Does the GPSR apply to spare parts and accessories sold separately?

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Jason van de Zande

The General Product Safety Regulation (EU) 2023/988 (GPSR) can apply to spare parts and accessories sold separately when they are consumer products in their own right—meaning they are intended for consumers or are likely to be used by consumers under reasonably foreseeable conditions. Whether the GPSR applies also depends on whether more specific EU harmonised product legislation covers the same risks. The questions below explain when parts become safety-relevant and what sellers must do.

Does the GPSR cover spare parts and accessories sold separately?

Yes, the GPSR can cover spare parts and accessories sold separately if they qualify as a consumer product placed on or made available on the EU market. A separately sold part or accessory is often treated as its own product when it is marketed to consumers, supplied for consumer repair or upgrade, or likely to be used by consumers in practice.

The GPSR works as a safety net. If a product is covered by EU harmonised legislation (for example, certain electrical equipment), that sector-specific law is the primary rule for the risks it addresses, and the GPSR applies only to aspects, risks, or categories of risks not covered (lex specialis principle). If no specific EU safety legislation applies, the GPSR can apply in full.

  • Likely consumer use matters: even parts designed for professional systems can fall under the GPSR if they migrate into consumer use (for example, DIY repairs).
  • Sales channel does not change scope: the GPSR applies to online and offline offers targeted at EU consumers.

When is a spare part treated as a safety-critical product under the GPSR?

A spare part is treated as safety-critical under the GPSR when it can affect the safety performance of the end product or introduce hazards on its own. This is common when the part changes electrical, mechanical, thermal, chemical, or choking risks, or when consumers are expected to install, replace, or maintain it without professional support.

Safety relevance increases when the part or accessory:

  • Controls or limits hazards, such as thermostats, chargers, battery packs, power supplies, braking components, guards, or child-resistant closures.
  • Creates inherent hazards, such as sharp edges, pinch points, overheating surfaces, flammability, or exposure to hazardous substances.
  • Is marketed for consumer repair, maintenance, or upgrade, especially for DIY installation.
  • Makes compatibility claims, such as “fits Brand X,” which can create foreseeable unsafe combinations if the claim is wrong or incomplete.
  • Has foreseeable misuse, such as being used with higher power ratings, different connectors, or in wet environments.

In practice, you should perform a risk assessment focused on realistic use and foreseeable misuse, then decide what safety information, warnings, and installation instructions are needed to keep the product safe.

What GPSR obligations apply when selling spare parts or accessories separately?

When the GPSR applies, the core rule is simple: only safe products may be placed on or made available on the EU market. Selling a part separately does not reduce obligations. You still need to assess risks, provide safety information, and maintain traceability so authorities can identify the product and the responsible economic operators.

  • Risk assessment and technical documentation: keep evidence showing why the part is safe under normal and reasonably foreseeable conditions of use.
  • Product identification and traceability: use identifiers such as model, type, batch, or serial number, and keep supply-chain details so products can be traced.
  • Clear instructions and warnings: provide installation instructions, use limitations, and safety warnings in the languages required for the Member States where you sell.
  • Distance sales information: online listings must present required safety and traceability information clearly, not only inside the package.
  • Corrective actions and recalls: if a part presents a risk, you must act quickly with corrective measures, including recall steps where needed.
  • Accident handling: have internal processes to collect safety complaints and accident information and to decide on corrective measures.

If you are a non-EU manufacturer or seller placing GPSR products on the EU market, you must have an EU-based Responsible Person (an economic operator) identified for the product. Under the Market Surveillance Regulation (EU) 2019/1020 (MSR), that economic operator must be indicated so authorities can contact them, and the Responsible Person must inform the manufacturer when it has reason to believe a product presents a risk.

How does EARP help with GPSR compliance for spare parts and accessories sold separately?

We help non-EU manufacturers and sellers keep spare parts and accessories compliant for EU market access by providing practical, documentation-focused support and an EU-based Responsible Person service.

  • Acting as your EU Responsible Person for GPSR products sold into the EU
  • Checking required safety documentation for presence and completeness, then storing it for fast authority access
  • Serving as a liaison with national market surveillance authorities for information requests
  • Providing guidance on product identification, traceability, labelling, and online listing information to make marketplace checks easier to satisfy
  • Supporting corrective-action workflows when a safety risk or accident report requires action

See our services, or contact us to discuss your spare parts or accessories and confirm which GPSR steps you need to take next.

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