GPSR for Shopify stores: when your shop targets the EU

When your own shop targets EU consumers

Under Article 4 GPSR (opens in a new tab), a product offered online is made available on the EU market if the offer is targeted at consumers in the EU, meaning the seller directs its activities, by any means, to one or more member states. Recital 21 lists the factors for this case-by-case test; a website merely accessible from the EU is not enough.

The GPSR guidelines (C/2025/6233, section 2.1) repeat these factors; more in our guidelines article. For CE-marked products, Article 6 of Regulation (EU) 2019/1020 (opens in a new tab) applies the same test to all end users, including professional buyers.

The Blue Guide 2022 for CE-marked products is blunter (section 2.4): physical delivery to an end user in the EU is irrefutable confirmation of placing on the EU market. As Article 4 GPSR closely follows Article 6 of Regulation (EU) 2019/1020, this is a sound guide for consumer products too.

Edge cases: English-only, Swiss and trade-only shops

• English only, prices in dollars. Language and currency are two factors; delivery decides. Each unit you ship to an EU address is placed on the EU market (Blue Guide, section 2.4), so to stay out, remove the EU shipping zones.
• A Swiss shop in German. A German storefront is normal in Switzerland and only one factor. Shipping to Germany or Austria, euro prices or a .de domain point clearly to the EU (recital 21 GPSR).
• Trade customers only. The GPSR covers items intended for or likely to be used by consumers (Article 3(1) GPSR). For CE-marked products, the end-user test above still applies.

No importer in direct shipping: why you need a Responsible Person

For a purchase from a shop outside the EU, the Blue Guide places the product on the market once the order for a ready-to-ship product is placed and confirmed (section 2.4). No one in the EU becomes importer: an importer must be established in the EU (Article 3(10) GPSR), and your customer is an end user, not an economic operator (Blue Guide, section 2.1).

Yet Article 16(1) GPSR (opens in a new tab) allows placing on the market only if an economic operator established in the EU is responsible for the tasks of Article 4(3) of Regulation (EU) 2019/1020. Of the four options in Article 4(2), direct shipping leaves only an Authorized Representative with a written mandate. The GPSR guidelines add that you must ensure no product reaches the EU market without the Responsible Person's contact details (section 3.1.1).

See who can be your GPSR Responsible Person and, for CE-marked products, Authorized Representative vs importer.

GPSR on Shopify product pages: what Article 19 requires

Article 19 GPSR (opens in a new tab) applies to every economic operator selling at a distance, not only to marketplace sellers; the Commission's guidelines cite “a product offer on your e-shop” (section 3.1.1). Each offer must show clearly and visibly:

• Manufacturer: name, registered trade name or registered trade mark, postal and electronic address.
• Responsible Person, if the manufacturer is outside the EU: name, postal and electronic address.
• Product identification: picture, type and any other product identifier.
• Warnings and safety information in the language set by the member state where the product is sold.

This applies to CE-marked products too (Article 2(1)(b) GPSR). Germany requires warnings in German (§ 6 no. 3 ProdSG).

A marketplace must provide fields for this (Article 22(9) GPSR); in your own shop, you create them. Shopify's Help Center suggests the “Disclosures” product metafield for legally required warnings and the description or a metafield for the rest, and says Shopify does not currently offer services for designating a Responsible Person directly. Show the details on each product page, not only in your legal notice.

What authorities and customs can do with a shop outside the EU

Authorities can check offers that target the EU, wherever the seller is based (Blue Guide, section 2.4). For a serious risk that cannot be removed otherwise, they can order content removed or a warning shown on your shop and, failing that, have service providers restrict access (Article 14(4)(k) of Regulation (EU) 2019/1020, via Article 23(1) GPSR).

Customs controls apply to GPSR products too (Article 2(2) of Regulation (EU) 2019/1020). Customs can suspend release of a product not labeled as EU law requires (Article 26(1)(b)); for CE products under Article 4, missing EU operator details are an explicit ground (Article 26(1)(d)). The customs “importer for distance sales” (Article 5(14) of Regulation (EU) 2026/2108) is a separate role; see EU customs reform.

Fines are national. In Germany, missing Article 19 details can cost up to 10,000 euros (§ 28(2) no. 26 and (3) ProdSG); more on GPSR penalties.

Step by step: getting your shop ready for EU orders

1. 1.Check your settings: shipping zones, languages, currencies, payment options and domain. No EU customers wanted? Remove EU destinations consistently.
2. 2.Classify each product: GPSR only, or covered by a CE act listed in Article 4(5) of Regulation (EU) 2019/1020.
3. 3.Appoint a Responsible Person before the first EU order, by written mandate for the tasks of Article 4(3) of that regulation.
4. 4.Label before shipping: its name, postal and electronic address on the product, packaging, parcel or an accompanying document (Article 16(3) GPSR; see our label guide).
5. 5.Complete every product page with the Article 19 items, warnings in each destination country's language.
6. 6.Prepare for recalls and accidents: use your customer data to notify buyers directly (Article 35(1) GPSR) and agree with your Responsible Person how accidents are reported via the Safety Business Gateway (Article 20).

Practical example: an Australian outdoor brand with its own shop

An Australian outdoor brand sells backpacks, tents and a portable gas stove through its own Shopify store. It has no company or warehouse in the EU and ships every order from Australia.

The brand prints the representative's details on each box, completes every product page and provides warnings in each destination country's language. For the stove, customs can also check these details (Article 26(1)(d) of Regulation (EU) 2019/1020).

Common mistakes with your own online shop

• “My shop is outside the EU.” Article 4 GPSR asks where the offer is targeted, not where you are based.
• “My customer is the importer.” End users are not economic operators (Blue Guide, section 2.1).
• The courier or a home warehouse as EU contact. Neither can take the role (Article 3(12) GPSR; Article 4(2)(d) of Regulation (EU) 2019/1020).
• The Responsible Person only online. Its details also belong on the product, packaging, parcel or an accompanying document (Article 16(3) GPSR).

Conclusion: choose your markets on purpose

Your shop is covered by the GPSR once it targets EU consumers, and every delivery to an EU address confirms it. Decide which countries you serve, then close the chain: a mandated Responsible Person, its details on the box and the Article 19 details on every product page.

Representa acts as your GPSR Responsible Person in the EU, reviews labeling, packaging and manuals, and handles communication with authorities and online platforms. For CE-marked products such as the gas stove, we act as your EU Authorized Representative by written mandate.

Frequently asked questions