EUREP

Consumer products without CE marking: the GPSR and related rules

Products without their own CE rules fall under the General Product Safety Regulation. Since 13 December 2024 a manufacturer outside the EU needs a responsible business in the EU, named on the product, its packaging or an accompanying document.

Frying pans hanging from a rack
  • General Product Safety RegulationRegulation (EU) 2023/988
  • Product Liability DirectiveDirective (EU) 2024/2853Applies from 9 December 2026
  • REACHRegulation (EC) No 1907/2006
  • REACH formaldehyde limitsCommission Regulation (EU) 2023/1464
  • REACH PFHxA restrictionCommission Regulation (EU) 2024/2462Applies from 10 October 2026
  • Textile Labelling RegulationRegulation (EU) No 1007/2011
  • Food Contact Materials RegulationRegulation (EC) No 1935/2004
  • Ecodesign for Sustainable Products RegulationRegulation (EU) 2024/1781
  • Textile EPRDirective (EU) 2025/1892Applies from 17 April 2028

Three key facts on consumer products

  • 4,671

    Safety Gate alerts in 2025

    A record number of alerts about dangerous products in the EU, 13% more than in 2024.

  • 2024

    GPSR applies

    Since 13 December 2024: responsible business in the EU, risk analysis, traceability and information in online offers.

  • 10 years

    Technical documentation

    The manufacturer keeps the risk analysis and technical documentation for 10 years.

Safety Gate report 2025, European Commission

Who does what

Art. 16 of the General Product Safety Regulation: a consumer product may only be placed on the EU market if a business established in the EU is responsible for it.

You, the manufacturer

  • Internal risk analysis and technical documentation
  • Safe design and tests to standards where they exist
  • Type, batch or serial number and your contact details on the product
  • Instructions and safety information in the language of each country

Written mandate

Representa, your GPSR Responsible Person

  • Reviews labelling, packaging and manuals
  • Keeps compliance files ready for inspections
  • Answers authorities and supports incident reporting
  • Our name and address on product, packaging, parcel or document

Deadlines ahead

The next dates from the rules on this page.

  1. Formaldehyde emission limits for furniture, wood-based and other articles

    REACH formaldehyde limits

  2. 2 October 2026

  3. PFHxA limits for clothing, footwear, cosmetics and food contact paper

    REACH PFHxA restriction

  4. New product liability rules apply, also to importers and authorized representatives

    Product Liability Directive

  5. EU countries transpose the new textile waste rules

    Textile EPR

  6. Formaldehyde limit for road vehicle interiors

    REACH formaldehyde limits

Free compliance guide: 5 steps to enter the EU market

Download our free checklist and learn what you need before selling in Europe.

  1. 01Classification
  2. 02Documentation
  3. 03Representative
  4. 04Labeling
  5. 05Ongoing compliance

Consumer products without CE marking: frequently asked questions

Does the GPSR require an EU Authorized Representative?

It requires a business in the EU responsible for the product: an EU manufacturer, importer, authorized representative or fulfilment service provider. Without an EU importer, an authorized representative is the usual route.

Where must the details of the business in the EU appear?

On the product, its packaging, the parcel or an accompanying document, and in every online offer to EU consumers.

Does clothing need a GPSR responsible person?

Yes, if the manufacturer is outside the EU. Textiles also need a fibre composition label, and REACH limits apply to dyes and finishes.

Do kitchen utensils need an EU address?

Yes. Food contact materials must show the name and address of a manufacturer, processor or seller established in the EU (Art. 15 of Regulation (EC) No 1935/2004).

Does furniture need CE marking?

Usually not. Furniture without electrical parts falls under the GPSR, so you need a risk analysis and a responsible business in the EU. Since 6 August 2026 REACH also limits formaldehyde emissions from furniture. Motorised furniture, such as height-adjustable desks, carries CE marking.

Insights on this topic

Why companies choose Representa GmbH

  • Representa secured our EU Authorized Representative appointment within 48 hours, saving our shipment from costly delay.

    U.S. electronic device manufacturerEU Authorized Representative
  • They turned the CE Marking process into clear, actionable steps, helping us meet our launch timeline and pass compliance the first time.

    Canadian consumer electronics companyCE marking
  • Thanks to Representa, our products became fully GPSR-compliant well before the deadline, ensuring uninterrupted marketplace sales.

    Asian consumer and healthcare exporterGPSR Responsible Person
  • Our beauty cosmetics line faced labeling issues, but Representa's quick review and precise updates got us approved without delay.

    Global beauty, fashion and cosmetics brandCompliance consulting
  • The onboarding was fast and transparent. Representa made EU compliance simple and gave us confidence to expand across Europe.

    Canadian industrial equipment supplier
  • We were unsure how to manage new GPSR rules. Representa guided us step by step, keeping us fully compliant and avoiding delays.

    U.S. consumer goods manufacturerGPSR Responsible Person

Which rules apply to your product?

Send us the product description and your target markets. We check the GPSR requirements and the role we can take for you.

Get in touch with our team of experts

Tell us what you manufacture and where you want to sell. We identify the requirements for EU and UK market access and come back to you with the next steps.

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