What products require an EU Authorized Representative under GPSR?

The General Product Safety Regulation (EU) 2023/988 (GPSR) applies to virtually all consumer products sold in the EU market, whether physical or digital, new or used. Products require an EU Authorized Representative when manufacturers are located outside the EU and need local representation for regulatory compliance. The GPSR creates a comprehensive safety framework that works alongside existing CE marking requirements to ensure consumer protection.

What is the general product safety regulation and which products does it cover?

The General Product Safety Regulation (EU) 2023/988 (GPSR) is the EU’s comprehensive safety framework that replaced the General Product Safety Directive on 13 December 2024. It applies to all products placed or made available on the European market, whether new, used, repaired, or reconditioned, covering every type of product intended for consumers or likely to be used by consumers under reasonably foreseeable conditions.

The regulation covers an extensive range of products including physical items, digital products, and standalone software. This means everything from household appliances and toys to mobile apps and software programs falls under GPSR requirements. The regulation takes a broad approach to ensure comprehensive consumer protection across the EU Single Market.

Products Covered by GPSR

Household appliances and electronics
Toys and children’s products
Mobile applications and software programs
Digital products and standalone software
Consumer goods and accessories
Repaired or reconditioned items

Products Exempted from GPSR

Medicinal products for human or veterinary use
Food and feed products
Living plants and animals
Genetically modified organisms
Aircraft and their parts
Equipment used in military or emergency services
Antiques
Products already covered by specific EU harmonisation legislation (for aspects covered by existing requirements)

The regulation addresses health and safety risks for consumers, including both physical and mental health risks. Environmental risks are also covered when they impact consumer health, making the GPSR a comprehensive safety net for products on the EU market.

How do you know if your product needs an EU authorized representative under GPSR?

Your product needs an EU Authorized Representative under GPSR if you are a manufacturer located outside the EU selling consumer products within the European market. The key determining factors are your company’s location, your product type, and whether your products fall under GPSR scope.

GPSR EU Representative Requirements Assessment

Assessment Factor	Requirement	EU Rep Needed?
Manufacturer Location	Outside the EU	Yes
Product Type	Consumer products or likely consumer use	Yes
Business Type	B2B only (no consumer access)	No
Company Size	Any size (no exemptions)	Yes
Existing EU Harmonisation	Partial coverage only	Yes (for uncovered aspects)

The decision framework starts with assessing your manufacturer status and location. If you design, manufacture, or have products manufactured outside the EU and place them on the European market, you need EU representation. This applies regardless of your business size, as GPSR obligations apply to businesses of all sizes because consumers are entitled to safe products without exceptions based on company size.

Next, evaluate whether your product falls under GPSR coverage. Products that require european authorized representative services include physical items, digital products, and software intended for consumers or likely to be used by consumers. However, if your products are exclusively intended for professional use (B2B) and are not reasonably likely to be used by consumers, they do not fall under GPSR requirements.

You also need to consider whether your products are already covered by specific EU harmonisation legislation. If they are, you may still need GPSR representation for aspects not covered by existing requirements. For example, toys with low voltage components would still need GPSR compliance for technology-related aspects not covered by EU toy legislation.

Key Regulatory Obligations Requiring EU Representation

Holding technical documentation
Cooperating with market surveillance authorities
Ensuring product safety information availability to regulators
Responding to regulatory requests and inquiries
Managing product recall procedures when necessary

What’s the difference between GPSR and other EU product regulations like CE marking?

GPSR provides minimum safety requirements that complement rather than replace existing EU harmonisation legislation like CE marking directives. While CE marking regulations focus on specific product categories with detailed technical requirements, GPSR creates a comprehensive safety net covering all consumer products and risks not addressed by other legislation.

GPSR vs CE Marking: Key Differences

Aspect	GPSR	CE Marking
Scope	All consumer products	Specific product categories
Requirements	General safety framework	Detailed technical standards
Application	Broad safety net	Specific conformity procedures
Coverage	Fills gaps in existing legislation	Comprehensive for covered categories
Relationship	Complementary	Category-specific primary requirement

The key difference lies in their scope and application. CE marking regulations such as EMC, LVD, and RoHS apply to specific product types with detailed conformity assessment procedures and technical standards. GPSR applies broadly to virtually all consumer products, filling gaps where specific harmonised legislation does not exist or does not cover certain risks.

GPSR Chapters That Apply Even With Existing EU Harmonisation

General provisions
Obligations for distance sales
Accident reporting requirements
Online marketplace provisions
Safety Gate Rapid Alert System

For products subject to both frameworks, certain GPSR chapters apply even when products are covered by EU harmonisation legislation. This means manufacturers often need to comply with both sets of requirements simultaneously.

The interaction between these frameworks means that GPSR does not duplicate existing requirements but rather ensures comprehensive coverage. For instance, if a product has CE marking requirements covering electromagnetic compatibility, GPSR would still apply to safety aspects not covered by the EMC directive, such as mechanical safety or new technology-related risks.

Both frameworks can require EU representation, but through different mechanisms. CE marking may require an Authorized Representative for specific conformity procedures, while GPSR requires representation for broader safety compliance and market surveillance cooperation. Understanding which requirements apply to your specific products helps determine the appropriate european authorized representative services needed for full compliance.

The GPSR creates a comprehensive safety framework that works alongside existing product regulations to ensure complete consumer protection. At EARP, we provide full-service representation under both GPSR and applicable CE marking directives, helping you navigate these overlapping requirements while maintaining compliant market access across all applicable frameworks.

If you are looking for support or to learn more, contact our team of experts today