1. What Is the GPSR?
The General Product Safety Regulation (GPSR) — officially Regulation (EU) 2023/988 — is the new EU-wide product safety regulation. It replaces the former Directive 2001/95/EC (General Product Safety Directive, GPSD), which served as the framework for general product safety in Europe for over 20 years.
The GPSR came into full effect on December 13, 2024 and has since applied directly in all EU member states. Unlike the old GPSD, the GPSR does not need to be transposed into national law: it is a regulation, not a directive, and is therefore directly binding.
Important
The GPSR applies to all consumer products placed on the EU market — regardless of whether they are sold online or offline. This explicitly includes products sold through online marketplaces like Amazon.
Why does the GPSR exist? The EU Commission introduced the regulation because commerce has fundamentally changed since 2001. E-commerce, third-party sellers from non-EU countries, and online marketplaces have allowed millions of products to reach the European market without adequate safety checks. The GPSR specifically addresses these gaps.
The core objectives of the GPSR are:
- Clearer responsibilities for all economic operators in the supply chain — manufacturers, importers, distributors, and online marketplaces
- Stronger traceability of products through mandatory contact details of a responsible person in the EU
- Modernized risk assessment that also considers cybersecurity risks and risks from connected products (Art. 6(2))
- Better protection of vulnerable groups, particularly children, elderly people, and people with disabilities (Art. 6(2)(d))
- Harmonized market surveillance with the Safety Gate/RAPEX system for rapid EU-wide alerts
For Amazon sellers, the GPSR is particularly relevant because it defines specific obligations for online commerce — including requirements for product pages that directly affect your Amazon listing.
2. What Changes for Amazon Sellers?
The GPSR introduces four key changes that directly affect every Amazon seller:
2.1 Mandatory Information on the Listing
According to Art. 19(3) GPSR, the following must be clearly and visually displayed for every distance selling offer (including Amazon listings):
- Name, registered trade name, or registered trademark of the manufacturer
- Postal address of the manufacturer
- If the manufacturer is not based in the EU: Name and address of the responsible person in the EU (Authorized Representative)
- Images of the product that allow identification (type, batch, serial number)
- All warnings or safety information relevant to the consumer
Amazon has introduced dedicated fields in Seller Central for this purpose. Under Compliance Information in the listing attributes, you can enter this data. For many categories, these fields are already mandatory — if the information is missing, the listing will be suspended.
2.2 Responsible Person in the EU
Art. 16 GPSR introduces the concept of the Responsible Person. If you as a manufacturer or importer are based outside the EU, you must designate a responsible person in the EU. This person:
- Must have a physical address in the EU
- Is the point of contact for market surveillance authorities
- Must be able to provide technical documentation upon request
- Must be able to demonstrate that the product meets safety requirements
Practical Tip
If you are based in the EU and sell your own products, you are automatically the Responsible Person. A separate designation is only necessary if the manufacturer is based outside the EU — for example, with private-label products manufactured in China.
2.3 Technical Documentation
The GPSR requires in Art. 9 and Art. 35 that manufacturers conduct an internal risk analysis and document it. This documentation must:
- Contain a general description of the product and its essential characteristics
- Include an analysis of the potential risks of the product and the solutions found
- List relevant European or national standards that were applied
- Be available to authorities upon request for 10 years after placing the product on the market
2.4 Consequences of Non-Compliance
The consequences of non-compliance with the GPSR are significant:
| Consequence | Details |
|---|---|
| Listing Suspension | Amazon suspends listings without a valid Responsible Person or missing compliance attributes |
| ASIN Suppression | Missing mandatory information leads to suppression in search results |
| Fines | National market surveillance authorities can impose fines — in Germany up to EUR 100,000 |
| Product Recall | Authorities can order an EU-wide recall through the Safety Gate |
| Legal Action | Competitors and consumer associations can take legal action over missing information |
3. GPSR Checklist: What You Need to Do Now
The following checklist covers all essential obligations you must fulfill as an Amazon seller in the EU. Work through it point by point.
Determine Your Role in the Supply Chain
What: Clarify whether you act as a manufacturer, importer, or distributor under the GPSR. Your role determines your obligations.
How: If you sell products under your own brand (private label), you are considered a manufacturer — even if production takes place in China. If you buy branded products from a non-EU supplier, you are an importer.
Common mistake: Private-label sellers consider themselves distributors. They are actually manufacturers and bear full responsibility for product safety and documentation.
Designate a Responsible Person (if necessary)
What: If the manufacturer of your product is based outside the EU, a Responsible Person with an EU address must be designated.
How: Enter yourself if you are based in the EU. Alternatively, appoint an Authorized Representative. The Responsible Person must be registered in Seller Central.
Common mistake: Entering the Chinese manufacturer's address as the EU address. Amazon now validates countries and suspends listings with non-EU addresses.
Enter Manufacturer Information in Seller Central
What: The manufacturer's name, trade name/brand, and full postal address must be recorded on every listing.
How: In Seller Central under Catalog > Edit Listing > Compliance Information. Also check via Flat File (Inventory Template) whether the fields manufacturer_name, manufacturer_address, and responsible_person are populated.
Common mistake: Only entering the brand name without a postal address. The GPSR explicitly requires a complete address — not just a company name.
Ensure Your Product Is Identifiable
What: Art. 9(6) GPSR requires every product to bear a type, batch, or serial number that allows unique identification.
How: Check your product and packaging. A model number on the product and/or packaging is generally sufficient. Also enter this in the listing.
Common mistake: Shipping products without any identification marking. This particularly affects sellers of generic/no-brand products.
Create an Internal Risk Analysis
What: Manufacturers must conduct an analysis of the risks associated with their product (Art. 9(2)). This does not need to be published but must be presentable to authorities within 10 days upon request.
How: Document potential risks (mechanical, chemical, electrical, choking hazards, etc.), the identified target audience, applied standards, and measures taken. A simple template is sufficient — it doesn't need to be a 100-page document.
Common mistake: Having no risk analysis at all. Many private-label sellers rely on their supplier's test certificates without creating their own analysis.
Add Warnings and Safety Information
What: Art. 9(7) requires products to carry clear warnings and safety instructions — in the language of the target country.
How: Add warnings on the packaging and in the listing bullet points. For the German market, these must be in German. Examples: age recommendations, choking hazard warnings for small parts, instructions for supervised use.
Common mistake: Having warnings only in English or Chinese on the packaging. For Amazon.de, they must be in German.
Check Product Images for Identifiability
What: For distance selling offers, Art. 19(3) requires at least one image showing the product so that the type/model is recognizable.
How: Ensure at least one listing image shows the model designation, labels, or packaging. Pure lifestyle photos are not sufficient.
Common mistake: Using only rendered images with no connection to the actual product.
Set Up a System for Complaints and Recalls
What: Art. 9(8) requires manufacturers to have a procedure for handling complaints and product recalls.
How: Document a simple process: How are complaints recorded? How is it decided whether a recall is necessary? Who gets notified? An internal SOP document is sufficient.
Common mistake: Having no process and having to improvise when authorities make an inquiry.
Report Unsafe Products Through the Safety Gate
What: If you discover that your product poses a safety risk, you are obligated under Art. 9(9) to report this to the relevant authorities.
How: In Germany, the Federal Institute for Occupational Safety and Health (BAuA) is the responsible authority. Reports can be submitted through the EU Safety Business Gateway.
Common mistake: Ignoring negative reviews about safety issues instead of treating them as potential reporting obligations.
Check All Marketplaces Where You Sell
What: The GPSR applies EU-wide. If you sell on Amazon.de, .fr, .it, .es, and .nl, compliance information must be correctly entered on every marketplace.
How: Export your inventory via Flat File and check the compliance fields for all EU marketplaces. Warnings must be in the respective national language.
Common mistake: Only updating Amazon.de and forgetting the other EU marketplaces.
Retain All Documents for 10 Years
What: Technical documentation, risk analyses, test certificates, and EU declarations of conformity must be retained for 10 years after the last placing on the market.
How: Set up a structured filing system (digital is sufficient). Organize by ASIN/product. Store: risk analysis, test results, declaration of conformity, supplier correspondence, packaging photos with markings.
Common mistake: Only keeping documents at the supplier's end. If the supplier changes or becomes unreachable, you'll lack the documentation.
4. GPSR + Other EU Regulations
The GPSR is a horizontal framework — it applies to all consumer products. Alongside it, there are product-specific EU regulations that impose additional requirements. As an Amazon seller, you need to understand how these regulations interact.
General rule: If a product falls under both the GPSR and a product-specific regulation (e.g., Toy Safety Directive), the specific requirements of the sector directive take priority. The GPSR applies to aspects not covered by the sector directive (Art. 2(1) GPSR).
| Regulation | Applies to | Core Obligation | Relation to GPSR |
|---|---|---|---|
| CE Marking | Toys, electronics, machinery, PPE, medical devices, etc. | Declaration of conformity, testing, CE mark on product | Takes priority. GPSR supplements where CE directive has no rule. |
| EPR (Extended Producer Responsibility) | Packaging (VerpackG), batteries (BattG), electrical devices (ElektroG) | Registration with LUCID/Stiftung EAR, system participation | Independent. EPR covers disposal, GPSR covers product safety. |
| WEEE (ElektroG) | All electrical and electronic equipment | Registration with Stiftung EAR, take-back, crossed-out wheelie bin | Independent. GPSR supplements safety aspects for electrical devices. |
| REACH | Chemicals in products (e.g., SVHC substances above 0.1%) | Disclosure obligation, SCIP database reporting | Takes priority for chemical risks. GPSR covers remaining safety aspects. |
| Toy Safety Directive (2009/48/EC) | All products intended for children under 14 | CE, EN 71 testing, age recommendation, specific warnings | Takes priority. GPSR supplements for uncovered safety aspects. |
Practical Example
You sell an LED desk lamp on Amazon.de. This requires: CE marking (Low Voltage Directive + EMC), WEEE registration with Stiftung EAR, packaging registration with LUCID, and GPSR-compliant listing information (manufacturer, address, Responsible Person). All four regulatory frameworks apply simultaneously.
5. Common Mistakes and How to Avoid Them
Based on the most frequent compliance issues we see with Amazon sellers, here are the top 5 mistakes:
Responsible Person Missing or Has No EU Address
Many sellers who import products from China have no Responsible Person with an EU address registered. Amazon is increasingly suspending these listings automatically.
What it costs: Immediate listing suspension, revenue loss, and potentially inventory destruction at FBA if the listing cannot be reactivated.
Solution: Enter yourself as the Responsible Person if you are based in the EU. Alternatively, use an Authorized Representative service. Enter the information in Seller Central under the compliance attributes.
No Internal Risk Analysis Documented
The risk analysis is often confused with test certificates. A GS certificate or EN 71 test report is important but does not replace the manufacturer's own risk analysis.
What it costs: When authorities inquire, you have 10 days. Without documentation, you face a sales ban and fines.
Solution: Create a simple risk analysis for each product: What risks exist? For whom? Which standards were applied? What measures were taken? The document doesn't need to be perfect — it needs to exist.
Warnings Missing or Not in the Local Language
Art. 9(7) GPSR requires that warnings and safety information be available in the language of the member state where the product is made available.
What it costs: Legal action by competitors (claim value EUR 5,000-25,000), listing suspension by Amazon, authority inquiry.
Solution: Add warnings in the local language for each marketplace — both on the packaging and in the listing bullet points. Use German for Amazon.de, French for Amazon.fr, and so on.
Confusing GPSR Obligations with EPR
Many sellers believe that with LUCID registration and a dual system, they have fulfilled all obligations. But EPR (Extended Producer Responsibility) regulates disposal — the GPSR regulates product safety. These are separate requirements.
What it costs: False sense of security. You're EPR-compliant but not GPSR-compliant — and Amazon suspends you anyway.
Solution: Treat GPSR, EPR, CE, and WEEE as separate compliance projects. Check which regulatory frameworks apply to each product and work through them individually.
Implementing Compliance Only for the Main Marketplace
Sellers update their GPSR information on Amazon.de but forget Amazon.fr, .it, .es, and .nl. The GPSR applies across the entire EU — and each marketplace is checked separately.
What it costs: Listing suspensions on individual marketplaces that you only notice when revenue drops.
Solution: Use Flat Files to update all EU marketplaces simultaneously. Check the compliance fields for each marketplace individually.
6. Download the GPSR Checklist
The complete GPSR checklist as a PDF — ready to print and check off. Free, no marketing spam.
Free Checklist
GPSR Compliance Checklist (PDF)
11 points every Amazon seller in the EU must complete. With explanations and examples.
No spam. Your email will only be used to send the checklist.
EU Compliance Spark
Claire checks your GPSR compliance automatically
Claire scans your listings for missing mandatory information, checks Responsible Person data, and identifies compliance gaps — for GPSR, EPR, CE, and WEEE. As part of your GoSparked AI team.
Get Sparked.Summary
GPSR Compliance in 3 Sentences
- The GPSR has been in effect since December 2024 for all consumer products in the EU — including Amazon listings.
- Mandatory information on the listing (manufacturer, address, Responsible Person) is not optional but a legal requirement.
- Non-compliance risks listing suspensions, fines up to EUR 100,000, and legal action.
