---
title: "Purchasing and marketing do not know the compliance basics"
description: "Most product duties are triggered by everyday decisions outside the compliance function: buyers choose suppliers and brands, marketing writes the offer, and customer service receives the complaints. The General Product Safety Regulation (EU) 2023/988 requires internal processes that allow the company to comply (Article 14). Teach each team the few rules its decisions touch, give it a checklist and a person to ask, and repeat the training when rules change."
type: "problem"
url: "https://www.conphora.com/solutions/problem/train-the-team/"
markdown: "https://www.conphora.com/solutions/problem/train-the-team.md"
locale: "en"
language: "en"
updated: "2026-10-05"
author: "Conphora compliance team"
publisher: "Conphora"
source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529"
tags: ["GPSR", "roles-responsibilities"]
license: "Free to quote with attribution and a link to the page"
---

# Purchasing and marketing do not know the compliance basics

Most product duties are triggered by everyday decisions outside the compliance function: buyers choose suppliers and brands, marketing writes the offer, and customer service receives the complaints. The General Product Safety Regulation (EU) 2023/988 requires internal processes that allow the company to comply (Article 14). Teach each team the few rules its decisions touch, give it a checklist and a person to ask, and repeat the training when rules change.

## Why this happens

Product compliance is decided in more places than the compliance function. Under the General Product Safety Regulation (EU) 2023/988, the role a company has for a product follows from what it does: a company established in the Union that places a product from a third country on the market is the importer (Article 3(10)), and a company that places a product on the market under its own name or trademark is deemed to be the manufacturer (Article 13(1)). Both facts are created by purchasing decisions. An importer must ensure, before placing a product on the market, that it is safe and that the manufacturer has drawn up the technical documentation and marked the product, and must not place it on the market where it has reason to believe otherwise (Article 11(1) and (2)). [1]

Marketing and e-commerce carry duties of their own. Where products are made available online or through other distance sales, the offer must clearly and visibly indicate the manufacturer's name and contact details, the responsible person where the manufacturer is not established in the Union, information identifying the product including a picture, and any warning or safety information in a language consumers easily understand (Article 19). Presentation also feeds into safety itself: the assessment of whether a product is safe takes into account its presentation, labelling and warnings, and whether its appearance makes it likely to be used by children or confused with food (Article 6(1)(d) and (f)). [1]

Customer service and logistics complete the picture. Manufacturers provide channels for complaints, investigate them and keep a register; importers investigate too and keep the manufacturer and distributors informed (Articles 9(11) and (12) and 11(10)). An importer or distributor that learns of an accident informs the manufacturer without undue delay (Article 20(3)). Importers and distributors ensure that storage and transport conditions under their responsibility do not jeopardise the product's conformity (Articles 11(5) and 12(2)), and an importer's additional label must not obscure required information on the manufacturer's label (Article 11(3)). [1]

The Regulation ties this together with one sentence: economic operators shall ensure that they have internal processes for product safety in place, allowing them to comply (Article 14). It does not prescribe training, although the Commission's guidelines name trained staff as an example of such processes (section 3.1.1), and for products under a CE act Chapter III, Section 1 (Articles 9 to 18) gives way to the sector act's own operator articles (Article 2(1), third subparagraph, point (b)), while Article 19 on online offers applies to all products. When something goes wrong, the authorities address the company: they can require economic operators to provide documents and information and to end a non-compliance (Regulation (EU) 2019/1020, Article 14(4)(a) and (g)). [1] [2] [3]

## How to solve it

1. **Map which decisions trigger a duty** Walk through a product's life with each team and mark the decisions that have a legal effect: choosing a supplier outside the Union, putting your brand on a product, changing a component, writing a product page, answering a complaint, storing and relabelling goods. That map is the syllabus.
2. **Teach purchasing the role and the gate** Buyers need three things: that importing from outside the Union makes the company the importer, that your own brand makes it the manufacturer, and which documents must be in hand before an order is placed. Give them a one-page checklist per product type and the right to say no to a supplier.
3. **Teach marketing what an offer must show and what it changes** Every online offer must show the manufacturer, the responsible person where the manufacturer is outside the Union, the product identification with a picture, and the warnings. Marketing also needs to know that presentation is part of safety: an image or text that makes a product appeal to children changes how it is assessed.
4. **Teach customer service and the warehouse to recognise a safety case** Customer service must tell a safety complaint or an accident from a quality complaint and pass it on the same day. The warehouse must know that storage and transport may not harm the product's safety or its marking, and that a stray label may not cover required information.
5. **Make it routine and keep a record** Put the basics into onboarding, repeat them once a year and whenever a rule or the range changes, and keep a short record of who attended and what was covered. A structured course gives everyone the same terms.

## What you need to show

- **Training plan and attendance record per team** — The compliance owner (GPSR Article 14 (internal processes; the record is evidence, not a named requirement))
- **Purchasing checklist: role, documents and marking before an order** — The compliance owner, used by purchasing (GPSR Articles 11(1), 11(2) and 13(1))
- **Offer template with the mandatory information** — Marketing or e-commerce (GPSR Article 19)
- **Instruction for handling and escalating safety complaints and accidents** — Customer service (GPSR Articles 9(12), 11(10) and 20(3))

## If you do nothing

- **A buyer makes the company a manufacturer** — A person that places a product on the market under its own name or trademark is deemed to be a manufacturer and is subject to the manufacturer's obligations (GPSR Article 13(1)). A branding decision taken in purchasing brings the whole documentation duty with it.
- **An offer goes live without the required information** — Where products are sold online, the offer must clearly and visibly indicate the manufacturer, the responsible person where applicable, the product identification and the warnings (GPSR Article 19). Authorities can require an operator to end the non-compliance (Regulation (EU) 2019/1020, Article 14(4)(g)).
- **An accident report stops at the service desk** — Importers and distributors that have knowledge of an accident caused by a product they supplied must inform the manufacturer without undue delay, and the manufacturer must ensure it is notified to the authorities (GPSR Article 20(1) and (3)).

## Questions

### Does the law require us to train staff?

No article read for this page names training. The GPSR requires internal processes for product safety that allow the company to comply (Article 14). The Commission's guidelines give staff trained on product safety and knowledgeable on EU product safety legislation as an example of such processes (Commission Notice C/2025/6233, section 3.1.1). A process that depends on buyers, marketers and service staff works only if they know their part.

### Who needs to know what?

Purchasing: the company's role and the documents before an order. Marketing and e-commerce: what an offer must show and how presentation affects safety. Customer service: how to recognise and pass on a safety complaint. Warehouse: storage, transport and labels. Management: who owns the process.

### How often should training be repeated?

No act sets an interval. Repeat it when people join, when the company takes on a new role or product type, and when a rule that affects a team changes. A short yearly refresher keeps the checklists in use.

### Our agency writes the product pages. Who is responsible for them?

The economic operator that makes the product available online. The duty to show the mandatory information in the offer rests on the operator (GPSR Article 19), whoever writes the text. What the agency must check or deliver is set by agreement.

## Regulations involved

GPSR

## Sources

1. [Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529) — EUR-Lex, 2026-10-05
2. [Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1020-20260812) — EUR-Lex, 2026-10-05
3. [Commission Notice — Guidelines on the application of the EU general product safety legislative framework by businesses (C/2025/6233)](https://eur-lex.europa.eu/eli/C/2025/6233/oj) — EUR-Lex, 2026-10-05