GPSR compliance checklist for non-EU manufacturers

What this GPSR compliance checklist covers

The General Product Safety Regulation (EU) 2023/988 (opens in a new tab) has applied directly in every member state since 13 December 2024 (Article 52). It covers consumer products: any item intended for consumers or likely to be used by them, new, used, repaired or reconditioned (Articles 2(3) and 3(1)). Food, medicines and antiques, among others, are excluded (Article 2(2)).

This checklist is for products without CE marking, such as furniture, childcare articles or gymnastic equipment, to which the GPSR applies in full (Commission guidelines C/2025/6233 (opens in a new tab), point 2.2). It also covers professional products likely to be used by consumers (GPSR and B2B products) and apps and software (software and digital products).

For CE-marked products, such as toys or electrical appliances, the sector law sets the manufacturer's duties and Articles 9 to 18 GPSR do not apply (Article 2(1)(b)); the EU economic operator usually follows from Article 4 of Regulation (EU) 2019/1020 (opens in a new tab). Articles 19, 20 and 35 to 37 GPSR still apply; see our EU and UK market entry checklist for a CE-marked example.

Before launch: seven checks for each product model

1. 1.Confirm your role. Selling under your own name or trademark makes you the manufacturer, even if a contract factory builds the product (Articles 3(8) and 13(1); see private label). An online shop that targets EU consumers is covered too (Article 4; see selling from your own shop).
2. 2.Design for the general safety requirement. Only safe products may be placed on the market (Article 5). Assess the aspects in Article 6(1), from packaging to children and cybersecurity; European standards published in the Official Journal give a presumption of safety for the risks they cover (Article 7(1)).
3. 3.Carry out the risk analysis and draw up the technical documentation per product model; keep it current and available for 10 years (Article 9(2), (3); guidelines, point 3.1.1). See risk assessment and technical documentation.
4. 4.Set up production controls that keep series production safe, as part of your internal processes for product safety (Articles 9(4) and 14).
5. 5.Appoint your Responsible Person, unless an EU importer takes the role (Article 16(1)). See who can be your Responsible Person and Authorized Representative or importer.
6. 6.Mark the product: a type, batch or serial number (Article 9(5)); your name, postal and electronic address on the product, or on the packaging or an accompanying document where that is not possible (Article 9(6)); the Responsible Person's details on product, packaging, parcel or accompanying document (Article 16(3)). See which address goes where.
7. 7.Write instructions and safety information in the language each member state sets, unless the product can be used safely without them (Article 9(7)). See safety warnings and language requirements by country.

At launch: listings, complaints and your supply chain

1. 1.Complete every online offer with the manufacturer's name and postal and electronic address, the Responsible Person, a picture, the type and any other identifier, and the warnings in the language the member state sets (Article 19). See what the 2026 GPSR sweep found.
2. 2.Open a complaints channel, such as a phone number, an electronic address or a website section, accessible to persons with disabilities (Article 9(11)), and start a register of complaints, recalls and corrective measures (Article 9(12)).
3. 3.Offer a safety-only option. If you run a product registration or loyalty program, customers must be able to give contact details for safety purposes only (Article 35(2)).
4. 4.Brief importers and retailers. An importer checks your documentation, the identification number and your details before selling (Article 11(1)); a distributor checks identification, details and instructions (Article 12(1)). Send what they need with the first order.
5. 5.Record your supply chain: for six years, who supplied the product, its parts or its embedded software, and whom you supplied (Article 15(3), (5)).

After launch: duties that keep running

1. 1.Keep the file in step with changes to design, materials or suppliers (Article 9(3)).
2. 2.Investigate safety complaints and log them; personal data in the register may be kept only as long as the investigation needs, five years at most (Article 9(12), (13)).
3. 3.Act at once on a dangerous product: corrective measures, information for consumers and a report to each member state where it was sold, through the Safety Business Gateway, the Commission's reporting portal for businesses (Article 9(8)). Keep your Responsible Person, importers and marketplaces informed (Article 9(10)).
4. 4.Notify accidents that caused a death or serious harm to health, without undue delay, to the member state where they happened, through the Safety Business Gateway (Article 20(1), (2)). See reporting and recalls.
5. 5.Recall by the rules: contact affected consumers directly, use a recall notice headed "Product safety recall" and, as a rule, offer at least two cost-free remedies (Articles 35 to 37); the template is in Implementing Regulation (EU) 2024/1435.
6. 6.Answer authorities. Information on risks, complaints, accidents and corrective measures must be available for 10 years (Article 15(2), (4)); see how to answer a market surveillance request.

Who does what: duty, legal basis and who can take it on

An Authorized Representative acts within its written mandate, which must cover at least the tasks of Article 10(2) GPSR and, to make it your Responsible Person, those of Article 4(3) of Regulation (EU) 2019/1020. The manufacturer remains the manufacturer.

Edge cases: an EU importer and direct shipping

• An EU importer. An EU business that buys from you and places the goods on the EU market is the importer and can be their Responsible Person (Article 4(2)(b) of Regulation (EU) 2019/1020).
• Direct shipping from your own shop. These orders have no EU importer. Without an Authorized Representative, an EU fulfillment service provider holding the stock becomes the Responsible Person by default (Article 4(2)(d)); parcels sent from outside the EU have no fallback, and Article 16(1) GPSR bars these sales.

Practical example: a U.S. maker of folding tables

A U.S. company sells a folding table, furniture without CE marking, through its own shop to consumers in Germany and France and to a Dutch retailer that buys stock in the U.S.

Before launch, it documents tipping, pinching and load risks and labels every unit with a batch number, its own address and its Authorized Representative (Articles 9(2), (5), (6) and 16(3)). The Dutch retailer, as importer, checks the file and adds its own details (Article 11(1), (3)); the brand's label works for both channels.

The shop pages show the Article 19 details and warnings in German and French. When the French market surveillance authority asks for the stability tests a year later, the representative supplies the current file in a language the authority easily understands (Article 4(3)(b) of Regulation (EU) 2019/1020).

Common mistakes on the way to GPSR compliance

• Buying an address instead of a Responsible Person. The role means verifying the file, answering authorities and checking products where the risks justify it (Article 16(2) GPSR; Article 4(3) of Regulation (EU) 2019/1020).
• Moving your details to the box for looks. In principle, only the product's size justifies that (guidelines, point 3.1.1).
• Giving a homepage as electronic address. An email address or a website section for direct contact qualifies; a website alone does not (guidelines, point 3.1.1).
• Softening a recall. A recall notice may not call the recall "voluntary" or "precautionary" or point out that no accidents were reported (Article 36(2)(c)).
• Planning with "4% of turnover". The GPSR sets no fines; each member state lays down its own penalties (Article 44). See GPSR penalties.

Conclusion: one checklist per product, with an owner for each line

A GPSR compliance checklist works when every line has an owner: the manufacturer for design, file and labels, the Responsible Person for checks and authority requests, the shop or retailer for the listing. Settle this before the first shipment and check the details against the Commission's guidelines.

Our compliance consulting turns this checklist into a roadmap for your products, including a review of your documentation, as part of Consulting. As your GPSR Responsible Person, Representa carries out the Responsible Person's tasks within the agreed scope and mandate; you remain the manufacturer and responsible for your product.

Frequently asked questions