EU GPSR Explained: Responsible Person, Labelling and Product Safety for Importers
Since 13 December 2024, the EU asks one question before a consumer product can be sold anywhere in the Union, online or in a shop: who inside the EU is responsible for this product? If no established economic operator is named, the product may not be placed on the market — and marketplaces have been removing listings that cannot answer.
The rule comes from the General Product Safety Regulation (GPSR), Regulation (EU) 2023/988, which replaced the old General Product Safety Directive. It applies to the EU member states and, under the Northern Ireland protocol, to Northern Ireland. If you buy from China and sell into Europe, this regulation is now part of your order, whether or not your product needs CE marking.
What GPSR covers — and what it does not
GPSR is the safety net for consumer products: it applies to every non-food consumer product sold in the EU, through every sales channel, including goods sold online into the EU from outside. It covers new, used and reconditioned items. Products governed by their own sector rules — medicinal products, food and feed, living plants and animals, plant-protection products, some aircraft, antiques — sit outside it.
A common misunderstanding: buyers assume GPSR only matters for CE-marked goods. It does not. CE marking comes from product-specific harmonised legislation; GPSR applies to everything else as well. A candle, a storage box or a kitchen gadget with no CE obligation still needs an EU responsible person.
The responsible person rule
A product can only be placed on the EU market if an economic operator established in the EU is responsible for it. Depending on the supply chain, that can be the manufacturer if it is based in the EU, an authorised representative appointed by the manufacturer in a written mandate, the importer, or a fulfilment service provider. For a Chinese factory with no EU presence, the practical route is an authorised representative or an importer who takes the role.
The responsible person’s duties are concrete, not symbolic:
- Verify that technical documentation and a risk analysis exist and are kept available.
- Ensure the operator’s name and contact details appear on the product, its packaging, the parcel, or an accompanying document.
- Cooperate with market-surveillance authorities and inform them of actions taken on unsafe products.
- Take corrective action, including recall where needed, when a product is found to be unsafe.
What has to be on the label, the package and the listing
The name, registered trade name or trademark, and postal address of the responsible economic operator and of the manufacturer must appear on the product or its packaging, the parcel, or an accompanying document. A postal address and an electronic address (an email address or a contact page that allows direct communication) are required — a static website or a phone number does not qualify, and a QR code cannot replace the address information.
Labels must also carry a product identifier (type, batch or serial number), the manufacturer’s details, and clear safety information and warnings in the language of the market where the product is sold. For products sold online, the same information must appear on the listing itself — not only in the box.
What this means when you buy from China
Your Chinese supplier cannot act as the responsible person unless it is established inside the EU. That is not a supplier failure; it is how the regulation is written. What you should be able to get from the factory is everything the responsible person and the technical file need:
- The manufacturer’s registered name, postal and electronic address, to be printed on the product or packaging.
- The Declaration of Conformity and the underlying test reports, where CE or other marking regimes apply.
- Artwork-ready label files carrying the responsible person’s details and the market-language warnings.
- A risk analysis and technical file you can hand to the responsible person and keep available for authorities.
Two practical consequences follow. First, the label artwork needs to be designed before mass production, because the responsible person’s details and the safety warnings are printed, not added later — our graphic design service prepares print-ready label files as part of the order. Second, the risk analysis and technical file belong in the pre-order specification, which is how our quality assurance process treats them.
A pre-order checklist for GPSR
- Confirm who will act as the EU responsible person, in writing, with a mandate if it is an authorised representative.
- Collect the manufacturer’s name, postal and electronic address for the label and the listing.
- Agree the product identifier system (batch or serial) with the factory.
- Finalise warnings and safety information in every language you sell in.
- Check whether your product also needs CE, UKCA, REACH or market-specific registrations, and file the paperwork.
- Update your online listings to show the operator information before the first unit ships.
Frequently asked questions
Does GPSR apply to B2B products?
GPSR targets products made available to consumers. If your product is supplied only to businesses but can reasonably be expected to be used by consumers, assume it is covered and plan accordingly.
Can the freight forwarder or a fulfilment centre be the responsible person?
A fulfilment service provider can be the responsible economic operator in specific supply chains, but only if it agrees to carry the duties. Most will not by default, so this must be contracted explicitly before the goods ship.
My product already has CE marking. Do I still need GPSR compliance?
Yes. CE marking proves conformity with the applicable product-specific directives. GPSR adds the responsible person requirement, traceability and general safety obligations on top, for CE and non-CE products alike.
What happens if I ignore it?
Marketplaces delist, market-surveillance authorities can require withdrawal, and in the worst case the goods are recalled at your cost. Since the operator information must be visible on the listing, non-compliance is easy to detect.
If you are preparing a first order for the EU market, send us the product and the countries you sell in — we will confirm the documentation list, prepare label artwork that meets GPSR, and book inspection before shipment. Start on our services page or through the contact form, and the broader picture is in our supplier compliance checklist.
