A retailer wants proof of compliance before listing
Retailers and marketplaces ask for proof because EU law makes them share responsibility for what they sell. Since 13 December 2024 the General Product Safety Regulation requires distributors to verify labelling and traceability, and marketplaces to show the manufacturer and the EU responsible person on every listing. You answer with four things: technical documentation, a declaration of conformity where sector law requires one, test reports, and correct label data.
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Reviewed 4 October 2026 by the Conphora compliance team · Not legal advice
Why this happens
The General Product Safety Regulation (EU) 2023/988 applies to consumer products that are not fully covered by product-specific rules. It gives every company in the chain its own duties: the manufacturer prepares technical documentation and marks the product (Article 9), the importer checks that this was done (Article 11), and the distributor verifies the labelling before making the product available (Article 12).[1]
Online marketplaces have their own article. A listing must show the manufacturer's name and contact details, the EU responsible person where the manufacturer is outside the Union, information that identifies the product, and any warnings (Articles 19 and 22). A marketplace that cannot show this data cannot lawfully carry the offer, so it asks you for it before the product goes live.[1]
The responsible person is not new: Regulation (EU) 2019/1020 introduced it for products under harmonisation legislation, and the GPSR extends the same idea to other consumer products.[2]
A declaration of conformity is a separate matter. The GPSR does not require one. It comes from harmonisation legislation, for example the Toy Safety Directive, the Low Voltage Directive or the Radio Equipment Directive, and retailers ask for it when your product falls under one of those acts.[3]
How to solve it
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Find out which rules the product falls under
Start with the product, not the retailer's form. One product can fall under the GPSR and two or three sector acts at once, and each act decides which documents exist.
Regulation guidesKnow-how Free Open -
Check the product against those rules
Go through the requirements per act and record what is met, what is missing and what needs a test.
Product validationCompliance engine Open in the console -
Produce the documents that are missing
Technical documentation with a risk analysis, and the EU declaration of conformity where a sector act requires it, signed by the manufacturer.
Documentation generatorCompliance engine Open in the console -
Put traceability and the responsible person on the label and the listing
Type, batch or serial number, the manufacturer's name with postal and electronic address, and the EU responsible person. The same data goes into the marketplace listing.
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Share one status link with the retailer
Send a link that shows the product's compliance status and the documents behind it, in place of loose PDF attachments per request.
Audit & share linksCompliance engine Open in the console
Work through the steps in the platform with your own product.
What you need to show
| Document | Where it comes from | Legal ground |
|---|---|---|
| Technical documentation | The manufacturer, based on an internal risk analysis | GPSR Article 9(2) |
| EU declaration of conformity | The manufacturer, only where harmonisation legislation applies | The sector act, e.g. toys, electrical or radio equipment |
| Test reports | A laboratory, against the standards named in the documentation | Supports the two documents above |
| Label and traceability data | The product, its packaging or an accompanying document | GPSR Articles 9(5)–(6) and 16 |
| Instructions and safety information | The manufacturer, in the language of the Member State | GPSR Article 9(7) |
If you do nothing
The listing is refused or removed
A marketplace that receives an order from an authority must act without undue delay, and within two working days (GPSR Article 22(4)).[1]
Penalties under national law
Each Member State sets its own penalties for infringements of the regulation (GPSR Article 44).[1]
No one to answer for the product
A product covered by the GPSR may only be placed on the market when an economic operator established in the Union is responsible for it (GPSR Article 16).[1]
Questions about this problem
Does the GPSR require a declaration of conformity?
No. The GPSR requires technical documentation. A declaration of conformity is required by harmonisation legislation such as the Toy Safety Directive, and only for products under that legislation.
We are based outside the EU. Who is our responsible person?
A manufacturer, importer, authorised representative or fulfilment service provider established in the Union, named on the product and in the listing.
Can a retailer ask for more than the law requires?
Yes. Retailers set their own onboarding terms by contract. This page covers the legal baseline those terms build on.
How long do we keep the documents?
Ten years after the product has been placed on the market.
Sources
- Regulation (EU) 2023/988 on general product safety EUR-Lex · accessed 21 September 2026
- Regulation (EU) 2019/1020 on market surveillance and compliance of products, Article 4 EUR-Lex · accessed 21 September 2026
- The 'Blue Guide' on the implementation of EU product rules 2022 (2022/C 247/01) European Commission · accessed 21 September 2026
About this page
- Reviewer
- Conphora compliance team
- Reviewed
- 4 October 2026
General information, not legal advice. Check the legal text or ask an adviser about your own product.
Conphora (2026). A retailer wants proof of compliance before listing. Retrieved 13 October 2026 from https://www.conphora.com/solutions/problem/retailer-proof/
Conphora (2026) A retailer wants proof of compliance before listing. Available at: https://www.conphora.com/solutions/problem/retailer-proof/ (Accessed 13 October 2026).
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author = {Conphora},
title = {A retailer wants proof of compliance before listing},
year = {2026},
url = {https://www.conphora.com/solutions/problem/retailer-proof/},
note = {Retrieved 13 October 2026}
} See it working before you add a product
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