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GPSR on marketplaces: new EU product safety obligations
Daniel Pawłowski · Amazonway · · ok. 10 min read
GPSR is the EU General Product Safety Regulation, which since 13 December 2024 has replaced the previous directive and now covers practically every non-food consumer product sold in the EU, including used and refurbished goods. For a marketplace seller it comes down to five things: you need a responsible economic operator established in the EU, the manufacturer's contact details on the product or its packaging, warnings and instructions in the language of every country you sell in, technical documentation with a risk assessment, and the same information visible in the online listing. Gaps in that data are picked up automatically by the platforms, which deactivate listings long before any authority gets in touch. Below we break each obligation down, show how Amazon, Allegro and Kaufland enforce them, and give you a checklist to tick off for every listing.
Legal position and platform requirements as of 29 July 2026. This text is not legal advice. We base it on Regulation (EU) 2023/988, official European Commission material, the Polish authorities UOKiK and biznes.gov.pl, and the documentation of Amazon, Allegro and Kaufland; every claim carries its source. Rules, the classification of your product and platform requirements do get updated, and assessing a specific case may require a lawyer's opinion. Before you decide anything, confirm the details in the current version of the sources and in your own account panel.
What GPSR is and when it started to apply
GPSR stands for General Product Safety Regulation, that is Regulation (EU) 2023/988 of the European Parliament and of the Council of 10 May 2023 on general product safety. It has applied since 13 December 2024 and repealed Directive 2001/95/EC on general product safety as well as Directive 87/357/EEC on products imitating food.
Two things set it apart from the previous legal position, and those two are what generate work on your side:
- It is a regulation, not a directive. It applies directly in every member state, with no need to transpose it into national law. So there is no "local version of GPSR" that would be more lenient.
- Online selling is addressed head-on. The regulation places obligations not only on manufacturers and importers, but also on providers of online marketplaces, and it puts an online listing on the same informational footing as a product on a shelf.
The scope is broad: it covers consumer products that are new, used, repaired and refurbished, sold online and offline. Outside its scope are, among others, medicines, food and feed, live plants and animals, aircraft and antiques (official EUR-Lex summary).
Who GPSR applies to: four roles, one responsibility
The most common misconception goes: "I only resell, so it is the manufacturer's problem." GPSR assigns obligations to every link in the chain, and your role is determined by what you actually do with the product, not by what your supplier contract says. The definitions from Article 3 of the regulation, in practical shorthand:
| Role | Who you are under GPSR | What it means for a marketplace seller |
|---|---|---|
| Manufacturer | You make the product, or have it designed or made, and sell it under your own name or trademark | Private label and own-brand always means the manufacturer role, even if the factory is in Asia. The full set of obligations sits with you |
| Importer | You are established in the EU and place a product from a third country on the market | You buy from China and sell in the EU, so you are an importer with your own set of obligations, including your details on the product |
| Distributor | You are in the supply chain, you are neither manufacturer nor importer, and you make the product available on the market | Classic resale. You have to check that the product carries the required details and information before you list it |
| Marketplace provider | You operate an interface that allows consumers to conclude contracts with traders | This is the role of Amazon, Allegro and Kaufland, not yours. But it is exactly why the platform must demand data from you and remove a listing without it |
Watch out for the role jump. If you substantially modify a product in a way that affects its safety, or you sell it under your own brand, you are treated as the manufacturer (biznes.gov.pl, in Polish). Repackaging a bundle, swapping the instructions, adding your own logo: any one of these can move you from distributor to manufacturer, along with all the documentation that entails.
Seven obligations you have to close out
Below the obligations are ordered practically: from what a product cannot be on the market without, to what the customer sees in the listing.
1. A responsible economic operator established in the EU
A product may not be placed on the EU market unless there is an economic operator established in the Union responsible for the safety-related tasks for that product. That role can be filled by a manufacturer established in the EU, an importer, an authorised representative or a fulfilment service provider (official EUR-Lex summary, biznes.gov.pl).
The practical consequences in two typical situations:
- You are an EU company importing from Asia. Usually you are that operator yourself, because you are the importer. You do not have to hire anyone, but you do have to put your details on the product and in the listing.
- The manufacturer is outside the EU and sells through you or directly. Then a designated responsible person in the EU is needed, with a current agreement in place. Kaufland puts it plainly: manufacturers outside the EU are required to appoint a responsible person in the EU (Kaufland Seller University).
2. The manufacturer's contact details on the product or packaging
On the product, or where that is not possible on the packaging or in an accompanying document, you must show: the manufacturer's name, registered trade name or registered trademark, plus a postal and an electronic address. The email address is the new part, and the easiest to forget, because old labels carried only a postal address. The importer adds its own details on top of that.
3. Warnings and instructions in the language of the country of sale
The product must come with clear instructions and safety information in a language easily understood by consumers, as determined by the member state. For sales in Poland, UOKiK points explicitly to the Polish language. Sell in five markets and you need five language versions, and not machine translation output but text a consumer can actually understand.
4. Safety assessment and technical documentation
The manufacturer carries out an internal risk analysis and draws up technical documentation containing at least a general description of the product and its essential characteristics relevant to assessing safety, an analysis of the hazards, and a list of the standards applied. The documentation is kept for 10 years from the product being placed on the market and made available to market surveillance authorities on request. An equivalent retention obligation rests on the importer.
This is the most frequently skipped part, because neither the customer nor the platform ever sees it. Until an inspection.
5. Traceability: batch, model, images
The product must carry a type, batch or serial number, or another element visible and legible to the consumer that allows it to be identified. This is not the same as an EAN. The EAN identifies a commercial variant; a batch number identifies a specific production run, so in the event of a recall it is clear which units are affected. For identification in an online listing, a product image is required as well.
6. Complaints, accidents and the Safety Business Gateway
GPSR requires consumers to have a genuine channel for submitting complaints and reporting accidents, and you have to act on those reports. If you establish, or have reason to believe, that a product you have placed on the market is dangerous, you inform consumers immediately and report the matter to the authorities through the EU Safety Business Gateway portal (UOKiK, biznes.gov.pl). Product-related accidents are reported through the same channel.
It is worth knowing the other side of this obligation, because it hits margin directly: in a product recall the consumer must be offered at least two of the three options, that is repair, replacement or a refund (official EUR-Lex summary). A recall is not just the cost of reverse logistics, it is also a choice you do not get to make alone.
7. Information obligations in the online listing
This is the obligation that really decides whether your listing stays alive. Distance selling has to give the buyer the same information as a product on a shelf. UOKiK lists the minimum: data identifying the product, the manufacturer's details, and safety information and warnings. The expanded version from biznes.gov.pl: the listing contains the manufacturer's details (name, registered trade name or trademark, postal and electronic address), and where the manufacturer is not established in the EU also the details of the responsible person, a description and an image of the product, plus any warnings and safety information.
How the platforms enforce GPSR in practice
Here is the crux for a seller: platforms verify data faster and harder than authorities do, because they carry their own legal obligation and they can automate it. The enforcement pattern looks the same everywhere: dedicated compliance fields in the product record, validation on save, listing deactivation when data is missing.
| Platform | What it requires | What happens when data is missing |
|---|---|---|
| Amazon (EU stores: DE, FR, IT, ES, NL, BE, SE, PL) | An EU responsible person, the manufacturer's contact details, PDF files or images with warnings and safety information, or a confirmation that none are required | Amazon announced that after 13 December 2024 it would deactivate non-compliant listings, including those with incorrect data or an expired agreement; the status is visible on the Account Health page |
| Allegro | A person responsible for the product's compliance with EU rules, plus safety information (text, attachment or a declaration that there is none); single and bulk editing, including via API | Gaps are filled in within the listing; Allegro released bulk editing precisely so this can be done across a large assortment |
| Kaufland | Contact details for the manufacturer and the EU responsible person, a product identifier (EAN, model number, image), warnings in the language of the country of sale | Kaufland states plainly that listings without this information are switched off from sale |
Sources: Amazon developer docs, 14 October 2024; Allegro developer portal, 9 December 2024; Kaufland Seller University.
If you run an account on Amazon, GPSR is worth monitoring alongside your other metrics: compliance gaps show up in the same place as other listing problems, that is on the Account Health page. When you move onto another channel, the same data set has to be prepared again in that platform's format, which we cover in the context of entering Kaufland.
What blocks listings most often
Below is a list of the gaps that recur most often in our own work tidying up assortments for GPSR. This is an Amazonway observation, not a quotation from the rules: the order reflects how often they come back, not their legal weight.
- No manufacturer email address. The label carries a postal address from the days of the old directive, while the regulation also requires an electronic address. Formally a detail; practically, an empty field and failed validation.
- Warnings in one language only. One set of files uploaded to every market. A listing in Germany needs a German version, a listing in France a French one.
- An expired or out-of-date agreement with the responsible person. The data stays in the listing, the legal basis disappears. Amazon names expired agreements explicitly as a reason for deactivating listings.
- No deliberate "no warnings" declaration. Some products carry no warnings at all and that is fine, but platforms expect confirmation of that fact rather than an empty field. An empty field reads as missing data.
- Warnings dumped into the description or into sales graphics. This is the costliest mistake, because it looks done. Compliance data goes into dedicated fields and attachments. A+ Content is no substitute, because it is not read as a compliance field.
- A mismatch between the product record and the label. The listing says one thing, the packaging another, the documentation a third. During an inspection that is a worse position than missing data.
- No control over the product record. If your brand is not enrolled, other sellers' edits can overwrite your compliance data. That is why, for own brands, Amazon Brand Registry is part of data hygiene, not just a marketing tool.
The practical conclusion: GPSR is above all a product data management problem, not a legal one. At a few hundred SKUs across several channels, filling fields in by hand ends in mismatches, which is why we keep compliance data in a single source of truth and push it to the channels by feed. The technical side of that setup, one source catalogue mapped to each platform's format, is run by our sister brand Seedlight as part of product feed automation.
GPSR compliance checklist, per listing
A set to tick off for every listing, in the order it actually falls into place. The first four points you do once per product; the rest per market and per channel.
- Role established. You know whether you are the manufacturer, importer or distributor for this product, and whether anything (branding, repackaging, modification) moves you up a level.
- EU responsible operator named, with a current agreement and its expiry date in the calendar.
- Technical documentation ready: product description, risk analysis, list of standards; archive set up for 10 years.
- Label and packaging checked: manufacturer name, postal and electronic address, type, batch or serial number.
- Warnings and instructions translated into the language of every country where the listing will be visible.
- Images ready: the product plus legible photos of the label and warnings, at a quality that makes them readable.
- Compliance fields in the product record filled in on each platform separately (manufacturer, responsible person, warnings or a deliberate "not applicable").
- Consistency verified: the product record, the label and the documentation all say the same thing.
- The complaints and reports channel works and somebody actually staffs it.
- Accident procedure written down: who reports through the Safety Business Gateway, within what time, and who informs customers.
- Recall scenario costed, bearing in mind that the consumer gets a choice of at least two options.
- Data held in one source and sent to the channels by feed, not typed by hand into every panel.
- A recurring review in the calendar: new SKUs, new markets, expiring agreements, changes to platform requirements.
Consequences of gaps: two different risks
It is worth separating two things, because they move at different speeds and on a different scale.
Risk one, fast: the platform. A listing without the required data is deactivated or switched off from sale. It happens automatically, within days, with no proceedings and no warning per individual SKU. The cost is immediate: zero sales from a blocked listing, loss of history and ranking, and where the problem is broader, an effect on account health too.
Risk two, slower: market surveillance. The regulation leaves it to member states to set penalties. In Poland that was done by the Act of 7 November 2025 on the supervision of general product safety (Dz.U. 2025 item 1826), which came into force on 3 January 2026. Supervision is exercised by the President of UOKiK, the Polish competition and consumer protection authority, together with the regional inspectors of the Trade Inspection. The act provides for administrative fines and, according to a commentary by PARP, the highest of them reach 1,000,000 PLN (for manufacturers, importers and platform providers), with a ceiling of 500,000 PLN indicated for distributors. These are the amounts under the Polish implementing act; other member states set their own. Check the specific legal basis and the amount that would apply to your situation in the text of the act or with a lawyer, because the catalogue of infringements is extensive and differs for each role.
So the practical order is the opposite of what intuition suggests: you will hear about missing data from the platform first, not from an authority. The good news is that the same work closes both risks at once.
What GPSR does not cover, and what not to confuse it with
Three boundaries worth knowing, so you neither duplicate work nor miss a different obligation.
- GPSR does not replace sector-specific rules. Toys, electronics, machinery and personal protective equipment have their own harmonised requirements and CE marking. GPSR is a safety net that complements those rules and steps in where they do not exist. Meeting GPSR does not exempt you from CE, or the other way round.
- GPSR is not EPR and it is not VAT. Packaging registration through LUCID in Germany, UIN numbers in France, WEEE and battery registrations, plus VAT and OSS reporting are entirely separate obligations, even though platforms verify them just as automatically. We break them down in our VAT, OSS and EPR service.
- GPSR does not apply in Great Britain. It is EU law, so it covers sales to consumers in the EU. According to the UK government service business.gov.uk, the responsible operator must be established in the EU or in Northern Ireland, and UK companies selling into the EU have to meet GPSR like any other seller. England, Scotland and Wales have their own product regime, which is one of many reasons why selling on Amazon.co.uk after Brexit counts as a separate exercise.
How Amazonway helps with this
GPSR rarely comes apart on the law. It comes apart on data: a few hundred SKUs, several language markets, several panels using different names for the same fields, and one agreement with a responsible person whose expiry date nobody remembers. At Amazonway this layer is part of the Waypoint framework stage called WP 03 Launch: we take the formalities and the product data on ourselves, together with VAT, OSS and EPR, so sales do not stall over a missing field in a product record. If the accounts are to be run on an ongoing basis, the same scope sits inside marketplace account management.
An honest caveat: we are not a law firm and we do not issue legal opinions, and classifying a product or assessing risk in difficult cases needs a lawyer or a testing body. Nor do we promise sales results, because those depend on the product, price and competition. What we are accountable for is data that is complete, consistent and deployed in every channel before the platform is the first to ask.
FAQ: GPSR on marketplaces
Since when has GPSR applied?
Regulation (EU) 2023/988 has applied since 13 December 2024 and replaced Directive 2001/95/EC and Directive 87/357/EEC. In Poland, supervision rules and penalties are additionally governed by the Act of 7 November 2025 on the supervision of general product safety, in force since 3 January 2026.
Does GPSR apply to me if I only resell other people's products?
Yes, in the distributor role. You have to check that the product carries the required manufacturer details, markings and instructions before you make it available to consumers, and you may not list a product you know to be dangerous. If you sell under your own brand or substantially modify the product, you move into the manufacturer role with the full set of obligations.
Who can be the responsible person in the EU?
An economic operator established in the Union: a manufacturer established in the EU, an importer, an authorised representative or a fulfilment service provider. An EU company importing goods from a third country usually fills the role itself as the importer, so it does not have to hire anyone, but it does have to put its details on the product and in the listing.
What language do warnings and instructions have to be in?
A language easily understood by consumers, as determined by the member state of sale. For Poland, UOKiK points to Polish. In practice that means a separate language version for every market where the listing is visible.
Why did Amazon deactivate my listings over GPSR?
Most often because the product record is missing one of three elements: the EU responsible person's details, the manufacturer's contact details, or the files with warnings and safety information (or a confirmation that none are required). Amazon announced it would deactivate non-compliant listings after 13 December 2024, including those with incorrect data or an expired agreement. The compliance status is visible on the Account Health page.
What is the Safety Business Gateway?
It is the EU portal through which economic operators report dangerous products and product-related accidents to surveillance authorities. It is part of the Safety Gate system. Reporting does not release you from the obligation to inform consumers.
Does GPSR apply in the United Kingdom?
Not in England, Scotland and Wales, because it is EU law. It applies to sales to consumers in the EU, and the responsible operator must be established in the EU or in Northern Ireland. UK companies selling into the EU meet GPSR on the same terms as any other seller.
Sources
- Regulation (EU) 2023/988 on general product safety, EUR-Lex: the text of the regulation and the official summary
- UOKiK, traders' obligations on product safety (in Polish)
- biznes.gov.pl, general product safety requirements (in Polish, updated 12 January 2026)
- Act of 7 November 2025 on the supervision of general product safety (Poland), Dz.U. 2025 item 1826
- Amazon, GPSR in Account Health (14 October 2024)
- Allegro, GPSR: responsible person and product safety information (9 December 2024, in Polish)
- Kaufland Global Marketplace, GPSR in Seller University
- PARP, commentary on GPSR and the new Polish supervision act, including the fine ceilings (in Polish)
- business.gov.uk, EU General Product Safety Regulation
Find out what your listings are missing
GPSR does not call for legal genius, just complete data in every channel and somebody watching the deadlines. If you have a few hundred SKUs across several markets and no idea where the holes are, start with a review: we will show you which listings are exposed to deactivation and in what order to fix them.