General Product Safety Regulation (GPSR): An Essential Guide

The General Product Safety Regulation (GPSR) mandates that all consumer products sold in the EU meet certain safety requirements. In this guide, we explain what GPSR compliance means in practice, while also answering common questions about the new EU regulation.

What is the General Product Safety Regulation (GPSR)?

The General Product Safety Regulation (GPSR) is a regulation mandating that all consumer products sold in the EU meet essential safety requirements in the European Union.

It sets various requirements affecting manufacturers, importers, distributors, marketplaces, and other entities.

What requirements are set by the GPSR?

The General Product Safety Regulation (GPSR) sets the following for manufacturers:

1. All consumer products sold in the EU must be safe

2. Products must comply with harmonised standards or other standards to demonstrate safety

3. Products may need to be accompanied by user instructions

4. Product and packaging labelling requirements

• Traceability
• Warnings
• Age group indication
• Instructions

5. Technical documentation

6. Product must generally be tested according to applicable standards

7. Non-EU manufacturers selling products to consumers in the EU need an authorised representative established in the European Union

Additionally, the General Product Safety Regulation (GPSR) sets requirements for information on e-commerce websites and how recalls must be managed.

Which products are covered by the GPSR?

The General Product Safety Regulation (GPSR) can be said to apply to products and aspects that meet the following criteria:

1. The product is a consumer product or can be used as a consumer product

2. The product or risk aspect is not covered by other EU regulations and directives

Example

As such, the GPSR functions as a safety net for products and safety aspects not covered elsewhere. Toys, for example, are covered by the Toy Safety Directive. As such, the GPSR does not cover toy safety.

That said, the GPSR does set additional labelling requirements not covered by the Toy Safety Directive.

Aspect	Toy Safety Directive	GPSR
Toy safety	Applicable	Not applicable
Electronic address	Not covered	Covered

General consumer products

For many products, the GPSR is the “primary” regulation to comply with. This is generally the case for the following:

• Children’s products
• Furniture
• Training equipment
• Bicycles

Such products can also be covered by the GPSR harmonised standards.

Which products are exempted by the GPSR?

Article 2 of the GPSR states that the following product categories are not covered under the GPSR:

1. Medicinal products for human or veterinary use

2. Food

3. Feed

4. Living plants and animals, genetically modified organisms and genetically modified microorganisms in contained use, as well as products of plants and animals relating directly to their future reproduction;
animal by-products and derived products

5. Plant protection products

6. Equipment on which consumers ride or travel,where that equipment is directly operated by a service provider within the context of a transport service provided to consumers and is not operated by the consumers themselves

7. Aircraft referred to in Article 2(3), point (d) of Regulation (EU) 2018/1139

8. Antiques

Who is responsible for GPSR compliance?

Manufacturers are generally responsible for actively managing the GPSR compliance process. However, importers, distributors and other entities are also subject to certain requirements.

The table below provides examples of the actions that must be taken from the perspective of manufacturers, importers, and distributors.

Entity	Manufacturer	Importer	Distributor
Definition	Manufactures or has a product manufactured based on its design or brand	Any company in the EU making products from outside the EU available for sale	Any company other than the manufacturer or the importer selling the product
Product safety	1. Must identify standards and design for compliance 2. Must arrange testing	Must obtain test reports from the manufacturer	Cannot sell unsafe products (including those suspected to be unsafe)
Technical documentation	Must create the technical documentation	Must obtain and check a copy from the manufacturer
Labelling	Must affix product and packaging labelling	1. Must check the labelling 2. Importer information must be affixed to the labels	Must check that the manufacturer and importer labelling (if applicable) is correct
Instructions	Must create the instructions	Must obtain and check the instructions (and likely translate them)	Must obtain and check the instructions

Learn more

• General Product Safety Regulation Requirements for Manufacturers
• General Product Safety Regulation Requirements for Importers

Product standards

While the General Product Safety Regulation (GPSR) mandates that all consumer products sold in the EU are safe, it does not provide product-specific requirements for how this is to be achieved. Instead, manufacturers must implement product standards to achieve this.

Example

For example, the GPSR does not explain how you should design a baby carrier to ensure an acceptable degree of safety. Instead, this is specified in the following product standards:

EN 13209-1 – Child use and care articles – Baby carriers – Safety requirements and test methods – Framed back carriers

EN 13209-2 – Child use and care articles – Baby carriers – Safety requirements and test methods – Soft carrier

How to find a relevant GPSR standard

1. Article 7 states that you should primarily follow harmonised standards

2. If harmonised standards don’t exist for your product, then compliance with national requirements can be acceptable

3. You have the following options if neither harmonised standards nor national requirements exist for your product:

• Non-harmonised EN standards
• International standards (i.e., ISO and IEC standards)
• International agreements
• Voluntary certification schemes
• Commission recommendations or guidelines on product safety assessment;
• National standards drawn up in the Member State in which the product is made available
• The state of the art and technology
• Product safety codes of good practice in force in the sector concerned
• Reasonable consumer expectations concerning safety
• Safety requirements adopted in accordance with Article 7(2)

Learn more

General Product Safety Regulation Standards Guide

Documentation

The GPSR sets various documentation requirements for manufacturers.

Technical documentation

Article 9(2) specifies that the manufacturer must create technical documentation containing the following information:

1. A general description of the product

2. Essential characteristics relevant for assessing its safety

3. an analysis of the possible risks related to the product and the solutions adopted to eliminate or mitigate such risks, including the outcome of any reports related to tests conducted by the manufacturer or by another party on their behalf; and

4. the list of any relevant European standards as referred to in Article 7(1), point (a), or the other elements referred to in Article 7(1), point (b) or Article 8, applied to meet the general safety requirement laid down in Article 5.

5. Where any of the European standards, health and safety requirements or elements as referred to in Article 7(1) or Article 8 have been only partly applied, the manufacturers shall identify the parts which have been applied.

Example

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Learn more

General Product Safety Regulation Technical Documentation Guide

Test reports

The technical documentation mandates the inclusion of test reports that serve as evidence of compliance with applicable product standards. For example, a manufacturer of baby carriers would need to provide test reports demonstrating compliance with EN 13209-1 or 2.

Learn more

General Product Safety Regulation Product Testing Guide

Instructions

Article 9(7) states that products must be accompanied by clear instructions and safety information. Whether this is needed depends on the product type and whether consumers need instructions to safely use the product.

Learn more

GPSR Warnings and Safety Information – A Practical Guide

Labelling requirements

The General Product Safety Regulation sets labelling requirements affecting manufacturers, importers, and authorised representatives. Depending on the product and the supply chain setup, you may need to include the following information:

• Product type
• Batch or serial number
• Manufacturer name
• Manufacturer postal address and electronic address
• Importer name
• Importer postal address and electronic address
• Authorised representative name
• Authorised representative postal address and electronic address
• Age group
• Safety information and warnings

Example

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Learn more

General Product Safety Regulation Labelling Requirements Guide

EU Authorised Representative

Article 16 of the GPSR states that a product can only be sold if there is an economic operator present in the EU. If the manufacturer or importer is located in the EU, then this requirement is already fulfilled.

However, if you are a non-EU company selling directly to consumers, then no economic operator is established in the EU. It is in this scenario that you also need an EU AR.

In practical terms, this means that you must:

1. Sign an agreement with a company acting as your EU AR

2. The EU AR will need to review your compliance documents, test reports, and labelling

3. Their information must be affixed on the labels and be available online

Learn more

Authorised Representatives under the General Product Safety Regulation

Website information

Article 19 of the General Product Safety Regulation requires that the following information is present on the website:

Manufacturer and EU AR information

1. Manufacturer name

2. Manufacturer postal address and electronic address

3. EU authorised representative name (if non-EU manufacturer)

4. EU authorised representative postal address and electronic address (if non-EU manufacturer)

Product information

1. Product image

2. Type and any other product identifier

3. Warnings and safety information are also available on the product, packaging, or user instructions

FAQ

Does the GPSR cover children’s products?

Yes, the GPSR covers children’s products. Note that children’s products that are not defined as toys are generally not covered by the Toy Safety Directive. As such, the GPSR is the “primary” regulation to comply with for baby carriers, feeding bottles, children’s furniture and other children’s products.

Further, there are several harmonised standards under the GPSR which apply to children’s products.

Does the GPSR apply to clothing and other textile products?

Yes, the GPSR applies to textiles, including clothing for both adults and children.

Does the GPSR cover toys?

Certain aspects of the GPSR may apply to toys. However, toy safety is primarily covered by the Toy Safety Directive.

Does the GPSR cover furniture?

Yes, the GPSR applies to furniture for both children and other age groups. There are also harmonised standards under the GPSR applicable to furniture.

Here are some examples of such standards:

EN 581-1:2006 Outdoor furniture – Seating and tables for camping, domestic and contract use – Part 1: General safety requirements

EN 716-1:2017+AC:2019 Furniture – Children’s cots and folding cots for domestic use – Part 1: Safety requirements

EN 1129-1:1995 Furniture – Foldaway beds – Safety requirements and testing – Part 1: Safety requirements

Does the GPSR cover packaging?

Yes, the GPSR applies to packaging in the following ways:

1. Labelling requirements can apply to packaging

2. Article 6 states that the safety of the packaging must be taken into account when ensuring compliance with the GPSR

Does the GPSR apply to second-hand or used products?

Yes, the GPSR does state that it applies to second-hand products:

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The requirements laid down in this Regulation should apply to second-hand products or products that are repaired, reconditioned or recycled, that re-enter the supply chain in the course of a commercial activity, except for those products for which the consumer cannot reasonably expect that they fulfil state-of-the art safety standards, such as products which are explicitly presented as to be repaired or to be reconditioned, or which are made available on the market as collectible items of historical significance.

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However, the GPSR also states that it does not apply to products introduced on the market (made available for sale, in most cases) before December 13, 2024. It is not clear in the GPSR if a product is deemed to have been placed before this date if it is resold as a second-hand product now.

Does the GPSR apply to handmade products?

Yes, the GPSR applies to handmade consumer products. There is no definition of what constitutes a handmade product in the GPSR. Nor is there any statement indicating that such products are exempt.

Does the GPSR apply to artworks?

Yes, the GPSR can apply to artworks. It does, however, exempt artworks defined as antiques:

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Antiques, such as works of art or collectors’ items are specific categories of products which cannot be expected to meet the safety requirements laid down by this Regulation, and should therefore be excluded from its scope. However, in order to prevent other products from being mistakenly considered as belonging to those categories, it is necessary to take into account that works of art are products created solely for artistic purposes, that collectors’ items are of sufficient rarity and historical or scientific interest to justify their collection and preservation, and that antiques, if they are not already works of art or collectors’ items or both, are of an extraordinary age.

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We have been contacted by many artists who have been concerned about the GPSR. What we have said is that GPSR compliance in many cases can be quite trivial for artworks, as the degree of safety, including documentation and testing needed to support that, varies depending on the product type.

A painting or sculpture does generally not pose the same risk as a baby carrier or feeding bottle.

Does the GPSR cover electronics?

Yes, the GPSR can apply to certain types of electronics. For example, the following harmonised standards can be found in relation to the GPSR:

EN 60065 – Audio, video and similar electronic apparatus – Safety requirements

EN 60950 – Information technology equipment – Safety – Part 1: General requirements

EN IEC 62368 – Audio/video, information and communication technology equipment – Part 1: Safety requirements

That said, most types of electronics are subject to specific regulations and directives. This includes the RoHS Directive, Low Voltage Directive, Radio Equipment Directive and so on.

Does the GPSR cover machinery?

Machinery is subject to the requirements of the Machinery Directive and the Machinery Regulation, rather than the General Product Safety Regulation.

Does the GPSR cover medical devices?

Medical devices are already covered by the Medical Devices Regulation rather than the General Product Safety Regulation.

Is GPSR compliance mandatory?

Yes, compliance with the General Product Safety Regulation is mandatory when selling consumer products in the European Union.

Who will check GPSR compliance?

GPSR compliance can be checked by national customs authorities in the EU upon arrival. Market surveillance authorities also conduct random inspections and compliance checks for products that are already available on the market in various EU countries.

That said, Amazon and marketplaces are perhaps the most effective enforcers of GPSR compliance. For context, the GPSR requires that marketplaces establish routines for checking GPSR compliance for third-party products sold via its channels.

They are also responsible for reporting non-compliant products to the authorities. Amazon and other marketplaces can request compliance documents when a product is first listed, or at a later date.

From when does the GPSR apply?

The General Product Safety Regulation has been applicable since December 13, 2024. The previous General Product Safety Directive was repealed on that date.

Does the GPSR require CE marking?

No, the General Product Safety Regulation does not mandate CE marking. A product cannot be CE marked on the basis of the General Product Safety Regulation alone.

What is the difference between the GPSR and CE marking?

CE marking regulations and directives apply to specific product types and aspects. For example, the PPE regulation only covers products defined as personal protective equipment.

The GPSR functions as a safety net for products and aspects not covered by such regulations and directives.

That said, the practical procedure that must be followed is not that different between products that fall under the GPSR and those that must be CE marked. Many concepts and steps that must be completed are largely similar.

Does the GPSR apply in the UK?

No, the EU General Product Safety Regulation does not apply in the UK, apart from Northern Ireland. However, the UK has its own version titled the General Product Safety Regulations 2005.

This regulation is based on the GPSD and shares many of the requirements found in the EU GPSR.

Does the GPSR apply in Northern Ireland?

Yes, the GPSR is applicable in Northern Ireland, as it remains aligned with EU product regulations and directives.

Do UK sellers need to comply with the EU GPSR?

Yes, UK companies selling to the EU or Northern Ireland must comply with the EU GPSR.

Do US companies need to comply with the EU GPSR?

Yes, American companies selling to consumers or importers in the EU must comply with the EU GPSR. This is not a requirement specifically aimed at US companies, but applies to all non-EU companies.

GPSR and GPSD Differences

Requirement	GPSR	GPSD
Responsible person	a. Manufacturer b. Importer c. Authorised representative d. Fulfilment service provider	/
Labelling	a. Product type, batch, or serial number b. Manufacturer’s name, registered trade name, or registered trade mark c. Manufacturer’s postal and electronic address d. Warnings (if applicable) e. Age suitability for children (if applicable)	a. Identity and details of the producer b. Product reference or batch number c. Warnings (if applicable)
Documentation	a. Technical documentation b. Instructions c. Test reports	a. Instructions b. Test reports
Communication channels	a. Telephone number b. Electronic address c. A specific section of the manufacturer’s website	N/A
Lab testing	a. Generally required	a. Generally required