Does the GPSR apply to products sold through my own website to EU customers?
The General Product Safety Regulation (EU) 2023/988 (GPSR) generally applies when you sell consumer products from your own website to customers in the European Union, even if your business is based outside the EU. If your online offer targets EU consumers and the product is supplied into the EU, it is typically considered “made available on the market” through distance sales. Below are the key scope rules, seller obligations, and how to check which EU framework applies.
Does the GPSR apply when I sell directly to EU consumers from my own website?
Yes, in most cases. The GPSR applies to consumer products made available on the EU market, including products offered through distance sales, such as your own webshop. If EU consumers can buy the product and it is supplied into the EU, the sale is generally in scope, even when the seller, stock, and fulfilment are outside the EU.
The GPSR has broad territorial and personal scope and is designed to cover online and offline channels. Limited exclusions exist where other EU rules fully govern safety, for example, food, medicinal products, and certain sector-regulated products. In many categories, product-specific “lex specialis” legislation can apply alongside the GPSR, meaning you may need to meet both the sector rules and the GPSR’s general safety expectations.
What obligations do online sellers and non-EU businesses have under the GPSR?
Selling via your own site does not remove GPSR duties. If you place or make consumer products available to EU consumers, you must ensure the product is safe under normal or reasonably foreseeable conditions of use, and you must be able to demonstrate how you assessed and managed safety risks.
Core obligations commonly relevant to direct-to-consumer sellers include:
- Safety and risk assessment: identify hazards, consider vulnerable users where relevant, and reduce risks through design, warnings, and instructions.
- Traceability: keep product identification and economic operator details available so authorities can trace the supply chain.
- Clear instructions and safety information: provide understandable warnings and instructions for EU consumers.
- Complaint handling: record and assess complaints and safety-related feedback, and use it to improve safety.
- Corrective actions: act quickly when you learn a product may be unsafe, including withdrawal, consumer warnings, or recall where needed.
- Cooperation with authorities: provide information and documentation on request and support market surveillance actions.
If the manufacturer is outside the EU, the GPSR requires an EU-based Responsible Person (an economic operator established in the EU) for products covered by the GPSR. This requirement exists regardless of whether you sell through a marketplace or your own website. Depending on your supply chain, roles can include manufacturer, importer, distributor, fulfilment service provider, and online marketplace provider. The Market Surveillance Regulation (EU) 2019/1020 (MSR) also matters for how authorities enforce rules and how the Responsible Person role functions in practice, including the duty to inform the manufacturer when there is reason to believe a product presents a risk.
How do I know if my product is covered by the GPSR or by other EU rules?
Use the GPSR as the default for consumer products, then check for sector rules. The GPSR is the EU’s “safety net” for consumer products, but many products also fall under harmonised EU product legislation with additional requirements. Your goal is to identify whether your product is a consumer product and whether a more specific EU framework applies.
Quick decision flow
- Is it a consumer product? If it is intended for consumers, or likely to be used by consumers under reasonably foreseeable conditions, the GPSR is generally relevant.
- Is it new, used, refurbished, or repaired? The GPSR can apply across these conditions when the product is made available to consumers.
- Is there harmonised EU legislation for the category? Examples include toys, machinery, personal protective equipment, and many electrical and electronic products. Those rules can add obligations such as CE marking and a technical file.
- Does the GPSR still matter? Often yes, for general safety aspects not fully covered by the sector rules, and for safety management practices like corrective actions and consumer communication.
If you are unsure, start by defining the product’s intended use, reasonably foreseeable misuse, and target user group, then map the product category to applicable EU legislation before finalising labels, instructions, and documentation.
How EARP helps with GPSR compliance for direct-to-consumer EU sales
We help non-EU businesses selling through their own websites meet GPSR requirements by providing practical, EU-based compliance support focused on continuity and clear processes. Our services include:
- Acting as your EU Responsible Person (economic operator) for GPSR-covered products
- Reviewing required safety and traceability documentation for completeness
- Storing documentation and making it available to market surveillance authorities upon request
- Supporting labelling, identification, and EU contact detail setup for distance sales
- Liaising with authorities and supporting corrective actions, including withdrawals and recalls, when needed
See our services to understand the options, then contact us to discuss your product category and sales model.
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