General consumer products sold online

• Regulation (EU) 2023/988 — General Product Safety Regulation
• Regulation (EU) 2019/1020 — market surveillance
• Regulation (EC) No 1907/2006 — REACH restrictions

Who has to appoint one

Anyone placing physical consumer products on the EU market where no economic operator established in the Union is responsible for them. Article 16 sets an order: the manufacturer if established in the Union, otherwise the importer, otherwise an authorised representative holding a written mandate, otherwise a fulfilment service provider. Private-label sellers are manufacturers in law, because they market the product under their own name. Dropshippers are typically importers or distance sellers and are fully caught. Marketplace sellers based in the UK, US, Turkey or China all need an entity inside the Union.

Thresholds and exemptions

None. GPSR is the residual regime: it applies to every consumer product not covered by more specific harmonised legislation, and to the aspects of covered products that the sectoral rules do not address. Handmade goods, small batches, second-hand products offered commercially and free samples are all in scope.

What must appear on the label

The manufacturer's name, registered trade name or trade mark and postal address, and an electronic address. The name and EU postal address of the responsible person under Article 16, with an electronic address. A type, batch or serial number identifying the product, or a picture where the nature of the product does not allow it. Warnings and safety information in the national language where the product presents a risk. Under Article 19, distance offers must show the manufacturer's details, the responsible person's details, the product identifier and any warnings before the consumer is bound by the contract.

Marketplace fields

Since 13 December 2024 Amazon, eBay, Etsy, Zalando, Kaufland, Temu, Shein and TikTok Shop suppress listings where the responsible person field is empty or contains a non-EU address, and this is enforced automatically. Marketplaces must also register in the Safety Gate portal, act on takedown notices within two working days, and pass seller details to authorities. A UK address, a Swiss address or a freight forwarder without a mandate will all be rejected.

Documentation you must hold

Technical documentation proportionate to the risk, kept for ten years, containing a general description of the product, its essential characteristics relevant to safety, an analysis of the possible risks and the solutions adopted, and a list of any standards applied. Records of complaints and of products found unsafe, and evidence that complaints were investigated. Traceability records identifying every supplier and every business customer. Where a product has been found unsafe, records of the corrective action, the consumers informed and the Safety Business Gateway notification.

Standards and testing

There is no single mandatory standard, so the risk assessment determines the test programme. In practice: mechanical and stability testing where the product can tip, trap or cut; electrical safety where mains or batteries are involved; REACH Annex XVII screening for restricted substances such as lead, cadmium, nickel release, phthalates and azo dyes; flammability for textiles and soft furnishings; and food-contact migration where the product touches food. Applying a relevant European standard creates a presumption of safety for the aspects it covers.

Language requirements

Warnings, safety information and instructions must be in a language easily understood by consumers in each member state where the product is made available, as determined by that state. In practice that means the national language of every market, and a bilingual EN-only label is not sufficient anywhere except Ireland and Malta.

When it applies

Everything must be in place before the product is offered to EU consumers, including in the online listing. Where a product presents a risk, the responsible person must notify the authorities through the Safety Business Gateway without delay and take corrective action, and where a recall is needed consumers must be notified directly wherever contact details are available, offered a remedy of repair, replacement or refund, and given at least two of those options.

How long records are kept

Technical documentation for ten years from the date the product was placed on the market. Traceability records for the same period. Complaint and accident registers for as long as the product is on the market plus the statutory period, because the responsible person must be able to demonstrate what it did with each complaint.

What happens if you do not comply

Listing suppression, which arrives first and hurts most. Then a documentation request with a short deadline, a withdrawal or recall order, destruction of stock, and a Safety Gate alert that is public and names the brand. Member states set their own fines and several tie them to turnover. Under GPSR consumers also have a direct right to a remedy in a recall, and the cost of a recall — notifying consumers, refunds, logistics — usually exceeds the fine.

Who enforces it

National market surveillance authorities, coordinated through ICSMS and the Safety Gate. Customs at the point of entry. Marketplaces themselves, which act as a first filter and must respond to authority notices within two working days.

Where the boundary lies

If harmonised sectoral legislation covers your product, that regime applies instead and is almost always heavier: toys, cosmetics, electrical equipment, machinery, PPE, medical devices, food contact materials. GPSR still fills the gaps those rules leave. The most frequent mistake is assuming a product is 'just homeware': a scented candle brings CLP, a bamboo bowl brings food contact rules, a phone charger brings the Low Voltage Directive and WEEE, and a child-attractive design can bring the Toy Safety Directive.

Questions we are asked

Our supplier is in China and we sell from the UK — who goes on the label?

The manufacturer, and an economic operator established in the Union. A UK entity does not satisfy Article 16 since Brexit, so you need an importer, an authorised representative or a fulfilment provider inside the Union.

Is one responsible person enough for all 27 member states?

Yes. One responsible person established anywhere in the Union covers the internal market. What changes per country is the language of the warnings and instructions.

We only sell a handful of units a month — is this proportionate?

The obligations do not scale with volume. What scales is the depth of the technical documentation, which must be proportionate to the risk, not to your turnover.

Can the responsible person be a freight forwarder or a virtual office?

A fulfilment service provider can hold the role if it accepts it in writing. A virtual office that has not accepted a mandate is not an economic operator, and marketplaces reject addresses that do not correspond to an entity that has taken the role on.