Does GPSR apply if I only sell a few items per month to EU customers?

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Jason van de Zande

If you sell even a few items per month to EU customers, the General Product Safety Regulation (EU) 2023/988 (GPSR) can still apply. GPSR is triggered by placing or making a consumer product available on the EU market, not by sales volume. The key questions are whether your offer targets EU consumers, whether your product is in scope, and whether you have an EU-based Responsible Person and the required traceability information.

Does GPSR apply to low-volume or occasional sales into the EU?

Yes. GPSR does not include a low-volume exemption. If you place or make a consumer product available in the EU, including through distance selling, the regulation can apply even to occasional shipments. The deciding factor is market access, not how many units you sell.

GPSR covers consumer products in a broad sense, including new, used, repaired, and refurbished goods. It can also cover products originally designed for professional use if they are likely to be used by consumers under reasonably foreseeable conditions. Some categories are excluded (for example, medicinal products, food, and certain aircraft). If specific EU harmonisation legislation applies to your product, GPSR mainly acts as a safety net for risks not already covered by that sectoral law.

For online selling, an offer may be treated as targeting EU consumers based on practical signals such as the languages used, shipping destinations, currency, payment methods, or domain choices, assessed on a case-by-case basis.

Who is considered an economic operator, and when is an EU Responsible Person required?

An economic operator is a defined role in EU product compliance, and an EU-based economic operator is required for many non-food products sold into the EU. Under the Market Surveillance Regulation (EU) 2019/1020 (MSR), products covered by its scope generally cannot be placed on the EU market unless there is an EU-established economic operator that can perform the Responsible Person function.

Common economic operator roles include:

  • Manufacturer, the entity that makes the product or has it designed or manufactured and markets it under its name or trademark.
  • Importer, the EU-based entity placing a product from a non-EU country on the EU market.
  • Distributor, an entity in the supply chain making a product available on the market, other than the manufacturer or importer.
  • Fulfilment service provider, an EU-based provider offering warehousing, packaging, addressing, or dispatching without owning the products.
  • Provider of an online marketplace, an intermediary platform with specific GPSR duties, but it is not automatically your Responsible Person.

For many non-EU sellers shipping directly to EU consumers, the practical requirement is to ensure there is an EU-based Responsible Person and that marketplaces can verify it. Typical traceability information expected across the product, packaging, or accompanying documentation includes the manufacturer’s identification and contact details, product identification (such as model or batch), and the EU Responsible Person’s contact details. Marketplaces may also request this information to match the listing to labelling photos and documentation.

What practical steps should small sellers take to comply with GPSR?

Small sellers should take a proportionate approach, but still meet the core GPSR duties: sell only safe products, keep safety information clear, and be ready to provide documentation quickly. A simple compliance workflow often prevents listing blocks and reduces delays when authorities or marketplaces ask questions.

  1. Do a basic product risk assessment: identify foreseeable hazards, misuse, and vulnerable users (for example, children).
  2. Build technical documentation: keep design and safety-relevant specifications, test reports where applicable, labelling and instructions, and traceability records.
  3. Set up traceability: maintain batch or lot identification and supplier and customer records suitable for targeted corrective actions.
  4. Provide warnings and instructions in the languages of the EU countries you target, aligned with how the product is marketed and used.
  5. Monitor accidents and complaints: track safety-related feedback and investigate patterns that could indicate a risk.
  6. Prepare recall readiness: have a plan to contact buyers, stop sales, and issue consumer communications using clear, consistent product identifiers.
  7. Be marketplace-ready: keep labelling photos and documentation consistent with the listing, so you can respond quickly to compliance checks.

How EARP helps with GPSR compliance for small-volume EU sales

When you sell low volumes, the hardest part is often not the safety work itself; it is having the right EU presence and being able to answer documentation requests quickly and correctly. [COMPANY] supports small sellers by taking on the EU Responsible Person role and organising the compliance process so you can keep selling with less disruption.

  • EU Responsible Person services aligned with GPSR and MSR expectations
  • Documentation intake, completeness checks, and secure storage for fast retrieval
  • Liaison with market surveillance authorities when information is requested
  • Support in responding to online marketplace compliance and listing documentation requests

Review our services, or contact us to confirm what you need for your specific products and sales model.

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