Does GPSR apply to small businesses and sole traders?

Yes. The General Product Safety Regulation (EU) 2023/988 (GPSR) applies to small businesses and sole traders if they place, make available, or offer consumer products to EU consumers, including through online and other distance sales. The rules focus on the product and the selling activity, not your company size. Below are the most common questions about scope, when you need an EU Responsible Person, and the simplest compliance steps.

Does GPSR apply to small businesses and sole traders?

Yes. GPSR is product- and activity-based, so it applies when you sell consumer products into the EU, whether you are a large manufacturer, a microbusiness, or a sole trader. It covers most consumer products, including new and used goods, and can also cover products originally designed for professional use if consumers are likely to use them under reasonably foreseeable conditions.

GPSR also applies to distance selling, including offers made online that are targeted at one or more EU Member States. Targeting is assessed on a case-by-case basis, using indicators such as the languages offered, currencies and payment methods, delivery areas, and domain choices. Some categories are outside the scope, for example, food and medicinal products, and GPSR acts as a “safety net” where no more specific EU product safety law covers the same risks.

When do you need an EU Responsible Person under GPSR?

You need an EU-based Responsible Person when your consumer product is made available in the EU and the manufacturer is not established in the EU, unless another qualifying economic operator in the EU already exists in the supply chain. This is not about business size; it is about ensuring an EU-based contact point and access to documentation for market surveillance.

Under the Market Surveillance Regulation (EU) 2019/1020 (MSR), the Responsible Person is an economic operator established in the EU. The typical hierarchy is: EU manufacturer; otherwise, the importer; otherwise, an authorised representative with a written mandate. If none exists, an EU fulfilment service provider can become the Responsible Person when it provides at least two of these services: warehousing, packaging, addressing, and dispatching.

Manufacturer: makes the product or has it made and sells it under its name or trademark (rebranding can make you the manufacturer).
Importer: an EU-established entity placing goods from outside the EU on the EU market.
Distributor: makes a product available on the market without being the manufacturer or importer.
Authorised representative: an EU-established entity with a written mandate; not mandatory, but can be appointed.
Responsible Person: an EU-established economic operator performing specific product safety tasks and acting as the authority contact.

Online marketplaces often check for Responsible Person details and may block listings when the required EU economic operator information is missing or inconsistent.

What are the key GPSR compliance steps for microbusinesses?

For microbusinesses, GPSR compliance is manageable if you treat it as a repeatable checklist. The goal is to show that the product is safe under normal and reasonably foreseeable use, and that you can provide traceability and safety information quickly if authorities ask.

Identify the product clearly: model, batch, or serial number where applicable, and consistent identifiers across packaging and listings.
Provide safety information: warnings, instructions, and any required language versions for the Member States where you sell.
Conduct a product risk assessment: consider hazards, foreseeable misuse, and vulnerable users (for example, children if the product is likely to be used by them).
Keep technical documentation available: store what you have to demonstrate product safety, and be ready to provide it to authorities on request.
Set up an accident and recall process: define how you will collect safety complaints, stop sales, contact customers, and issue recall notices if needed.
Cooperate with market surveillance: respond promptly to information requests, and keep your EU economic operator contact details accurate.
Check your “economic operator” details: ensure the Responsible Person information appears where required, such as on the product, packaging, or accompanying documentation, and matches the online listing.

How EARP helps with GPSR compliance for small businesses and sole traders

We help small businesses and sole traders meet GPSR requirements by providing practical, EU-based regulatory representation and documentation readiness, without adding operational burden to your team.

We act as your EU Responsible Person and, where appropriate, authorised representative under a written mandate.
We review, verify, and store product safety documentation so it is available to authorities when requested.
We serve as a liaison with national market surveillance authorities and support clear, consistent traceability information.
We guide you on what to show on labels, packaging, and online listings to reduce marketplace compliance issues.

See our services, or contact us to discuss your products and set up the EU Responsible Person role.

Does GPSR apply to small businesses and sole traders?