Does GPSR apply to private label and white label products?

Yes. General Product Safety Regulation (EU) 2023/988 (GPSR) applies to private-label and white-label consumer products when they are placed on the market or made available to consumers in the EU, regardless of who owns the brand. What matters is the product’s safety and the economic operator roles in the supply chain. Below are the key scope rules, who carries which obligations, and the practical compliance steps marketplaces and authorities typically expect.

Does GPSR apply to private-label and white-label products?

Yes. GPSR applies based on whether the product is a consumer product offered in the EU, not on whether it is private-label, white-label, or a branded original. It covers new and used products, and it also covers digital elements such as software or apps when they are part of a consumer product offering. The same safety requirement applies whether you sell via a distributor, your own website, or an online marketplace.

GPSR has exclusions, including (among others) food, medicinal products, and certain aircraft categories. Services themselves are not covered, but products supplied to consumers in a service context can be covered (for example, products that consumers use or are exposed to during a service).

GPSR also interacts with sector-specific EU harmonisation laws. Where a product is covered by specific EU safety legislation, GPSR generally acts as a safety net and applies to risks not already covered by that specific legislation, while certain GPSR chapters still apply, including key distance-sales and online marketplace provisions.

Who is responsible under GPSR for private-label and white-label products?

Responsibility under GPSR depends on your legal role, not your branding model. In private-label and white-label setups, the brand owner often becomes the “manufacturer” in the legal sense if it places the product on the market under its name or trademark, or modifies a product in a way that can affect safety. If you are outside the EU, you still need an EU-based GPSR responsible person (an economic operator established in the Union).

Here is how roles commonly map in private-label and white-label scenarios:

Manufacturer: Ensures the product is safe, performs the safety assessment, prepares and maintains technical documentation, and manages corrective actions.
Importer: If an EU importer exists, it has its own checks and traceability duties for products it brings into the EU.
Distributor: Acts with due care, verifies that key information is present, and cooperates on corrective actions.
Fulfilment service provider: Can become the relevant EU economic operator in certain distance-selling models where no other EU operator is identified.
Responsible person: Provides an EU contact point and performs specific tasks under the MSR framework for products sold into the EU.

Under Market Surveillance Regulation (EU) 2019/1020 (MSR), the responsible person must, among other duties, inform the manufacturer if it has reason to believe a product presents a risk. The responsible person is not the role that notifies serious risks to authorities; that responsibility lies with the authorised representative when appointed for that purpose.

What compliance steps are needed for private-label and white-label products under GPSR?

Private-label and white-label sellers should treat GPSR as an operational checklist: prove the product is safe, make traceability easy, and be ready to respond quickly if a safety issue arises. Market surveillance authorities can request documentation, and online marketplaces often ask for simple, verifiable evidence that matches the listing and the physical product.

Product safety assessment: Identify hazards, foreseeable use and misuse, vulnerable users, and any digital or cybersecurity-related safety aspects, where relevant.
Technical documentation: Keep a structured file that demonstrates product safety (design information, risk assessment, test evidence where applicable, and control measures).
Traceability identifiers: Ensure model or type identification is clear, and include batch or serial identification where applicable.
Manufacturer labelling: Show the manufacturer’s name, postal address, and an electronic contact address that enables direct two-way communication, plus the model or type number.
Warnings and instructions: Provide clear safety information in the languages required for the EU countries where you target consumers.
EU responsible person details: Display the responsible person’s contact details on the product, packaging, or accompanying document, following the practical hierarchy used for small items.
Accident handling and corrective actions: Maintain internal processes to collect safety feedback, assess risk, and implement corrective actions, including recalls when needed, and coordinate with the relevant economic operators.
Marketplace documentation readiness: Keep consistent photos and documents so the label, listing, and technical file match; inconsistencies are a common reason for listing blocks.

How EARP helps with GPSR compliance for private-label and white-label products

When you need an EU-based economic operator to support GPSR market access for private-label or white-label products, we can take on the responsible person role and support authorised representative activities where applicable, while keeping your documentation and communications with authorities organised.

We provide EU responsible person and authorised representative support aligned with GPSR and MSR role requirements.
We check for the presence and completeness of required product safety documentation, and store it so it can be made available to authorities upon request.
We act as a liaison with national market surveillance authorities and support structured responses to information requests.
We guide onboarding so your labelling and marketplace evidence align with your technical file.

Review our services, then contact us to discuss your private-label or white-label product range and set up your EU responsible person coverage.

Does GPSR apply to private label and white label products?