Does GPSR apply to products I sell on my own Shopify store if I ship to EU customers?

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Jason van de Zande

Yes. If you sell consumer products through your own Shopify store and your offer is directed at EU customers, the General Product Safety Regulation (EU) 2023/988 (GPSR) can apply even if you ship directly from outside the EU. The key trigger is making a product available on the EU market through distance sales. Below are the main questions sellers ask about when GPSR applies, what duties follow, and when an EU Responsible Person is needed.

Does GPSR apply if I sell through my own Shopify store and ship to EU customers?

GPSR can apply when your Shopify offer is targeted at EU consumers and you ship products to the EU, because the rules cover products sold online and through other distance channels. It is not limited to EU-based sellers or marketplaces. If your product is a consumer product, or is likely to be used by consumers under reasonably foreseeable conditions, GPSR is generally relevant.

Whether an online offer is “directed” to the EU is assessed on a case-by-case basis. Practical signals include offering delivery to EU Member States, using EU languages, showing prices in EU currencies, or providing payment and customer service options aimed at EU buyers. GPSR applies from 13 December 2024 to products placed on the market, made available, or offered from that date. Units placed on the market before that date under the previous framework can continue to be made available.

What GPSR obligations do online sellers have when shipping directly to EU consumers?

When you sell directly to EU consumers, you must ensure that only safe products are made available and that buyers and authorities can identify the product and the responsible economic operators. In practice, GPSR expectations for online selling focus on safety by design, clear product identification, and prompt cooperation with market surveillance checks, regardless of whether you sell through Shopify or a marketplace.

  • Product safety assessment: consider design, composition, packaging, instructions, and foreseeable misuse, including risks to vulnerable users where relevant.
  • Traceability and identification: ensure clear manufacturer identification and product identifiers (for example, model, batch, or serial information where applicable) are consistent across the product, packaging, and listing.
  • Consumer information: provide required warnings and instructions in appropriate languages for the markets you target, aligned with how the product is presented online.
  • Technical documentation readiness: maintain, and be able to provide, safety-related documentation promptly when requested by authorities or business partners.
  • Cooperation with authorities: respond to requests from national market surveillance authorities, including providing information and supporting corrective actions when needed.

Also check whether product-specific EU rules apply (for example, CE-marking legislation for certain electrical, radio, toy, or machinery-related products). Those frameworks can add labeling, documentation, and conformity requirements beyond GPSR.

Do I need an EU Responsible Person for GPSR if I don’t have an EU importer or distributor?

Often, yes. For many non-EU sellers shipping directly to EU consumers, the compliance gap is that there is no EU-based economic operator in the supply chain. Under the Market Surveillance Regulation (EU) 2019/1020 (MSR), certain products require an economic operator established in the EU to perform the Responsible Person role, so authorities have a reliable EU contact for compliance and access to documentation.

At a high level, the roles differ:

  • Manufacturer: remains primarily responsible for product safety and compliance.
  • Importer/distributor: may take on obligations when they place products on the market or make them available in the EU supply chain.
  • Responsible Person (economic operator): provides an EU-based compliance contact and performs the tasks set out in MSR Article 4, including making documentation available to authorities upon request and notifying the manufacturer if there is a risk.
  • Authorized Representative: can be appointed by a manufacturer but is not automatically required in every case; it is distinct from the Responsible Person role.

Where required, the Responsible Person’s name, postal address, and electronic contact details must be provided on the product, packaging, parcel, or accompanying documentation, depending on the applicable rules for the product and how it is supplied.

How does EARP help with GPSR compliance for Shopify sellers shipping to the EU?

We help non-EU Shopify sellers meet GPSR and MSR requirements by acting as an independent, EU-based compliance partner, focused on regulatory representation and documentation readiness, so you can keep selling into the EU with fewer disruptions.

  • Provide EU Responsible Person and Authorized Representative services aligned with GPSR and MSR obligations.
  • Support documentation handling, including structured checks for the presence and completeness of required product safety documents, and secure storage for authority requests.
  • Act as an EU liaison with national market surveillance authorities during information requests and compliance checks.
  • Guide you on which identification and contact details must appear on labels, packaging, or accompanying materials for your sales model.

See our services for details, or contact us to discuss your Shopify setup and the products you ship to EU customers.

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