Safety Business Gateway: GPSR reporting and product recalls
9 min readRepresenta GmbH
Safety Business Gateway under the GPSR: when manufacturers, importers and the Responsible Person must report, what a recall notice needs, which remedies.
The Safety Business Gateway is the European Commission's portal through which businesses must report dangerous products and accidents under the General Product Safety Regulation (EU) 2023/988 (GPSR). Here is when a report is due, who files it for a manufacturer outside the EU, and what a GPSR product recall requires.
What the Safety Business Gateway is
The Safety Business Gateway (opens in a new tab) is a web portal run by the European Commission. Economic operators and online marketplaces use it to give authorities and consumers the information the GPSR (opens in a new tab) requires on dangerous products and accidents (Article 27(1)). For these reports, the gateway is mandatory (Commission guidelines C/2025/6238 (opens in a new tab), section 2).
You need an EU Login account and see only your own notifications; third parties such as competitors cannot submit (C/2025/6238, sections 3 and 5.2). Your entry reaches all relevant authorities at once (C/2025/6233, point 3.4.3).
When a report is due: dangerous products and accidents
The GPSR has two triggers. The first is a dangerous product, meaning any product that is not safe (Article 3(3)). If a manufacturer considers or has reason to believe that a product it placed on the market is dangerous, it must immediately take corrective measures, inform consumers and inform, through the gateway, the authorities of every member state where the product was made available. The report covers the risk, measures already taken and, if available, the quantity still on the market per member state (Article 9(8)).
The second is an accident: an occurrence associated with the use of a product that resulted in a person's death or in serious adverse effects on their health and safety, including injuries and illnesses (Article 20(2)). The manufacturer must ensure it is notified without undue delay from the moment it knows, to the authorities of the member state where it occurred, with product type, identification number and, if known, the circumstances (Article 20(1)).
Who reports when the manufacturer is outside the EU
The manufacturer stays responsible even without an EU address. Each role in the supply chain has its own duties, often for the same report:
| Role | Dangerous product | Accident | Corrective measures |
|---|---|---|---|
| Manufacturer | Informs authorities via the gateway (Art. 9(8)(c)) | Ensures notification, may instruct importer or distributor (Art. 20(1), (3)) | Takes them, informs consumers (Art. 9(8)(a), (b)) |
| Importer | Informs manufacturer and authorities via the gateway (Art. 11(2), (8)) | Informs manufacturer (Art. 20(3)) | Ensures them, acts itself if needed (Art. 11(8)) |
| Responsible Person | Informs authorities of a risk (Art. 4(3)(c)) | Ensures notification (Art. 20(4)) | Cooperates, makes sure they are taken (Art. 4(3)(d)) |
| Distributor | Ensures authorities are informed via the gateway (Art. 12(4)(c)) | Informs manufacturer (Art. 20(3)) | Ensures them (Art. 12(4)(b)) |
An Authorized Representative with a GPSR mandate notifies the action taken to eliminate the risks if the manufacturer has not, or on its instruction (Article 10(2)(c)).
Because many duties say “ensure”, one notification can cover several operators (C/2025/6238, section 3). Agree in writing who submits, or you risk duplicate reports or none. More on the role: who can be your GPSR Responsible Person.
Article 4(3)(c) of Regulation (EU) 2019/1020 (opens in a new tab) is broader: a product “presenting a risk” (Article 3(19)) also covers interests such as the environment, and no channel is named. Article 16(1) GPSR applies this task to GPSR products; the Commission's checklist points the Responsible Person to the gateway (C/2025/6233, point 3.2).
Step by step: from the first complaint to a recall
- Record and investigate complaints and accident reports, and keep the internal register (Article 9(11) and (12)).
- Assess the risk, for example with the authorities' method explained in our GPSR risk assessment article.
- Choose the measure: a withdrawal stops products in the supply chain, a recall brings back products consumers already have (Article 3(25) and (26)).
- Notify through the gateway: log in with EU Login and select every member state where the product was made available (C/2025/6233, point 3.1.1).
- Contact affected consumers directly and without undue delay, using the customer data you hold. If you cannot reach everyone, publish a recall notice on your website, social media and in shops (Article 35(1) and (4)).
- Offer remedies at no cost to the consumer (Article 37).
- Inform the supply chain, including your Responsible Person, and record the recall (Article 9(10) and (12)).
What a GPSR recall notice must contain
Written recall information takes the form of a recall notice in the languages of the member states concerned (Article 36). The template is in Implementing Regulation (EU) 2024/1435 (opens in a new tab), applicable from 13 December 2024. The notice contains:
- the headline “Product safety recall”;
- picture, name, brand, identification numbers and where to find them, and, if available, when, where and by whom the product was sold;
- a clear description of the hazard;
- what consumers should do, including an instruction to stop using the product immediately;
- the remedies, a free phone number or interactive online service, and encouragement to share the notice.
Words that play down the risk, such as “voluntary”, “precautionary” or “in rare situations”, are not allowed, and neither is a note that no accidents were reported (Article 36(2)(c)).
Remedies: at least two, free of charge
The operator responsible for the recall offers an effective, cost-free and timely remedy, as a rule a choice of at least two: repair, replacement with a safe product of the same type and at least the same value and quality, or a refund of at least the price paid (Article 37(1) and (2)). One remedy is enough only if the others would be impossible or disproportionately costly.
Consumers bear no shipping costs, products that are not portable are collected, and a refund is due if repair or replacement takes longer than a reasonable time (Article 37(2) and (5)). Vouchers are an extra incentive, not a remedy (C/2025/6233, point 3.4.2). Registration and loyalty programs must offer a safety-only contact option (Article 35(2)).
Practical example: a U.S. camping chair brand
A U.S. outdoor brand sells folding camping chairs through its online shop to consumers in Germany and France; its Responsible Person is an Authorized Representative in Germany. A French customer reports that a chair collapsed and she was treated for a broken wrist.
| Event | Who acts | What happens | Legal basis |
|---|---|---|---|
| Accident report | Brand, with the Responsible Person | Notification to France via the gateway: model, batch, circumstances | Art. 20(1), (4) |
| Weak rivets found in one batch | Brand | Notification to Germany and France: risk, measure, quantities | Art. 9(8) |
| Recall | Brand | Emails to all shop buyers of the batch, recall notice in German and French | Art. 35, 36 |
Common mistakes in reporting and recalls
- Waiting for a deadline. “Immediately” runs from the moment you have reason to believe the product is dangerous.
- Informing one country only. Report to every member state where the product was made available (Article 9(8)(c)).
- Relying on the marketplace. Marketplaces also report through the gateway (Article 22(12)(d) and (e)), but that does not discharge your duty under Article 9(8).
- Offering store credit instead of a remedy, or charging for returns (Article 37(2) and (5)).
Conclusion: settle the roles before you need them
The Safety Business Gateway turns a safety problem into a documented case with every member state concerned. Decide in advance who holds the EU Login account, who submits which notification and who writes the recall notice.
In Germany, a corrective measure not taken can cost up to 100,000 euros, a missing notification up to 10,000 euros (§ 28(2) nos. 7, 9 and 27 and (3) ProdSG); see GPSR penalties.
As your GPSR Responsible Person, Representa monitors safety incidents and handles direct communication with authorities and online platforms; under Article 20(4), it must itself ensure that accidents it knows of are notified. Corrective measures and the recall remain your obligation as manufacturer (Article 9(8)). For CE-marked products, Representa acts as your EU Authorized Representative.
Frequently asked questions
Do I need an EU Login account for the Safety Business Gateway?
Yes. Businesses need an EU Login account, the Commission's authentication service, to submit notifications, and each business sees only its own notifications (Commission guidelines C/2025/6238, section 5.2).
How quickly must an accident be reported under the GPSR?
Without undue delay from the moment the manufacturer knows about it, to the authorities of the member state where it happened (Article 20(1) GPSR). The regulation sets no number of days. Dangerous products must be reported immediately (Article 9(8)).
Do accidents with CE-marked products go through the gateway?
Yes. Article 20 GPSR also applies to products covered by Union harmonisation legislation (Article 2(1)(b); guidelines C/2025/6238, section 3). For dangerous CE-marked products, the sector legislation and, where it applies, Article 4(3) of Regulation (EU) 2019/1020 set the duties.
Can a GPSR product recall offer only a refund?
Only by way of exception, where other remedies would be impossible or disproportionately costly (Article 37(2) GPSR). As a rule, consumers choose between at least two of repair, replacement and a refund of at least the price paid.
Who reports if the manufacturer is outside the EU?
The manufacturer remains obliged. Its Responsible Person in the EU must ensure that accidents it knows of are notified (Article 20(4) GPSR), and importers and distributors must ensure that dangerous products are reported (Articles 11 and 12).