The complete GPSR compliance checklist for e-commerce sellers

The General Product Safety Regulation (Regulation (EU) 2023/988) has applied since 13 December 2024, and for online sellers it is the rule that most often stops a listing. It is not a testing standard and it is not CE marking. It is a set of duties about documentation, traceability, information shown to the buyer, and what you do when something goes wrong.

This is a working checklist. Take one product, work down the list, and the gaps will be obvious.

1. Establish which role you hold

Your duties depend on your role, and you can hold more than one.

You are the manufacturer if you make the product, or if you sell it under your own brand or trademark, or if you modify a product in a way that affects its safety. Private-label sellers are manufacturers. This surprises people, and it is the single most consequential point in the regulation for ecommerce.

You are the importer if you are established in the EU and bring products from outside the EU onto the market. You are a distributor if you make products available without being manufacturer or importer. You may be a fulfilment service provider if you warehouse, pack and dispatch for others.

If you are outside the EU selling directly to EU consumers, there is no EU importer in your chain, so you need an EU-established responsible economic operator under Article 16.

2. Build the technical documentation

For each product the manufacturer must hold, in a form that can be produced on request:

• product identification: model, type, batch or serial numbering scheme;
• a description of the product and its intended use, including foreseeable misuse;
• photographs of the product, packaging and markings;
• the applicable standards or other specifications used;
• a risk assessment covering the hazards you identified and how you addressed them;
• test reports where testing was carried out, from a competent laboratory;
• warnings, instructions and safety information, in the required languages;
• the Declaration of Conformity where sector legislation requires one;
• records of your production or supplier controls.

Keep it for ten years after placing the product on the market. "Our supplier has it" is not compliance if you cannot obtain it quickly and in a language authorities accept.

3. Do a real risk assessment

A one-page generic statement is not a risk assessment. Identify hazards by category — mechanical, electrical, thermal, chemical, choking and small parts, entrapment, flammability, hygiene, radiation, noise — and for each hazard record the risk, who is exposed, what you did about it, and what residual risk is communicated by warning. Where children may be exposed, the analysis needs to reflect that explicitly.

4. Get traceability right

You need to identify each product and trace it. Practically: a model or type identifier on the product; a batch, lot or serial number that lets you isolate an affected population; the manufacturer's name and postal address on the product, or on the packaging or accompanying document where the product is too small; the same for the EU responsible operator; and records connecting your suppliers to the batches you received and the customers or channels you shipped to.

Traceability is what makes a recall proportionate. Without a batch scheme, a recall becomes everything you ever sold.

5. Fix your listings before anything else

Distance selling has explicit information duties, and this is where enforcement starts because it is visible without an inspection. Every EU offer needs:

• the manufacturer's name, postal address and electronic contact;
• the EU responsible operator's name, postal address and electronic contact, where the manufacturer is outside the EU;
• product identification, including model and pictures;
• any warning or safety information required, in the language of the market, visible before purchase.

On marketplaces, use the dedicated compliance and safety fields. Text buried in a description is not reliably surfaced, and platforms audit the structured fields.

6. Cover the language requirements

Warnings, instructions and safety information must be in a language easily understood by consumers in the market where the product is sold, as determined by that Member State. Selling into six countries means six language versions in practice. Machine translation of a safety warning is a risk you own.

7. Have an incident procedure before you need one

If you learn a product you placed on the market is dangerous, you must take corrective action and notify authorities through the Safety Business Gateway. If an accident occurs involving your product, you must notify the authority of the Member State where it happened without delay.

Write the procedure down: who decides, who notifies, what evidence gets collected, how customers are contacted, what your public recall notice says, and how you report outcomes. Decide the escalation thresholds while nothing is on fire.

8. Set up your recall mechanics

You need to be able to contact affected customers directly where you hold their details, and consumers must be offered an appropriate remedy — repair, replacement or refund — with at least two options. Recall notices must be clear, must not minimise the risk and must not use language that discourages action. If you sell through marketplaces, know how to reach affected buyers through each channel before you need to.

9. Check the sector rules that sit alongside GPSR

GPSR is the general regime. If your product falls under specific legislation — toys, electrical equipment, radio equipment, personal protective equipment, machinery — those rules govern conformity assessment and CE marking, and GPSR fills the gaps. Chemicals bring REACH and CLP. Packaging brings the PPWR and national EPR. Environmental claims bring EmpCo. Batteries bring the Battery Regulation.

10. Keep it current

Review when you change supplier, factory, material, formulation or specification; when a standard is updated; when you enter a new market with a new language requirement; and when you add SKUs to a mandate held by an EU representative. Compliance decays quietly.

11. Keep a per-SKU compliance record

One page per product, holding: role you occupy, technical file location, risk assessment date, batch numbering scheme, EU responsible operator and mandate reference, language versions of instructions and warnings, marketplace compliance field status per channel, and the date of the last review. This is the artefact that turns an authority request from a fire drill into an email attachment, and it is also what a marketplace compliance team wants when a listing is suppressed.

12. Know what your marketplace actually requires

Each platform implements the GPSR information duties through its own fields and its own validation. Amazon, Etsy and eBay all collect manufacturer and responsible-person details, and all of them suppress listings where required fields are incomplete. Treat platform requirements as a superset: satisfying the regulation is necessary, satisfying the field validation is what keeps you selling. Audit your channels one at a time and record which fields each one exposes, because a change on the platform side is the most common cause of a sudden listing problem.

The five failures that actually cost sellers money

No EU responsible operator named in the listing. Fastest route to suppression.

Private-label sellers assuming they are distributors. They hold manufacturer duties, including the technical file.

No batch numbering. Turns a contained problem into an uncapped one.

Single-language safety information across multiple markets. Easy for an authority to spot from a desk.

No documented risk assessment. The first thing requested, and the hardest to produce retroactively.

How to use this list

Do not attempt the whole catalogue at once. Take your top-selling product, complete every line, and you will have a template — a documentation structure, a listing template and a language matrix — that the rest of the catalogue can be pushed through far faster.

Educational information only, not legal advice. Sector-specific conformity routes and national penalties vary — confirm your obligations with a qualified advisor.