Does GPSR apply to products sold in Norway, Iceland and Liechtenstein?

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Jason van de Zande

The General Product Safety Regulation (EU) 2023/988 (GPSR) applies directly in EU Member States from 13 December 2024, but it does not automatically apply in Norway, Iceland, or Liechtenstein on that same date. Those countries are EEA EFTA states, so EU internal market product rules can apply there only after incorporation into the EEA Agreement and completion of the relevant national implementation steps. Below are the practical rules to follow in the meantime, and when a GPSR Responsible Person may be needed.

Does the GPSR apply in Norway, Iceland and Liechtenstein through the EEA agreement?

Not automatically on the EU application date. The GPSR is an EU regulation that applies directly in all EU Member States from 13 December 2024. Norway, Iceland, and Liechtenstein participate in the EU internal market via the EEA Agreement, but EU acts generally apply in those countries only after they are incorporated into the EEA Agreement (typically via the relevant Annex) and then implemented through each country’s legal mechanisms.

In practice, that means the GPSR can become applicable in the EEA EFTA states, but the timing can differ from the EU. Businesses should treat “applicable in the EU from 13 December 2024” and “applicable in the EEA EFTA states” as two separate questions, because EEA incorporation can happen later and may come with adaptations.

  • EU: The GPSR applies directly and uniformly from 13 December 2024.
  • Norway, Iceland, Liechtenstein: Applicability depends on EEA incorporation and national implementation timing.

What rules apply while the GPSR is not yet incorporated or fully implemented in an EEA EFTA state?

You must follow the product safety rules that are currently in force in that country. If the GPSR is not yet incorporated or fully implemented in a specific EEA EFTA state, that country’s national product safety framework continues to apply. In many cases, that framework reflects the EU General Product Safety Directive 2001/95/EC, as adapted and implemented in the EEA, until it is replaced by GPSR-equivalent rules.

Even during any transition, the core expectations do not disappear: products must be safe, authorities can request information, and businesses must take corrective action when a product presents a risk, including warnings, withdrawals, and recalls where needed. Market surveillance authorities in each country can still investigate accidents and require documentation that supports product safety.

  1. Check the current legal status of GPSR incorporation for Norway, Iceland, and Liechtenstein separately.
  2. Follow local guidance from the relevant national market surveillance authority.
  3. Keep product safety documentation ready to share promptly if requested.

Do you need a GPSR ‘Responsible Person’ for products sold to Norway, Iceland or Liechtenstein?

A GPSR Responsible Person is a GPSR-specific requirement, so it applies in Norway, Iceland, and Liechtenstein only if and when the GPSR is incorporated and implemented there. Under the EU framework, the Responsible Person is an economic operator established in the Union that must be in place for products covered by the GPSR when the manufacturer is not established in the EU, including for distance sales and online marketplace listings targeting EU consumers.

If you sell into Norway, Iceland, or Liechtenstein, whether you must appoint a “GPSR Responsible Person” depends on that country’s current legal position on the GPSR. Separately, you may still have obligations under other product-specific EU harmonisation laws (for example, CE-marking legislation), under which an authorised representative may be appointed; however, an authorised representative is not automatically required for every product. Also distinguish the Responsible Person role from importer and distributor roles, which depend on your supply chain structure in each country.

Role What triggers it Key point
GPSR Responsible Person The GPSR applies in the target market Economic-operator contact point and documentation-availability duty under the GPSR
Authorised representative Relevant sector law allows or requires it Not universally mandatory; depends on product legislation
Importer or distributor Supply chain placement in that market Commercial-operator obligations, not a neutral compliance function

Where Market Surveillance Regulation (EU) 2019/1020 (MSR) applies, Article 4 sets out the “EU-based economic operator” concept for many non-food products. The Responsible Person role is about having an accountable EU-based operator for market surveillance contact and documentation access. The Responsible Person must notify the manufacturer of risks under Article 4 of the MSR, while notifications of serious risks to authorities are handled by the authorised representative where that role exists.

How does EARP help with GPSR applicability in Norway, Iceland and Liechtenstein?

We help you determine what applies in each EEA EFTA country and what you must do next to keep products compliant and listings active. Our support is practical and documentation-focused, so you can respond quickly to marketplace checks and authority requests.

  • Confirm whether the GPSR has been incorporated and implemented for Norway, Iceland, and Liechtenstein, and what the effective dates mean for your products.
  • Map your obligations under the GPSR, the MSR, and any product-specific EU rules that may apply to your category.
  • Check traceability and labelling content needed for online offers and product packaging.
  • Review and organise technical documentation for readiness, storage, and rapid sharing when authorities request it.
  • Act as your EU Responsible Person and, where relevant, your authorised representative through our services.

If you want a clear, country-by-country answer for your products and sales channels, contact us here: contact.

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