The EU General Product Safety Regulation requires importers buying from China to follow the rules. That’s why, if you open your seller account and realize that forty listings are gone, the offers could have been deactivated because no EU responsible person is shown on the product page. Your stock sits in a fulfilment centre near Malaszewicze, your supplier is in Ningbo, and the sales manager there replies within an hour: “No problem, we have a CE certificate.” That fixes nothing, because the platform is not asking about CE. It is asking about GPSR, Regulation (EU) 2023/988, the rule that decides whether a consumer product may legally exist on the EU market at all. Importers buying from China usually meet it only after a listing is pulled or customs holds a pallet.
What is GPSR and what did it replace?
GPSR is the EU General Product Safety Regulation, Regulation (EU) 2023/988, and it has been in force since 13 December 2024. It was adopted on 10 May 2023, published in the Official Journal on 23 May 2023, and entered into force on 12 June 2023, with an 18-month run-up. It repealed the old General Product Safety Directive 2001/95/EC and Council Directive 87/357/EEC on products that imitate food.
Tip: goods placed on the market before 13 December 2024 under Directive 2001/95/EC can still be sold.
GPSR is a safety net. It sets the general safety requirement for consumer products with no sector-specific EU legislation of their own: furniture, textiles, kitchenware, candles, jewellery, and most of the long tail of housewares arriving from Shenzhen and Yiwu.
Does GPSR apply to products that already have CE marking?
Partly, and this is where most importers get it wrong. Article 2 says that for products covered by EU harmonisation legislation, Chapter II and Chapter III Section 1 do not apply to the risks that legislation already covers. So for a CE-marked power supply or a toy, the Article 16 responsible person rule in GPSR is switched off.
It is switched off because an identical duty already applies through Article 4 of Regulation (EU) 2019/1020, in force since 16 July 2021. You do not escape it; you meet it under a different article. Chapter III Section 2 (Articles 19 to 21), Chapter IV (marketplaces), Chapter VI (Safety Gate) and Chapter VIII (Articles 33 to 39 on consumer information, recall notices and remedies) still apply to CE marked goods. If you are working out which products need CE marking, settle that first, and read our guide to CE marking when importing from China.
Who can be your responsible person in the EU?
Article 16 says a product may not be placed on the Union market unless an economic operator established in the Union is responsible for the tasks in Article 4(3) of Regulation (EU) 2019/1020. That operator can be an EU manufacturer, an EU importer, an authorised representative appointed in writing by the manufacturer, or an EU fulfilment service provider where none of the others exists.
If you buy from a Chinese factory and import into the EU yourself, you are the responsible person. Nothing to appoint, nobody to hire. The trap is the other model: you dropship, your supplier ships directly to the end customer, or you are a UK or US company selling into the EU without an EU entity. Then somebody inside the Union has to hold the file and answer the authority, taking real exposure for a product they never made. They verify that the technical documentation exists, keep it and the test reports available for authorities, flag a product that presents a risk, and cooperate on corrective action. Their name and contact details go on the product, the packaging, the parcel or an accompanying document.
No EU responsible person means the product cannot legally be placed on the market, no matter how good the factory's paperwork looks.
Selling in the EU and GPSR
What documentation do you have to hold to comply with GPSR?
Article 9(2) requires an internal risk analysis and technical documentation with at least a general description of the product and the characteristics relevant to its safety. Article 9(3) says you keep that file available to market surveillance authorities for 10 years after the product is placed on the market.
There is no EU form you must use, but the Commission published GPSR guidelines on 19 November 2025 (C(2025) 7699 final) with a practical model for the risk analysis. They also confirmed that standards adopted under Directive 2001/95/EC keep their presumption of conformity. A workable dossier holds the product description and photos, the bill of materials, the risk analysis, the test reports and the user manual and warnings.
What has to be on the product and the packaging?
Article 9(5) requires a type, batch or serial number or another element identifying the product, easily visible and legible for consumers, or on the packaging if the product is too small. Article 9(6) requires the manufacturer’s name, registered trade name or trade mark, and postal and electronic address, plus a single contact point. Importers add their own name and address under Article 11.
“Electronic address” means an email address, or a specific section of your website where a consumer can contact you directly. While you are redoing artwork, line up your other labelling duties, because PPWR packaging compliance and extended producer responsibility registration hit the same box at the same time.
What must an EU online listing show?
Article 19 requires distance sales offers to show four things clearly: the manufacturer’s name, registered trade name or trade mark plus postal and electronic address; the name, postal and electronic address of the responsible person where the manufacturer is not EU established; details identifying the product, including a picture, its type and any other identifier; and any warnings or safety information, in a language easily understood by consumers in that Member State.
Article 22 puts the matching duty on the platform. Marketplaces must register a single contact point on the Safety Gate Portal, build the fields that let traders supply the Article 19 information, and act on a Safety Gate order within two working days. That clock is why listings vanish before anyone calls.
When do you have to report an accident?
Article 20 requires you to notify an accident caused by your product through the Safety Business Gateway, the system set up under Article 27. The threshold is death or serious adverse effects on health and safety. Temporary, non-serious effects do not trigger it. You notify without undue delay once you become aware.
Enforcement is not theoretical. Products of Chinese origin accounted for 2,006 alerts, about 43% of the total in 2025, with toys at 16% of notifications and electrical appliances at 11%.
What happens in a recall?
Article 36 requires a written recall notice with defined content, and bans language that plays the risk down, so no “voluntary”, “precautionary”, “discretionary”, “in rare cases” or claims that no accidents have occurred. Implementing Regulation (EU) 2024/1435 gives a template, though using it is not obligatory if your own version carries the required content.
Article 37 is the one that costs money. You must offer the consumer at least two of three remedies: repair, replacement or an adequate refund. A single remedy is allowed only where the others would be impossible or disproportionate, and you cannot tell the consumer to repair or dispose of the product. Price this in before you place a 20,000-piece order, not after.
What should you demand from your Chinese supplier when importing to the EU?
Ask for the inputs to your own file, not for certificates. Outside harmonised sectors there is no GPSR certificate for anyone to issue. What you need is the bill of materials with named substances, component test reports from a laboratory you can verify, production photos, and a signed statement of what the product is made of.
Then check that the reports are real. Fake and recycled lab reports are common, and one issued for a different model is worthless in an authority’s hands. Learn how to read a CE declaration and a test report so you can spot one copied from another buyer’s order. Put the labelling in the purchase order too: batch number, your name and address as importer, your electronic address, warnings in the right languages. If it is not in the PO, it will not be on the carton.
A supplier who answers a GPSR question with “we have CE” is telling you they do not know the difference between a conformity route for a regulated product category and a general safety obligation that sits on you.
Most GPSR problems trace back to a decision made long before the container was loaded: the wrong supplier, an unverified test report, a label nobody checked. If you want the file to hold up when an authority asks, start at the factory with proper quality control in China.
Frequently asked questions about GPSR
What is GPSR?
GPSR is Regulation (EU) 2023/988, the EU General Product Safety Regulation. It sets baseline safety, documentation and traceability rules for consumer products sold in the EU and acts as a safety net for goods that no sector-specific EU law covers. It replaced the old General Product Safety Directive 2001/95/EC and has applied since 13 December 2024.
When did GPSR come into force?
GPSR has applied since 13 December 2024. Regulation (EU) 2023/988 was adopted on 10 May 2023, published in the Official Journal on 23 May 2023 and entered into force on 12 June 2023, after which an 18-month transition period ran. Article 51 allows goods already placed on the market before 13 December 2024 under Directive 2001/95/EC to continue being made available.
Who needs an EU responsible person?
Every consumer product placed on the EU market needs an economic operator established in the Union. Article 16 of GPSR bars placing a product on the market unless such an operator handles the tasks in Article 4(3) of Regulation (EU) 2019/1020. Where the manufacturer is Chinese, the role falls to the EU importer, an authorised representative or an EU fulfilment service provider.
Does GPSR apply to products that already have CE marking?
GPSR applies to CE-marked products, but only in part. Article 2 disapplies Chapter II and Chapter III Section 1 to risks already covered by EU harmonisation legislation, so the Article 16 responsible person duty is met instead under Article 4 of Regulation (EU) 2019/1020, in force since 16 July 2021. The distance selling, marketplace, Safety Gate and recall rules still apply.
What happens if you sell in the EU without a responsible person?
The product cannot lawfully be placed on the EU market, and marketplaces will remove the listing. Under Article 22 of GPSR, online marketplaces must let traders display responsible person details and must act on a Safety Gate order within two working days. Customs can stop the goods, and Article 44 leaves the level of penalties to each Member State.
If you need more guidance on importing to the EU, feel free to reach out to us!