GPSR guidelines: 10 clarifications for non-EU manufacturers
10 min readRepresenta GmbH
The Commission's GPSR guidelines C/2025/6233 settle ten questions on online shops, labels, technical files and the Responsible Person. What they mean.
On 21 November 2025 the European Commission published its guidelines for businesses on the General Product Safety Regulation (EU) 2023/988, Commission Notice C/2025/6233. The GPSR guidelines answer questions that decide whether a product can stay on the EU market: when an online shop targets the EU, where the manufacturer's address must appear and who counts as Responsible Person. Here are ten clarifications for manufacturers outside the EU, each with its legal basis.
What the GPSR guidelines are, and what they are not
Article 17(2) GPSR requires the Commission to adopt guidelines for economic operators, with particular regard to small and medium-sized enterprises. The result appeared in the Official Journal as Commission Notice C/2025/6233.
They still matter as the Commission's published reading of the GPSR. Most useful are the checklists for each role, from manufacturer to online marketplace.
Scope: which products and offers the GPSR covers
Points 1 to 4 decide whether the GPSR applies to you at all.
1. An online shop is covered when it 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. For this case-by-case assessment, the guidelines list the factors from recital 21: shipping destinations, languages of the offer or ordering process, means of payment, and a member state's currency or domain name. A website merely accessible from the EU is not enough (recital 21).
2. For old stock, each unit counts
Products that complied with the old Directive 2001/95/EC and were placed on the market before 13 December 2024 may still be sold (Article 51 GPSR), and the guidelines confirm that the new labelling rules do not apply to them. The catch: placing on the market is determined for each individual unit. A unit first made available in the EU on or after 13 December 2024 must meet the GPSR in full, even if the same model was sold earlier.
3. Software, apps and professional products can be consumer products
The GPSR defines a product as any item intended for consumers or likely to be used by them (Article 3(1)). The guidelines read this broadly: tangible and non-tangible items, including apps and software such as chatbots. Professional products are covered once they migrate to consumers, such as renovation products sold in DIY stores (recital 9). So are used, repaired and refurbished products, unless clearly marked as needing repair before use (Article 2(3)).
4. CE-marked products are not outside the GPSR
Where harmonisation legislation such as the Low Voltage Directive applies, the GPSR steps back only in part. Under Article 2(1), its safety requirements do not apply to the risks the sector law covers, and Chapter III, Section 1 (general obligations of economic operators) does not apply at all. Still applicable: listing information (Article 19) and accident reporting (Article 20), the marketplace rules and the rules on recalls and remedies. Risks the sector law leaves open stay under the GPSR; the guidelines cite self-learning features of low-voltage devices.
Labels and technical documentation
Points 5 to 7 concern your labels and your files.
5. The manufacturer's details belong on the product
Article 9(6) GPSR requires the manufacturer's name, registered trade name or trade mark, and postal and electronic address on the product, or where that is not possible on the packaging or in an accompanying document. The guidelines narrow this exception: only the size of the product justifies the packaging, not aesthetic or similar reasons, and you must be able to justify your choice in a dispute. The same applies to importers (Article 11(3)).
| Information | Where | GPSR |
|---|---|---|
| Type, batch or serial number | Product; otherwise packaging or accompanying document | Art. 9(5) |
| Manufacturer's name, postal and electronic address | Product; otherwise packaging or accompanying document | Art. 9(6) |
| Responsible Person's name, postal and electronic address | Product, packaging, parcel or accompanying document | Art. 16(3) |
| Manufacturer, Responsible Person, product identification, warnings | Every online offer that targets the EU | Art. 19 |
6. A website is not an electronic address
Articles 9(6), 16(3) and 19 GPSR require an electronic address. The guidelines define it as an e-mail address or a dedicated section of your website that lets consumers contact you directly and easily. A website as such is not enough if it does not allow direct communication. For the other listing details, see our article on the 2026 GPSR sweep.
7. Technical documentation is kept per product model
Before placing a product on the market, the manufacturer must carry out an internal risk analysis, draw up technical documentation (Article 9(2) GPSR) and keep it for 10 years (Article 9(3)). The guidelines clarify that it is prepared per product model, not per unit. Variants with features that may affect safety, such as a different colour, composition or functionality, are separate products with their own documentation. The guidelines include an optional model template.
Roles: who is responsible for what
Points 8 to 10 decide who answers to the authorities.
8. An Authorized Representative is the Responsible Person only if the mandate says so
Under Article 16(1) GPSR, a consumer product may only be placed on the market if an economic operator established in the EU is responsible for the tasks in Article 4(3) of Regulation (EU) 2019/1020 (opens in a new tab). An Authorized Representative qualifies only with a written mandate designating it to perform those tasks (Article 4(2)(c) of that regulation).
The guidelines keep the two roles apart: the minimum tasks of an Authorized Representative under Article 10(2) GPSR are one thing, the role of Responsible Person is an additional designation with additional obligations. They add that a representative needs practical and administrative capacity and, where possible, the languages of the authorities it deals with. On request, it must show its mandate (Article 10(2)).
9. A fulfilment centre can become Responsible Person by default
If there is no manufacturer, importer or mandated Authorized Representative in the EU, the fulfilment service provider becomes the Responsible Person for the products it handles (Article 4(2)(d) of Regulation (EU) 2019/1020). The guidelines stress that this happens automatically. A fulfilment service provider offers at least two of warehousing, packaging, addressing and dispatching without owning the goods (Article 3(12) GPSR); a marketplace that also stores and ships products acts as one for those products.
10. Selling under your own brand makes you the manufacturer
Whoever places a product on the market under their own name or trade mark is its manufacturer, with all obligations of Article 9 (Article 13(1) GPSR). In the guidelines' example, a company that buys mugs, adds its logo and sells them becomes the manufacturer. The same applies to a marketplace selling own-brand products and, at least for the modified part, to anyone who substantially modifies a product, physically or digitally (Article 13(2) and (3)).
What to do now: a checklist based on the guidelines
- Check each online shop and marketplace account against the targeting factors: shipping destinations, languages, payment methods, currency and domain.
- Sort your stock by the date each unit was first made available in the EU. Units from 13 December 2024 onward need full GPSR labelling.
- Check where the manufacturer's details sit on each product. If they are only on the box, record the size reason.
- Replace homepage links in labels and listings with an e-mail address or a website section for direct contact.
- Map your technical documentation to product models and split it where variants differ in features that may affect safety.
- Read your Authorized Representative's mandate. If it does not cover the tasks of Article 4(3) of Regulation (EU) 2019/1020, you may have no Responsible Person, or only your fulfilment centre by default.
Practical example: a Canadian furniture maker selling online
A Canadian furniture maker sells a bookshelf in natural oak and in white lacquer, plus a bar stool, through its own online shop and an EU marketplace. Stock sits with a fulfilment service provider in the Netherlands; there is no EU importer and no EU company. The guidelines name furniture as a product group fully covered by the GPSR.
| Question | Answer from the guidelines | What the maker does |
|---|---|---|
| Is the own shop covered? | Yes: shipping to Germany and France, euro prices and German pages target the EU (Art. 4 GPSR) | Adds the Article 19 details to every product page |
| One technical file for both finishes? | Not if the lacquer changes features that may affect safety, such as composition | Keeps separate documentation for the lacquered version (Art. 9(2)) |
| Manufacturer details only on the box? | No: the bookshelf is large enough for a label | Labels each unit (Art. 9(6)) |
| Who is the Responsible Person? | By default the fulfilment service provider (Art. 4(2)(d) Regulation (EU) 2019/1020) | Appoints an Authorized Representative with a mandate designating it as Responsible Person |
Each fix is small; together they decide whether the products pass a check.
Common misreadings of the GPSR guidelines
- Treating the guidelines as law. In a dispute the regulation counts; cite the article.
- Ignoring them because they are not binding. They are the Commission's reading of the rules.
- Assuming CE marking takes a product out of the GPSR. Articles 19 and 20 and the recall rules still apply.
- Assuming an EU representative is automatically the Responsible Person. Only the right mandate makes it one.
Conclusion: the guidelines make the roles concrete
The GPSR guidelines add no new obligations, but they close several escape routes: a homepage instead of an electronic address, a label moved to the box for looks, a representative without the right mandate. For manufacturers outside the EU the last point matters most.
Representa acts as your GPSR Responsible Person in the EU, reviews labels, packaging and manuals, and keeps your compliance files ready for inspections. For CE-marked products we take on the role of EU Authorized Representative by written mandate.
Frequently asked questions
Are the GPSR guidelines legally binding?
No. Commission Notice C/2025/6233 explains how the Commission reads the GPSR. Only the text of the regulation has legal force, and binding interpretation is reserved to the Court of Justice of the EU. The guidelines are still the best indication of how the Commission applies the rules.
When is an online shop outside the EU covered by the GPSR?
When the offer targets consumers in the EU (Article 4 GPSR). Relevant factors are shipping destinations, languages, means of payment and the use of a member state's currency or domain name. A website that is merely accessible from the EU is not enough (recital 21).
Is my EU Authorized Representative automatically my Responsible Person?
No. It is the Responsible Person only if its written mandate designates it to perform the tasks of Article 4(3) of Regulation (EU) 2019/1020 (Article 4(2)(c) of that regulation, Article 16(1) GPSR). Without that, a fulfilment service provider may become Responsible Person by default.
Do I need separate technical documentation for each colour of a product?
Only if the variants differ in features that may affect safety, such as a different composition. Otherwise one technical documentation per product model is enough. Keep it for 10 years after the product was placed on the market (Article 9(3) GPSR).
Can I still sell stock produced before 13 December 2024?
Yes, if the units complied with Directive 2001/95/EC and were placed on the EU market before 13 December 2024 (Article 51 GPSR). This is assessed per unit. Units first made available from that date must meet the GPSR in full.