EU GPSR Compliance Guide: Responsible Person, Labelling and Online Seller Obligations

The GPSR defines a hierarchy of who must serve as the responsible person for products from outside the EU: (1) the manufacturer, if established in the EU; (2) the importer, if the manufacturer is outside the EU; (3) an authorised representative mandated in writing by the manufacturer; (4) a fulfilment service provider (e.g., Amazon FBA, third-party logistics) established in the EU, if no other entity above is responsible. The responsible person's name, postal address, email and phone number must appear on the product, its packaging, or an accompanying document. For non-EU sellers using FBA, Amazon has indicated it will provide responsible person services for a fee — but sellers should confirm this arrangement and understand the scope.

Every consumer product placed on the EU market must display: (1) the name and contact details of the manufacturer (postal address, email, phone); (2) the name and contact details of the EU responsible person; (3) a type, batch, or serial number, or other element for product identification; (4) safety warnings and instructions for safe use, in a language easily understood by consumers in the destination country. For online sales, all of this information must be displayed in the product listing before the consumer completes the purchase — not just on the physical product. Products without proper labelling can be blocked at customs or removed from marketplaces.

Online marketplaces have specific obligations under GPSR: (1) they must cooperate with market surveillance authorities and remove listings that contain unsafe products; (2) they must operate a single contact point for authorities and consumers; (3) they must display product safety information (manufacturer, responsible person, safety warnings) in the listing; (4) they must act on Safety Gate notifications and remove or disable listings for recalled products; (5) they must use their 'best efforts' to verify that product listings contain the required manufacturer and responsible person information. For sellers, this means marketplaces may proactively block or remove listings that lack GPSR-compliant information — even if the product itself is safe.

GPSR covers all non-food consumer products placed on the EU market — new, second-hand, repaired, reconditioned, or refurbished. This includes products sold online to EU consumers from outside the EU. Exclusions: (1) medicinal products for human use (regulated by separate pharmaceutical legislation); (2) food and feed; (3) living plants and animals; (4) motor vehicles, aircraft, and maritime equipment (covered by sector-specific rules); (5) antiques. Where sector-specific EU legislation exists (e.g., Toy Safety Directive, Machinery Regulation, PPE Regulation), those rules apply alongside GPSR — GPSR fills any gaps in safety coverage. Products with CE marking are not exempt from GPSR; the CE mark covers specific directives while GPSR covers general safety.

Penalties are set by each EU member state and must be 'effective, proportionate and dissuasive' under the regulation. Examples of announced penalties: (1) Germany — fines up to €500,000 for serious violations; (2) France — up to €300,000 for legal entities; (3) Netherlands — administrative enforcement with potential product seizure. Beyond fines, enforcement actions include: mandatory product recalls, market withdrawal orders, customs blocks on imports, and marketplace listing removals. The most immediate risk for cross-border sellers is marketplace enforcement — Amazon, bol.com and other platforms have begun requiring GPSR compliance documentation before allowing products to be listed. Sellers who cannot provide the required information risk having their entire catalogue suspended.