What are the GPSR obligations for online marketplaces themselves under Article 22?

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Jason van de Zande

Under the General Product Safety Regulation (EU) 2023/988 (GPSR), Article 22 sets out duties for online marketplace providers, meaning platforms that intermediate distance sales between traders and consumers. The focus is on the marketplace’s own controls, notice handling, and cooperation with authorities—not on how sellers design products. Below are the key Article 22 requirements, how to respond to unsafe product notices and recalls, and what listing traceability measures marketplaces should implement.

What does Article 22 of the GPSR require from online marketplaces?

Article 22 requires online marketplace providers to run their platforms in a way that supports product safety enforcement. In practice, this means having clear internal processes to receive and act on notices about unsafe products, cooperating with market surveillance authorities, and enabling traceability and consumer communication when risks arise.

An “online marketplace provider” under the GPSR is the provider of an online interface that allows consumers to conclude distance contracts with traders for products. The marketplace is not automatically the manufacturer or importer, but it has its own standalone obligations under Chapter IV of the GPSR.

  • Maintain a single point of contact for authorities and for users (traders and consumers) on product safety matters.
  • Put in place product safety-related procedures, including how offers are assessed, restricted, or removed when needed.
  • Cooperate with authorities, including providing information and acting on orders.

How must online marketplaces handle unsafe products, notices, and recalls under Article 22?

Online marketplaces must be able to receive notices from authorities and traders, assess them quickly, and take effective action, such as disabling access to an offer or removing it. They must also support consumer warnings and recalls when a product has already reached consumers.

Operationally, Article 22 expects a marketplace to have a documented workflow that covers intake, verification, decision-making, execution, and record-keeping. When a competent authority issues an order, the marketplace should be able to restrict or remove the relevant content and preserve evidence for follow-up.

  1. Intake and triage: log the notice, identify the product offer, and confirm the trader and listing identifiers.
  2. Immediate risk controls: disable access to the offer where required, including across Member State storefronts if applicable.
  3. Consumer communication: help ensure consumers receive recall notices or safety warnings through the platform’s messaging and order history tools.
  4. Authority cooperation: respond through the required channels and within the required timelines, and provide requested listing, trader, and transaction information.

Where Safety Gate tools apply, marketplaces should align their processes with the EU’s Safety Gate ecosystem, including the technical and procedural rules set by implementing and delegated measures linked to the GPSR.

What information and traceability controls must marketplaces put in place for listings?

Marketplaces must structure listings so that trader and product traceability is possible and safety actions can be targeted. That means collecting, displaying, or making available key information that enables authorities and consumers to identify the trader, the product, and the relevant EU economic operator responsible for specific compliance tasks where required.

In practice, marketplaces commonly govern listings by requiring structured fields and documentary checks before a product can be offered to EU consumers. Typical controls include:

  • Trader identification: verified trader name, address, and contact details.
  • Product identification: model, type, batch, or serial number where applicable, and consistent product identifiers across offers.
  • Responsible Person details where the GPSR requires an EU-based economic operator to be designated for the product, especially for non-EU manufacturers selling at a distance.
  • Safety information: warnings and instructions in appropriate languages for the Member States targeted.
  • Governance measures: listing rules that prevent relisting after removal, audit trails for edits, and escalation paths for repeat non-compliant offers.

These controls help a marketplace act quickly when a safety issue arises, and they reduce the risk of incomplete or misleading product information reaching consumers.

How does EARP help with GPSR Article 22 marketplace obligations?

We help marketplaces and non-EU sellers meet GPSR expectations by putting the right EU-based regulatory operator in place and by organizing the product safety documentation and listing data that platforms and authorities typically request.

  • EU Responsible Person and EU Authorized Representative services aligned with GPSR and Market Surveillance Regulation (EU) 2019/1020 (MSR) role requirements
  • Documentation readiness support, including structured checks for the presence and completeness of required product safety documents
  • Processes to store technical documentation and make it available to authorities upon request
  • Practical guidance for marketplace listing data fields, including Responsible Person details where required

See our services, or contact us to discuss what your platform or catalogue needs to stay compliant with GPSR Article 22.

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