The Complete GPSR Guide: Everything You Need to Know About EU Regulation 2023/988

In the fast-moving market of the European Union, consumer safety is a priority. To address the challenges posed by new technologies and the globalization of trade, the EU introduced Regulation (EU) 2023/988, known as the General Product Safety Regulation (GPSR). This regulation replaces the earlier Directive 2001/95/EC, establishing uniform and stricter product safety standards across the entire EU.

GPSR introduces a number of significant changes aimed at increasing consumer protection and ensuring that products available on the market are safe and compliant with the new requirements. For businesses, this means having to adapt production, import, distribution, and sales processes to the new regulations.

This guide aims to present the key aspects of GPSR, outline the obligations for different parties in the supply chain, and provide practical tips on how to prepare for the upcoming changes. Read on to learn more.

Introduction to GPSR - the General Product Safety Regulation

What is GPSR?

The General Product Safety Regulation (GPSR), or Regulation (EU) 2023/988, is an EU legal act designed to ensure a high level of health and safety protection for consumers by setting uniform safety requirements for products placed on the EU market. The regulation replaces the earlier Directive 2001/95/EC, introducing rules that are more comprehensive and better suited to today's realities.

Purpose and scope of Regulation (EU) 2023/988 (GPSR)

The main purpose of GPSR is to ensure that all products available on the EU market are safe for consumers, regardless of distribution channel or origin. The regulation covers a broad range of products, including new, used, repaired, and refurbished items made available to consumers on the EU market. Note that some products are excluded from the regulation, including medicinal products, food, feed, and certain categories covered by other specific EU legislation. You can read more about excluded products in the text of the regulation - Chapter I, Article 2, point 2.

Key changes introduced by GPSR

GPSR introduces a number of significant changes compared to the previous regulations:

Broader scope of application

The new regulation covers not only traditional physical products but also products with digital elements, such as smart devices and apps.

New obligations for economic operators

The regulation also imposes a range of additional requirements on manufacturers, importers, distributors, and online marketplace operators, aiming to ensure the safety of products sold to end users.

Stronger market surveillance

GPSR expands the powers of market surveillance authorities and introduces more effective mechanisms for monitoring and enforcing compliance.

Greater responsibility for e-commerce platforms

Operators of online marketplaces such as Allegro and Amazon, as well as providers of e-commerce platforms such as Shopify and Shoper, are required to ensure that products offered on their platforms meet GPSR requirements. This includes providing sellers with the tools they need to fulfill their own compliance obligations.

Effective date

Regulation (EU) 2023/988 was published in the Official Journal of the EU on 23 May 2023 and entered into force 20 days after that date. However, the regulation itself will only become applicable from 13 December 2024. Businesses operating in the EU market should act as soon as possible to adapt to the new requirements in order to avoid potential penalties and ensure business continuity under the applicable rules.

What key changes does EU Regulation 2023/988 (GPSR) introduce?

Scope of GPSR

GPSR covers a wide range of products, including:

• Physical products – both new and used, refurbished, or repaired.
• Digital products – including smart devices and apps, which were previously outside the scope of Directive 2001/95/EC.
• Specialized products – excluding food, medicines, and feed, which are governed by other specific EU legislation.

The regulation also introduces clear definitions of key terms such as manufacturer, importer, and distributor, eliminating previous interpretive ambiguities.

Increased documentation requirements for responsible parties

• Manufacturer: Must create detailed technical documentation for every product, including a risk analysis and a declaration of conformity.
• Importer: Must verify the manufacturer's technical documentation, which is one of the bigger logistical challenges for companies bringing goods in from outside the EU.
• Distributor: Responsible for checking product labeling and compliance with the new standards.

Who is the EU Responsible Person under GPSR?

The EU Responsible Person is an entity (an individual or a company) that ensures a product sold in the EU meets the safety requirements and regulations set out in GPSR.

This person must, among other duties, verify and retain the product's declaration of conformity, maintain technical documentation, inform market surveillance authorities of potential hazards, cooperate with those authorities, and take the necessary corrective action if non-compliance or risk is detected. Their role is essential for ensuring that consumers have access to safe products that comply with EU law, and for effective market surveillance and rapid response to hazards.

The responsible person can be the manufacturer, importer, distributor, or another entity placing the product on the EU market. This entity must be established or resident within the EU.

New labeling and safety requirements

• Mandatory markings: Every product must carry information allowing it to be clearly identified (e.g., batch number, EAN, GTIN, model, and contact details of the manufacturer/importer).
• Warnings and instructions: Products must include safety warnings and instructions for use in the languages of the countries where they are sold.

Stronger market surveillance

• Market surveillance authorities, such as trade inspectorates and consumer protection bodies, gain new powers to carry out inspections and take action, such as:
  • Withdrawing non-compliant products from the market.
  • Imposing financial penalties (up to PLN 1 million in Poland).
  • Conducting mystery-shopper checks, for example in e-commerce.

The role of marketplaces in enforcing the regulation

Platforms such as Allegro, Amazon, and Shoper are required to:

• Make it easier to add GPSR-compliant data to product listings.
• Block non-compliant listings within 3 days of notification from a surveillance authority.
• Provide communication channels for consumers and surveillance authorities.

Obligations for each group of parties under GPSR

Below we present in detail all the obligations imposed on manufacturers, importers, and distributors, as well as on e-commerce platform providers, under GPSR.

Manufacturer

Manufacturers carry the most obligations, since they are responsible for designing, producing, and placing products on the market. Key obligations:

• Creating technical documentation, including:
  • A description of the product and its intended use.
  • A risk analysis.
  • Instructions for use and safety warnings.
• Labeling products: Every product must display the manufacturer's name, address, and contact details.
• Keeping records:
  • A register of product complaints.
  • A register of product recalls and corrective actions taken.

Importer

Importers play a key role in ensuring that products brought in from outside the EU meet GPSR requirements. Importer obligations:

• Verifying the manufacturer's documentation: Checking that the product complies with EU requirements before placing it on the market.
• Labeling products: Every importer must include their own details (name, address, email) on the product or its packaging.
• Keeping documentation: Importers must retain technical documentation and be ready to provide it to surveillance authorities on request.

Distributor

Distributors have fewer obligations than manufacturers or importers, but they still play an important role in the supply chain. Their tasks include:

• Checking compliance: Making sure products carry the correct markings and comply with the regulations.
• Reporting issues: Informing manufacturers/importers of potential product hazards.

Marketplace and e-commerce platforms (Allegro, Amazon, Shopify, Shoper) and GPSR

E-commerce platforms are responsible for:

• Enabling sellers to add the required data to product listings.
• Cooperating with surveillance authorities to remove unsafe products.
• Ensuring their interfaces comply with GPSR requirements, for example by allowing warnings and instructions to be displayed in the appropriate sections of product listings.

The division of responsibilities under GPSR is meant to create a clear system of accountability that minimizes the risk of unsafe products entering the market. Implementing the regulation, however, requires cooperation among all participants in the supply chain and investment in tools and procedures that meet the new standards.

How to implement GPSR compliance in your company: a practical guide

Implementing GPSR may seem like a complex process, but with the right action plan it can be carried out smoothly and efficiently. The guide below combines best practices to offer comprehensive support at every stage.

Step 1: Identify your role in the supply chain

The first step is to precisely determine your company's role under GPSR:

• Manufacturer: If you design and manufacture products under your own brand, you bear full responsibility for their GPSR compliance. You must prepare technical documentation, a risk analysis, and ensure compliant labeling.
• Importer: If you bring products in from outside the EU, you are responsible for verifying the manufacturer's documentation and for the products' compliance with EU regulations.
• Distributor: If you handle further distribution, your task is to check that products comply with GPSR requirements and ensure they are properly labeled.

Note: the role of the responsible person

If the manufacturer is based outside the EU, a responsible person (an individual or legal entity) established within the European Union must be designated. You can take on this role yourself as the importer, or use the services of specialized providers offering this type of support.

Step 2: Audit your products and processes

1. Check documentation:
   • Make sure every product has complete technical documentation, including a risk analysis, instructions for use, and information on potential hazards.
   • Verify that safety has been considered for assembly, use, and disposal of the product.
2. Verify labeling:
   • Check that products carry the required markings, such as manufacturer details, batch numbers, warnings, and instructions for use.
3. Review your supply chain:
   • Make sure your suppliers – manufacturers and importers – meet GPSR requirements.

Step 3: Update labeling and documentation

• Labeling:
  • Add complete contact details for the manufacturer, importer, or responsible person (name, address, email, batch number).
  • Include safety warnings and instructions for use in the official languages of the countries where the products are sold.
• Technical documentation:
  • Create documentation including a risk analysis, technical specifications, and quality control procedures.
  • Keep records of complaints and product recall actions.

Step 4: Implement product data management systems

1. PIM (Product Information Management) system:
   • Centralizes product information management, making it easier to update and distribute data across marketplaces such as Allegro or Amazon.
2. ERP system:
   • Automates processes related to quality control, compliance monitoring, and complaint handling.
3. Marketplace integrations:
   • Use dedicated tools offered by e-commerce platforms, such as Allegro Sales Center, to support adding the required information.

Step 5: Train your team

• Production department: Training in risk analysis and implementing safety procedures.
• Sales department: Introduction to the new labeling requirements and creating GPSR-compliant product listings.
• Customer service department: Handling product safety complaints and product recall procedures.

Step 6: Prepare for an inspection

1. Assemble your documentation:
   Prepare all required documents, including risk analyses, product specifications, and records of complaints and corrective actions.
2. Simulate an inspection:
   Run an internal audit to check whether your processes and documents meet GPSR requirements.

Step 7: Monitor regulatory changes

1. Track regulatory updates:
   Use tools that monitor EU regulatory changes as well as guidance from national surveillance authorities.
2. Work with experts:
   Hire compliance specialists who can help you keep your processes and documentation up to date with new requirements.

Review your current GPSR compliance efforts

Implementing GPSR requires commitment and proper planning, but it can bring significant benefits. Through the use of modern tools such as PIM and ERP systems, along with team training, your company can not only meet legal requirements but also become more competitive and build customer trust.

GPSR is not just a challenge – it is also an opportunity to grow and raise standards within your company. Start implementing it today so you're ready for the changes ahead. If you need support, consult compliance experts or use ready-made tools that support this process.

GPSR in practice - examples and case studies

Example 1: A children's toy manufacturer

Situation: A company manufactures toys sold under its own brand.

Actions taken:

• Introduced new labels including batch number, manufacturer name, address, and safety warnings (e.g., choking hazard).
• Developed a risk analysis for each product, taking into account the possibility of contact with eyes or skin.

Result: The company successfully passed inspection and secured its sales in the EU market.

Example 2: An importer of consumer electronics

Situation: An importer brings in smart devices from China.

Actions taken:

• Requested full technical documentation from the Chinese manufacturer and published it on the platform where the products are sold.
• Designated a responsible person (in this case, the importer chose to take on this role).
• Added the importer's details (name, address, email) to the product packaging.

Result: The products were approved by the surveillance authorities, allowing distribution in the EU to continue.

Example 3: A clothing distributor

Situation: A distributor sells clothing manufactured in Bangladesh.

Actions taken:

• Verified that the clothing includes manufacturer information and washing instructions.
• Designated a responsible person (during discussions it turned out the clothing manufacturer already had a responsible person in the EU; the distributor contacted them and agreed on the process and division of duties).
• Informed the manufacturer of missing labeling and requested that it be completed.

Result: The products met GPSR requirements, avoiding penalties.

Example 4: A small online store on Shoper

Situation: The owner of an online store on the Shoper platform sells handmade jewelry.

Actions taken:

• Used Shoper's built-in features to assign safety information to product groups and add key information about the manufacturer, distributor, and responsible person.
• Added appropriate warnings about the risks associated with use and disposal.

Result: The products are GPSR-compliant, allowing sales to continue.

Example 5: The Allegro marketplace

Situation: Allegro has to adapt its platform to GPSR requirements.

Actions taken:

• Added mandatory fields in the seller panel, such as manufacturer data, warnings, and batch numbers.
• Automatically verifies product listings for accuracy before publication.
• Notifies sellers and audits accounts.

Result: The platform meets legal requirements, increasing trust among both consumers and sellers.

Special GPSR requirements for online sales

One of the goals of GPSR was to standardize and clarify the regulations around online sales in light of the previous directive. Under the regulation, online sales are subject to specific GPSR rules that require adapting the content presented on e-commerce platforms and in customer service systems. Below we outline the requirements for marketplace and e-commerce platforms.

Marketplaces: Allegro, Amazon, Erli

Allegro

• Mandatory fields in the seller panel:
  Allegro has introduced dedicated fields for GPSR-related information. Sellers must fill in manufacturer data, batch numbers, and safety warnings in their sales settings. The data is then automatically displayed on the product listing.
• Data accuracy checks:
  Allegro runs mystery-shopper checks to verify listings' GPSR compliance.

Amazon

• Stricter standards:
  Amazon requires all products to meet GPSR standards regardless of when they were first placed on the market. After 13 December, any listing found to be non-compliant will be blocked. Failure to keep a seller's products GPSR-compliant results in the account being suspended.
• Translated warnings:
  All instructions and warnings must be available in the languages of the countries where the product is sold. This means that if you sell in, for example, France, Germany, and the UK, you need to prepare three language versions of the documents.

Erli

• Centralized data:
  The platform allows bulk addition of safety information and warnings for many products at once.
• Support for small businesses:
  Erli has introduced an intuitive interface for editing product data.

E-commerce platforms: WooCommerce, Shopify, Shoper

On e-commerce platforms, where the seller runs their own sales channel, it is up to them to be aware of the requirements and implement them in their online store. If you run your own store, now is the time to put in place the means to complete your product information in line with GPSR.

WooCommerce

• Compliance modules:
  Plugins allow automated addition of GPSR data, such as manufacturer information, batch numbers, and warnings.
• Multi-language management:
  Thanks to integration with WooCommerce Multilingual, sellers can adapt content to the language requirements of different countries.

Shopify

• PIM functionality:
  Shopify allows product information management through integration with PIM systems, making it easier to add GPSR-compliant data.
• Automatic data assignment:
  Shopify supports bulk assignment of markings and warnings to product groups.

Shoper

• Visibility of warnings:
  Safety warnings and standards information are automatically displayed in dedicated sections of product listings.
• Support for multiple products:
  The bulk data assignment feature allows quick adaptation to GPSR requirements.

Key guidelines for online sales

• Displaying warnings on the website:
  GPSR requires all warnings and safety information to be available already at the browsing stage, for example on the product listing page.
• Languages of the target countries:
  All warnings, instructions, and information must be translated into the official languages of the countries where the products are offered.

Other additional labeling requirements for online sales

• Additional documents:
  If a product is too small to fit all the required data, additional documents may be attached, but the key information must still be easily accessible to the consumer.
• QR codes:
  Using QR codes to direct the consumer to full instructions and warnings is accepted, but it cannot replace physical labeling where required.

Integration with data management systems

To make it easier to meet GPSR requirements, companies should use product information management (PIM) systems. With them:

• Process automation:
  Technical data, warnings, and instructions can be automatically synced with e-commerce platforms.
• Efficient management:
  Keeping data current for thousands of products becomes simpler and less time-consuming.

Cooperation with marketplaces

• Responding to changes:
  Platforms such as Allegro or Amazon may introduce additional requirements, so it's important to monitor updates to their policies.
• Transferring data:
  Companies must prepare their product data in a way that makes it easy to hand over to marketplaces, speeding up the listing publication process.

GPSR - frequently asked questions (FAQ)

Does GPSR apply retroactively?

No, GPSR does not apply retroactively. Products placed on the market before 13 December 2024 can continue to be sold under the previous rules. However, products placed on the market after that date must comply with GPSR. It's worth marking goods that were placed on the market before the deadline to avoid misunderstandings during an inspection.

Which products are subject to GPSR?

GPSR covers all products sold to consumers in the EU, except those regulated by other specific rules, such as medicines, food, or feed. Digital products, such as smart devices and apps, are also subject to GPSR.

Can QR codes replace traditional product labeling?

No, GPSR requires key information such as manufacturer data, batch numbers, or warnings to be visible on the product, its packaging, or in accompanying documentation. QR codes can be used to supplement this information but cannot replace physical labeling. If a product is too small to fit all the information, it is permitted to attach documents containing the essential details.

Do I need to translate all instructions and warnings when selling in a foreign market?

Yes, GPSR requires instructions and warnings to be available in the official languages of the countries where the product is sold. For example, products sold in Germany must include information in German.

What are the main differences between a manufacturer, importer, and distributor under GPSR?

• Manufacturer: Creates technical documentation, analyzes risk, and labels products.
• Importer: Verifies the manufacturer's documentation and adds their own contact details.
• Distributor: Checks products' GPSR compliance but doesn't need to create their own documentation.

Does GPSR also apply to online sales?

Yes, online sales are subject to specific GPSR requirements. Product information such as manufacturer data, batch numbers, or warnings must be visible on product listings already at the browsing stage.

What are the consequences of failing to comply with GPSR?

Sanctions can include financial penalties (up to PLN 1 million), a ban on selling the products, and product recalls. Marketplaces such as Allegro or Amazon can also block listings that don't comply with the regulations.

Summary: GPSR is not as scary as it sounds

Regulation (EU) 2023/988, known as GPSR, marks a fundamental shift in product safety for the EU market. It covers a wide range of products and places new obligations on manufacturers, importers, distributors, and e-commerce platform operators. The rules aim to increase consumer safety and standardize requirements across the European Union.

Adapting to GPSR requirements can be a challenge, especially for small and medium-sized businesses, but proper preparation – including an audit, training, and the use of modern tools – makes it possible to meet these requirements.

Ensure GPSR compliance and keep track of your progress

• Start today: The sooner you begin adapting your products and processes to GPSR requirements, the better your chances of avoiding penalties and business disruptions.
• Use the tools available: Take advantage of PIM systems, ERP systems, and the features offered by marketplaces to streamline compliance.
• Invest in training: Train your team on the new requirements to avoid mistakes and oversights.
• Look for support: Get help from compliance experts and lawyers specializing in EU regulations.

GPSR is not just an obligation – it's also an opportunity to build customer trust and strengthen your market position. By complying with the new regulations, you contribute to improving consumer safety and boosting your company's competitiveness in a globalized market.

Wondering whether GPSR will affect your sales? Need help making sure the products you sell are compliant, regardless of the channel? We'll support you every step of the way – from full-featured websites and online stores, through effective marketing campaigns, to the tools and strategy that will drive your business forward. Fill in the form and let's get started together.