all products, as do the recall rules in Articles 35 to 37. REACH restrictions and labelling rules do not take a product out of Articles 9 to 18. Whoever places on the EU market a product not designed for it, or a used product from outside the EU, takes on the manufacturer's role (Blue Guide, section 3.1); a used CE product resold inside the EU falls under the GPSR in full. The regulation guides list the article for each act.

Before the product is placed or sold

  • Designate a single point of contact for direct electronic communication with the market surveillance authorities on product safety and register with the Safety Gate Portal, and designate a single point of contact for consumers. GPSR Art. 22(1) and 22(2)
  • Have internal processes for product safety in place. GPSR Art. 22(3)
  • Design the interface so that traders can provide, and consumers see in the listing, the manufacturer's name and addresses, the responsible person where the manufacturer is outside the EU, the product identification with a picture, and the warnings and safety information; and so that traders can give their self-certification that they offer only products that comply. GPSR Art. 22(9) and 22(10)
  • Under the Digital Services Act, obtain and check the trader's identity and its self-certification before the trader can offer products. This rule does not apply to platforms that are micro or small enterprises, unless they are designated as very large online platforms. Regulation (EU) 2022/2065 Art. 29 and 30

While it is on the market

  • Use at least the Safety Gate Portal for the random checks of offers against official databases that the Digital Services Act asks for, and take the dangerous products notified on Safety Gate into account in your own measures to detect and remove offers, telling the notifying authority what you did. GPSR Art. 22(6) and 22(7); Regulation (EU) 2022/2065 Art. 31(3)
  • Suspend, after a prior warning and for a reasonable period, traders that frequently offer products which do not comply with the regulation. GPSR Art. 22(11)
  • Cooperate with the market surveillance authorities, with traders and with the other economic operators on corrective action, including giving the authorities' online tools access to your interface to identify dangerous products, and answering data requests on the supply chain. GPSR Art. 22(12), points (c), (g) and (h)

When something is wrong

  • Act on an authority's order to remove an offer of a dangerous product, disable access to it or display an explicit warning without undue delay, and in any event within two working days from receipt of the order, and tell the authority what effect you gave to it. GPSR Art. 22(4)
  • Process other notices on product safety without undue delay, and in any event within three working days from receipt. GPSR Art. 22(8)
  • In a recall you know of, notify directly the consumers who bought the product through the marketplace and publish the recall information on your interface. GPSR Art. 22(12)(a); Art. 35(1)
  • Inform the authorities through the Safety Business Gateway about dangerous products that you know were offered on your marketplace, and notify accidents you are told about that caused a serious risk or actual damage to a consumer's health or safety, informing the manufacturer. GPSR Art. 22(12)(d) and (e)

The General Product Safety Regulation (EU) 2023/988 defines a provider of an online marketplace as a provider of an intermediary service using an online interface which allows consumers to conclude distance contracts with traders for the sale of products (Article 3(14)). Article 22 sets out the specific obligations of such providers, without prejudice to the general obligations of the Digital Services Act.[1][2]

The article starts with contact and process: a single point of contact for the authorities (Article 22(1)), one for consumers (Article 22(2)) and internal processes for product safety (Article 22(3)). It then sets the clocks. Orders from market surveillance authorities to remove an offer of a dangerous product, disable access or display a warning are acted on within two working days (Article 22(4)); notices from others are processed within three working days (Article 22(8)).[1]

The remaining duties concern the offers themselves. Providers use at least the Safety Gate Portal for their random checks of offers (Article 22(7)), enable traders to provide the mandatory information and ensure that it is displayed (Article 22(9) and (10)), suspend traders that frequently offer non-compliant products (Article 22(11)), and cooperate with authorities and economic operators on corrective action (Article 22(12)). That cooperation is concrete: notifying directly the consumers who bought a recalled product through the marketplace, publishing recalls, and informing the authorities through the Safety Business Gateway about dangerous products and accidents.[1]

A marketplace is not one of the operators that can be responsible for a product in the Union: the list in Article 4(2) of Regulation (EU) 2019/1020 names the manufacturer, the importer, the authorised representative and the fulfilment service provider. That is why marketplaces ask every trader for the responsible person and display it in the offer.[3]

What Conphora does for the online marketplace

What the platform does today for a company in this role.

Try the demo — free

Who you share with

  • Online seller

    You give
    Notice when an offer is removed, a warning before a suspension, and recall information for the products concerned.
    You receive
    For each listing: the manufacturer, the responsible person in the EU, the product identification and the warnings.

  • Shop or consumer

    You give
    The mandatory information in the listing, and a direct notice when a product bought through the marketplace is recalled.
    You receive
    Product safety questions and notices through the consumer contact point.

  • Market surveillance authorities

    You give
    Action on orders and a report of the effect given to them, notifications through the Safety Business Gateway, and access to the interface for the authorities' online tools.
    You receive
    Orders to remove an offer, disable access or display a warning.

See the whole flow →

Regulations that bind the online marketplace

Taken from the regulation guides: 4 acts name this role. The article numbers are those of the role's duties in each act.

All regulation guides →

Problems people in this role ask about

Problem pages written for this role: 2 in all.

We run a marketplace and must meet the GPSR dutiesRoles and responsibilitiesA product needs to be recalledIncidents, recalls and authorities

All problems for this role →

Questions about the role

Do these duties replace the Digital Services Act?

No. Article 22 applies without prejudice to Regulation (EU) 2022/2065 and refers to it throughout. It adds the product safety specifics, and the Digital Services Act duties, such as obtaining and checking trader identity before a trader can offer products (Article 30), apply alongside it. Those trader rules do not apply to platforms that are micro or small enterprises unless designated as very large online platforms (Article 29). GPSR Article 22 contains no such exemption of its own, and Conphora reads its duties as applying to every marketplace.

Do we have to check every product before it goes online?

The article requires processes, the mandatory information, use of the Safety Gate Portal and action on orders and notices. It does not describe a general pre-approval of every product.

What can an authority order us to do?

To remove content referring to an offer of a dangerous product, to disable access to it, or to display an explicit warning.

Can the marketplace be a seller's responsible person in the EU?

Not as a marketplace: the provider of an online marketplace is not on the list in Article 4(2) of Regulation (EU) 2019/1020. A marketplace company that also stores and ships a seller's goods may qualify as a fulfilment service provider for them, and a fulfilment service provider established in the Union can fill the role where no manufacturer, importer or authorised representative is established there (GPSR recital 46).

Sources

  1. Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026) EUR-Lex · accessed 5 October 2026
  2. Regulation (EU) 2022/2065 on a Single Market for Digital Services (Digital Services Act) EUR-Lex · accessed 5 October 2026
  3. Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026) EUR-Lex · accessed 5 October 2026

About this page

Reviewer
Conphora compliance team
Reviewed
5 October 2026

General information, not legal advice. Check the legal text or ask an adviser about your own product.

Cite this page 
Conphora (2026). The online marketplace role in EU product compliance. Retrieved 13 October 2026 from https://www.conphora.com/roles/online-marketplace/
Reviewed

The other roles

Demo Company

See it working before you add a product

The Demo Company is a complete, read-only example — products, documents, supplier requests and deadlines. Open it with a free account; no card, no trial clock.

Try the demo — freeAll roles

Free account · no card · opens in the Demo Company