We do not know which regulations apply to our product

The General Product Safety Regulation is the starting point because it is the widest net. It covers any item supplied or made available that is intended for consumers or likely, under reasonably foreseeable conditions, to be used by them even if not intended for them (Article 3(1)), whether new, used, repaired or reconditioned (Article 2(3)). It excludes a fixed list, including medicinal products, food, feed, living plants and animals, plant protection products and antiques (Article 2(2)). It applies from 13 December 2024 (Article 52).^[1]

The GPSR then steps back where more specific Union rules exist. It applies insofar as there are no specific provisions with the same objective regulating the safety of the products concerned; where specific safety requirements exist, it covers only the aspects and risks they do not (Article 2(1)). For products subject to specific requirements imposed by Union harmonisation legislation, its safety chapter (Chapter II) does not apply to the risks that legislation covers (Article 2(1)(a)), and its Chapter IIa, Chapter III Section 1 (the duties of economic operators in Articles 9 to 18), and Chapters V, VII and IX to XI do not apply at all (Article 2(1)(b), as amended by Regulation (EU) 2024/2748). The online-sales duties of Article 19 sit in Section 2 and are not in that list. REACH and labelling acts such as the footwear and textile rules are also listed in Annex I to Regulation (EU) 2019/1020, to which the GPSR's definition of Union harmonisation legislation refers (Article 3(27)). The Commission nonetheless reads the GPSR as applying fully to everyday goods such as furniture and childcare articles that REACH also restricts (Commission Notice C/2025/6233, section 2.2), and Conphora follows that reading: a product-specific harmonisation act switches Articles 9 to 18 off, while REACH, the POPs rules and labelling-only acts apply alongside them.^[1]

Union harmonisation legislation has a precise meaning: the acts listed in Annex I to Regulation (EU) 2019/1020 and any other Union legislation harmonising the conditions for marketing products to which that regulation applies (GPSR Article 3(27)). Annex I is a practical checklist. It names, among others, the Low Voltage, EMC and Radio Equipment Directives, the Toy Safety Directive, the Battery and Packaging Regulations, the energy labelling framework, the textile labelling regulation, the footwear labelling directive, the cosmetics regulation and the units of measurement directive. Each act's scope article decides whether it applies: the Low Voltage Directive, for example, covers electrical equipment rated 50 to 1 000 V AC or 75 to 1 500 V DC (Directive 2014/35/EU Article 1).^[1][2][4]

Not every act is about safety. The energy labelling framework applies to energy-related products, and its labelling duties bite where a delegated act covers the product group (Regulation (EU) 2017/1369 Articles 1, 3, 4 and 16); it adds labels, a product information sheet and a database entry. Labelling acts like these are easy to miss because they do not change the product's design, yet a product that lacks a required label does not conform to applicable harmonisation legislation, and authorities act on that (Regulation (EU) 2019/1020 Article 16(1)(b)).^[2][3]

The result should be written down. A manufacturer of a product under the GPSR draws up technical documentation before placing it on the market and keeps it up to date (Article 9(2) and (3)); the text does not require a separate record of which acts apply, but keeping one with that documentation is a practical choice. For products under the harmonisation acts listed in Article 4(5) of Regulation (EU) 2019/1020, an economic operator in the EU verifies that the declaration of conformity and technical documentation required by those acts exist (Article 4(1) and (3)).^[1][2]