Direct answer: the EU General Product Safety Regulation (GPSR, Regulation (EU) 2023/988) has applied since 13 December 2024 and replaces the old General Product Safety Directive. Three hard requirements for Chinese exporters: (1) before placing a product on the EU market, there must be an EU-established economic operator acting as the "responsible person", whose name and contact details appear on the product/packaging/accompanying documents; (2) distance-sales (e-commerce) listings must clearly show the manufacturer, the EU responsible person, product identification and warnings; (3) safety-related accidents must be notified by the manufacturer through the Safety Business Gateway without undue delay. Manufacturers must also carry out an internal risk analysis and technical documentation, kept for at least 10 years; online marketplaces, importers and distributors have cooperation/verification duties. GPSR is not "only for big brands": platforms, customs and market surveillance can all ask for this information.
This guide is for Chinese manufacturers, cross-border sellers and EU importers/authorised representatives/fulfilment providers selling consumer products (electronics, battery-containing products, toys, household goods, tools) in the EU. Data cut-off: 8 November 2026; sources are EUR-Lex Regulation (EU) 2023/988 (consolidated 29 May 2026), the EUR-Lex summary and the EU Safety Gate. Official facts, editorial interpretation and items to confirm are kept separate. This is not legal advice.
(1) GPSR already applies (13 December 2024); without an EU responsible person, a product cannot be placed on the market. (2) Responsible-person, manufacturer, product identification and warning information must be visible to consumers/platforms/authorities; e-commerce listings are a common check point. (3) Accident reporting goes through the Safety Business Gateway; keep risk analysis/technical documentation for 10 years, not just after an incident.
Timeline: already applicable since 13 December 2024
The GPSR was adopted on 10 May 2023, published in the Official Journal on 23 May 2023 and has applied since 13 December 2024, replacing Directive 2001/95/EC (General Product Safety Directive) and Directive 87/357/EEC. It is not a new proposal; it is already being enforced. The 2026 focus is moving from "knowing about compliance" to having product pages, packaging, responsible-person arrangements and accident processes that can be checked. The Commission publishes unsafe-product alerts through Safety Gate, and market surveillance/platform takedowns can rely on that information.
| Date | Event | What it means |
|---|---|---|
| 10 May 2023 | GPSR adopted | Replaces the old GPSD |
| 23 May 2023 | Published in the Official Journal | Implementation preparation |
| 13 Dec 2024 | Applies | Responsible person, risk analysis, distance sales, accident reporting |
| Ongoing | Safety Gate/market surveillance | Alerts, takedowns, recalls, penalties |
Sources: EUR-Lex Regulation (EU) 2023/988 and the official summary; EU Safety Gate (accessed 8 November 2026). National enforcement and penalties follow national law.
Scope: consumer products, distance sales and online platforms
The GPSR covers products intended for consumers or likely to be used by consumers, including online and cross-border sales; products such as food, feed, medicinal products and medical devices covered by sector-specific rules are usually excluded, but the GPSR may still apply as a residual safety rule to aspects not covered by those rules. Roles include: manufacturer (design/manufacture/risk analysis/technical documentation/accident reporting), importer (verify responsible person/documents/marking), distributor (due diligence), authorised representative/fulfilment provider (as EU responsible person), and online marketplace (cooperate, takedown, inform). Regardless of the country of dispatch, products offered to EU consumers must meet these requirements.
| Object | Coverage | Check first |
|---|---|---|
| Consumer products | Core scope; online/offline sales | Whether intended for consumers |
| Sector-specific products | Food/medicines/medical devices usually excluded | Whether sector rules cover safety |
| Distance sales | E-commerce/catalogues/social commerce | Listing information, warnings |
| Online platforms | Specific product-safety duties | Contact point, takedown process |
| Importers/distributors | Verification/cooperation | Responsible person, marking, documents |
| Non-EU sellers | Need an EU responsible person | Contract/address |
Sources: Regulation (EU) 2023/988 Articles 1-4, 16, 19 and 22 and the official summary (accessed 8 November 2026). This is an editorial summary; exclusions/scope follow the Regulation and competent authority interpretation.
Manufacturers: risk analysis, technical documentation and 10-year retention
Article 9 requires manufacturers, before placing a product on the market, to ensure it meets the general safety requirement in Article 5 and to carry out an internal risk analysis and draw up technical documentation (at least a general description of the product and its essential safety-related characteristics; where relevant, the risk analysis/mitigation, test results and list of applicable standards). The documentation must be kept up to date and retained for 10 years after placing on the market, available to market surveillance authorities on request. Manufacturers must also ensure series-production consistency, mark their name/trade mark/contact address on the product/packaging, provide traceability information, monitor products on the market and take corrective/recall action when a risk is found.
| Duty | Key point | Checkable evidence |
|---|---|---|
| General safety | Article 5; design/manufacture to expected safety | Design file, test reports |
| Risk analysis | Internal risk analysis, identify/mitigate risks | Risk assessment, mitigation records |
| Technical documentation | Product description, characteristics, standards/tests | Technical file, version records |
| Retention | At least 10 years after placing on the market | Archive, retention schedule |
| Marking/traceability | Name/trade mark/contact address, batch/model | Label, packaging, batch records |
| Post-market monitoring | Correct/recall when risk found | Monitoring records, CAPA, recalls |
Sources: Regulation (EU) 2023/988 Articles 5 and 9 (accessed 8 November 2026). This is an editorial summary; the depth of technical documentation, testing and marking follows the Regulation, standards and competent authority requirements.
EU responsible person: no product without one
Article 16 requires an EU-established economic operator to act as the responsible person before a product is placed on the EU market, carrying out the tasks in Article 4(3) of Regulation (EU) 2019/1020 (verify technical documentation/declaration, cooperate with market surveillance, provide information) and regularly checking compliance with Article 9(2) and 9(5)-(7). The responsible person's name, registered trade mark and contact details (postal and electronic address) must appear on the product, packaging, parcel or accompanying document. For non-EU manufacturers, this is usually the importer, authorised representative or fulfilment provider; without a responsible person, the product cannot be placed on the market.
| Item | Requirement | Evidence |
|---|---|---|
| Who can act | EU-established economic operator (importer/representative/fulfilment, etc.) | Contract, mandate |
| Tasks | Verify documentation/declaration, cooperate, provide information | Responsible-person agreement, check records |
| Marking | Name/trade mark/postal + electronic address | Product/packaging/accompanying document |
| Ongoing checks | Regular checks against Article 9(2), 9(5)-(7) | Check records |
| No responsible person | Cannot place on the market | Takedown/customs/penalty risk |
Sources: Regulation (EU) 2023/988 Article 16 and Regulation (EU) 2019/1020 Article 4(3) (accessed 8 November 2026). This is an editorial summary; arrangements, contracts and marking follow the Regulation and competent authority requirements.
Distance sales: what the e-commerce listing must show
Article 19 requires that, where products are made available online or through other distance sales, the offer clearly and visibly states at least: the manufacturer's name/registered trade mark and postal/electronic address; where the manufacturer is not established in the EU, the name/address of the EU responsible person; product identification information (including a picture, type and other identifiers); and any warning/safety information required on the product, packaging or accompanying document (in a language easily understood by consumers in the target Member State). This applies to standalone stores, marketplace listings, social commerce and cross-border parcels; platforms may require sellers to complete these fields, and missing information can lead to delisting.
| Field | Content | Common problem |
|---|---|---|
| Manufacturer | Name/trade mark, postal + electronic address | "Made in China" alone is not enough |
| EU responsible person | Name/address for non-EU manufacturers | Inconsistent with importer/representative |
| Product identification | Picture, type, model/other identifier | Picture does not match product/variant |
| Warnings/safety | Target Member State language, required information | English/Chinese only |
| Traceability | Batch/model, contact | Listing and packaging inconsistent |
Sources: Regulation (EU) 2023/988 Article 19 (accessed 8 November 2026). This is an editorial summary; platform fields, language and presentation follow the Regulation, platform rules and competent authority requirements.
Accident reporting, recalls and Safety Gate
Article 20 requires manufacturers to notify, through the Safety Business Gateway, an accident caused by a product placed or made available on the market to the market surveillance authority of the Member State concerned without undue delay after becoming aware; the report covers product identification, the accident and measures taken/planned. When a product is found unsafe, manufacturers/importers/distributors must take corrective action and, where necessary, recall/withdraw (Articles 35/36) and communicate through Safety Gate and with consumers. Online marketplaces (Article 22) must designate a contact point, cooperate with authorities, take action on unsafe products (takedown/disable access) and inform consumers/authorities. Safety Gate is the EU alert system for unsafe products, and regulators/platforms rely on its information.
| Stage | Requirement | Evidence |
|---|---|---|
| Accident report | Without undue delay via Safety Business Gateway | Report copy, timeline |
| Correct/recall | Correct/recall/withdraw unsafe products | Recall plan, notices |
| Consumer communication | Clear, timely, target language | Notices, email/SMS |
| Platform cooperation | Contact point, takedown, inform | Platform tickets, takedown records |
| Authority cooperation | Provide documents, samples, information | Response records, evidence pack |
Sources: Regulation (EU) 2023/988 Articles 20, 22, 35 and 36 and EU Safety Gate (accessed 8 November 2026). This is an editorial summary; reporting fields, deadlines and recall procedures follow the Regulation, implementing acts and competent authority requirements.
90-day implementation checklist
Use the first 90 days to connect the product list, EU responsible person, listing/label information, risk analysis/technical documentation and accident/recall process. The order is: product scope, responsible person, listing/labels, risk/documentation, accident/recall, evidence and drills.
| Phase | Action | Output |
|---|---|---|
| Weeks 1-2 | Inventory consumer products sold in the EU, channels and existing responsible person | Product list, scope |
| Weeks 2-3 | Confirm/appoint an EU responsible person; check mandate and tasks | Responsible-person agreement, contact details |
| Weeks 3-5 | Update listings, packaging and accompanying documents with manufacturer/responsible person/warnings | Listing template, label draft |
| Weeks 5-7 | Carry out internal risk analysis and technical documentation; retain 10 years | Risk assessment, technical file |
| Weeks 6-8 | Build Safety Business Gateway accident reporting and recall SOP | Report template, recall plan |
| Weeks 8-10 | Align with platforms/importers/fulfilment on takedown and cooperation | Platform contact, ticket process |
| Weeks 10-12 | Run an accident/recall drill and evidence review | Drill report, remediation list |
Editorial implementation advice, not an official template; specific scope, responsible-person arrangements, documentation, reporting and recall follow the GPSR, implementing acts and competent authority requirements.
FAQ
Does the GPSR apply now?
Yes. It has applied since 13 December 2024 and replaces the old General Product Safety Directive. The 2026 focus is making the responsible person, listing/label information, risk analysis and accident process checkable.
Which products are covered?
Products intended for consumers or likely to be used by consumers, including online/offline sales. Food, feed, medicines, medical devices and similar products covered by sector-specific rules are usually excluded, but the GPSR may apply as a residual safety rule to aspects not covered. Check the product and sales model.
What is the EU responsible person?
An EU-established economic operator carrying out the tasks in Article 4(3) of Regulation (EU) 2019/1020 (verify technical documentation/declaration, cooperate with market surveillance, provide information) and regularly checking compliance with the relevant Article 9 requirements. Its name/trade mark/contact details must appear on the product/packaging/accompanying document.
Can we sell without an EU responsible person?
No. Article 16 requires an EU responsible person before placing the product on the EU market; without one, the product cannot be placed on the market and may face platform takedown, customs detention or penalties.
What must a distance-sales listing show?
The manufacturer's name/trade mark and postal/electronic address; the EU responsible person's name/address where the manufacturer is outside the EU; product identification (picture, type, other identifiers); and required warnings/safety information in the target Member State language. This applies to standalone stores, marketplaces and social commerce.
How are accidents reported?
After becoming aware of a safety-related accident, the manufacturer notifies the relevant Member State market surveillance authority through the Safety Business Gateway without undue delay, covering product identification, the accident and measures taken/planned. Unsafe products must also be corrected/recalled/withdrawn and communicated.
What are online marketplaces required to do?
Article 22 requires online marketplaces to designate a product-safety contact point, cooperate with market surveillance, take action on unsafe products (takedown/disable access) and inform consumers/authorities. Platforms also require sellers to provide responsible-person/manufacturer/warning information in listings.
What are the fines?
The GPSR requires Member States to set effective, proportionate and dissuasive penalties; specific amounts/procedures follow national law. Beyond fines, products may face takedown, recall, customs detention and platform bans.
Research method and limitations
This article separates "official facts" from "editorial advice": the GPSR's adoption/publication/application dates, scope, manufacturer duties, responsible person, distance sales, accident reporting, recalls and platform duties come from EUR-Lex Regulation (EU) 2023/988 (consolidated 29 May 2026), the EUR-Lex summary and the EU Safety Gate (accessed 8 November 2026). The 90-day list and "evidence/action" columns are editorial.
Eight limitations: (1) this is not legal advice; (2) national market surveillance, penalties and platform rules are not checked country by country; (3) product exclusions/sector-specific overlaps are highly product-specific; (4) responsible-person arrangements, mandates and marking need contract/authority-specific review; (5) accident-report fields/deadlines follow the Safety Business Gateway and authorities; (6) not all recall/consumer-communication details are covered; (7) the article does not map every interaction with CRA/machinery/battery/toys rules; (8) the Regulation/guidance may update, so recheck the official pages before publishing.
Sources and basis
- EUR-Lex, Regulation (EU) 2023/988 (consolidated 29 May 2026): eur-lex.europa.eu/eli/reg/2023/988/oj. Articles 5, 9, 16, 19, 20, 22, 35 and 36. Accessed 8 November 2026.
- EUR-Lex, General product safety regulation (2023) - official summary: eur-lex.europa.eu/EN/legal-content/summary/general-product-safety-regulation-2023.html. Key points, application date and main duties. Accessed 8 November 2026.
- European Commission, Safety Gate: ec.europa.eu/safety-gate. Unsafe-product alerts, recalls and market surveillance information. Accessed 8 November 2026.
Data cut-off 8 November 2026; based on official pages and the Regulation; not legal advice; specific obligations follow the GPSR, implementing acts, platform rules and competent authority requirements.