The basis of product compliance is that all products must be safe for the consumer to use. Toys, electronics, and medical devices – to name a few – are covered by product specific directives and standards.
But, what if you’re importing or manufacturing a product falling outside the scope of such directives?
This is where the General Product Safety Directive (GPSD) comes in – as it outlines general product safety requirements that can apply to all products
What is the General Product Safety Directive (GPSD)?
The General Product Safety Directive (GPSD) is a European Union Directive that is enforced among all member states of the Union. This directive aims to ensure the general safety of consumer products before they can be placed in the market.
The GPSD sets out the general principles and regulatory framework for manufacturers, distributors, importers, and member states from the perspective of obligations, management, market surveillance, enforcement activities, penalty rules, and other procedures related to the manufacturing and market circulating processes of the products.
This Directive applies to all consumer products, whether new, used, or reconditioned. When products are regulated by some specific safety requirements or legislation imposed by the EU, the GPSD shall apply only to the aspects and risks or categories of risks not covered by those requirements.
As an example, if you are importing an electrical product that has an input voltage of 220 Volts, say a coffee machine or a hairdryer, then the electrical safety will be covered by the Low Voltage Directive, as the product falls under its scope.
However, GPSD would still cover other risks and safety aspects, for example, the possible mechanical risks caused by the product.
Here some examples of consumer’s products regulated by the GPSD:
Does GPSD require CE marking?
The GPSD is not a CE marking directive and, as such, does not require CE marking.
However, as we saw in the above-mentioned example, a product might be covered by both the GPSD and one or more CE marking directives, say Low Voltage Directive and EMC Directive.
In this case, the CE marking will be required, as it is required for any product that is covered by at least one CE marking directive.
How do I know which EN standards to follow?
Although there exists a list of harmonized EN standards that you can use to assess compliance with the GPSD, these standards only cover a subset of consumer products.
Here what you could do in order to evaluate what EN standards to follow:
1. Check the list of harmonized standards provided by the European Commission. Is your product covered by one or more standards?
If the answer is yes, you can then learn more about the standard, either by browsing the free information available on the internet or even buying the standard itself.
2. Whether you can find relevant EN standards or not, you shall contact a lab testing company in order to assess the safety risks of your product and the necessary steps to comply with the directive.
Is lab testing mandatory?
Compliance with GPSD doesn’t strictly require lab testing. However, you still have to ensure the safety of your product for the consumers.
The GPSD provides specific harmonized standards for a large array of products, for example, bikes and stationary training equipment.
When such standards exist, the most direct way to prove compliance is often to test your product for compliance with the relevant standard.
If no specific standard exists, we would still recommend you to get in touch with a lab testing company, to assess the safety risks of your product.
Also, note that your product might be subjected to other regulations and directives, that do require lab testing.
As mentioned in the previous section, the European Commission established harmonized standards for some types of products covered by the GPSD, including furniture, bicycles, gymnastic equipment, and several children’s products.
You can check the list of products that are regulated by specific harmonized standards under the GPSD on the official EU website.
EN 581-1 – Outdoor furniture – Seating and tables for camping, domestic and contract use – Part 1: General safety requirements
EN 581- 1 specifies the general safety requirements for outdoor seating and tables used for camping and contract purposes by adults. This standard does not take the materials, design, construction, mechanisms, and manufacturing processes into consideration.
EN 913 – Gymnastic equipment – General safety requirements and test methods
EN 913 specifies the general safety requirements and test methods for gymnastic equipment used for the purposes of physical education, training, and competition.
EN 957 – Stationary training equipment
EN 957 is composed of 10 parts that involve the general safety requirements, test method, mechanical requirements for specific equipment like strength training benches, rowing machines, treadmills, elliptical trainers, and exercise bicycles.
EN 14764 City and trekking bicycles – Safety requirements and test methods
EN 14764 establishes safety requirements for bicycles that are used on the public roads, with the saddle height at least 635 mm, from the perspective of the design, assembly, and test methods. This standard also contains performance requirements, usage instructions, and maintenance methods for this kind of product.
EN 14764 does not apply to mountain bicycles, racing bicycles, tradesman’s delivery bicycles, recumbent bicycles, and tandems for games.
Finally, bicycles with a saddle height less than 435 mm should be considered as children’s products and refer to EN 71 standards.
EN 14682 – Safety of children’s clothing – Cords and drawstrings on children’s clothing – Specifications
EN 14682 specifies safety standards for children’s clothing that have cords and drawstrings. The standard also covers disguise costumes and ski apparel intended to be used by children less than 14 years old.
EN 60065 – Audio, video and similar electronic apparatus – Safety requirements
EN 60065 specifies the safety requirements for electrical equipment designed for use within certain voltage limits.
The aim of this standard is to protect people and the surroundings of the apparatus from hazards including electric shock, fire, and radiation.
EN 60950-1 – Information technology equipment – Safety – Part 1: General requirements
EN 60950-1 specifies general safety requirements for information technology equipment for the purpose of reducing risks of fire, electric shock, or injury to the person who operates the equipment.
The standard concerns the safety requirements in terms of equipment installation, operation, and maintenance.
The GPSD demands manufacturers, importers, or distributors of the products subject to the directive to provide essential information in order to facilitate tracking the origin of the products and the other necessary information to avoid risks, recall potentially dangerous products, and more.
Risk Assessment Report
Manufacturers, importers, or distributors have the responsibility to ensure the safety of their products. This includes the creation and backup of a Risk Assessment Report that covers the risks and risk categories associated with the product.
The following information should be explicitly determined and explained in the Risk Assessment Report:
- Product information
- Hazard(s) disclosure
- Description of how the hazard may harm the subject
- Explanation of the nature and severity of the potential harm
- Determining the risk level by combining the severity of harm and the probability of that harm occurring in the scenario described
- Uncertainty concerning risk assessment
The GPSD does not specify a user manual as a mandatory requirement for manufacturers or importers. However, writing a user manual end-users is recommended since it could improve safety by specifying the correct usage of the products.
The following are some information you may want to include in the product user manual:
- Installation method of the product
- Components and parts information and explanation
- Safety instructions
- Usage instructions
- The recommended disposal method of the product (for electronic products)
Even if it might not be compulsory, drawing a technical file facilitates the conformity assessment of the products by relevant authorities.
The GPSD doesn’t provide specific instructions for the information that shall be included in the technical file. However, here some information that is usually relevant:
- Bill of material
- Design files, including drawings
- Label files (if any)
- Packaging files (if any)
- Relevant test reports (if any)
- Relevant EN standards (if any)
- Quality inspections reports (if any)
As the aforementioned lab testing procedure, the GPSD generally does not compel mandatory tests.
However, you must still show that your product is safe for the consumer. And a test report for relevant EN standards released by a reputable lab testing company might facilitate the procedure of product recognition.
Here a list list of laboratories that offer GPSD lab testing:
- F2 Labs
Product Traceability Labeling
Article 5 of the Directive states that the product or its packaging shall contain the name and details of the importer, and a batch number or other product reference, excluding when there is a justified reason to avoid such an indication.
More in general, the documentation requirements mandate the necessity of demonstrating the origins of products in order to hold accountability on the relevant parties and avoid potential risks during the circulation of the products.