What is the difference between the GPSR and the old General Product Safety Directive?

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Jason van de Zande

The General Product Safety Regulation (EU) 2023/988 (GPSR) replaces the former General Product Safety Directive (GPSD) and updates EU-wide consumer product safety rules for modern supply chains, especially online sales. The biggest difference is that the GPSR is a regulation that applies directly across the EU, with clearer duties for manufacturers, importers, distributors, fulfilment service providers, and online marketplaces. Below are the key definitions, changes, and practical compliance steps.

What is the GPSR, and what was the General Product Safety Directive (GPSD)?

The GPSR is the EU’s current horizontal consumer product safety law, while the GPSD was the previous framework that it replaces. The GPSR is Regulation (EU) 2023/988. The GPSD was Directive 2001/95/EC. Both set general safety requirements for consumer products, especially where no more specific EU harmonisation legislation applies.

The GPSR entered into force on 12 June 2023 and has applied since 13 December 2024. It works alongside sector-specific rules—for example, toy, electrical, or radio equipment legislation—where those rules exist. When a product is covered by specific harmonisation legislation, those rules apply first, and the GPSR fills gaps relating to general safety, accidents, and market surveillance cooperation.

What are the key differences between the GPSR and the GPSD?

The GPSR is more directly enforceable and more explicit about online and supply chain responsibilities than the GPSD. Because it is a regulation, it applies uniformly across EU Member States without requiring national transposition, reducing variation in how core obligations are implemented.

Topic GPSD (2001/95/EC) GPSR (EU) 2023/988
Legal form Directive, implemented via national laws Regulation, directly applicable across the EU
Online marketplaces Less detailed, from the pre-platform enforcement era Specific duties, including contact points, cooperation, and recall support
Traceability and identification General expectations Clearer product identification and distance-sales display expectations
Risk assessment and safety info General safety duty Stronger emphasis on proactive risk assessment and clear warnings in appropriate languages
Accident reporting and corrective action Less structured reporting approach More explicit expectations for accident reporting and effective recalls and withdrawals
EU-based economic operator Not framed the same way Explicit requirement for an EU-based responsible person for certain products sold via distance sales, where needed

Another practical change is stronger alignment with modern market surveillance tools and cooperation, including the Safety Gate ecosystem and business reporting workflows. The GPSR also clarifies that standards can support a presumption of safety when relevant European standards exist, while still allowing authorities to act if a product is dangerous in practice.

Who must comply with the GPSR, and what practical steps should businesses take?

The GPSR applies to virtually all non-food consumer products made available in the EU, including new, used, repaired, or reconditioned products, and it also covers distance-sales offers targeting EU consumers. It sets obligations for manufacturers, importers, distributors, authorised representatives (where appointed), fulfilment service providers, and online marketplace providers.

Practical steps that usually matter most for day-to-day compliance include:

  1. Confirm applicable rules: Identify whether sector-specific EU harmonisation legislation applies in addition to the GPSR.
  2. Build and maintain technical documentation that supports product safety, including a documented risk assessment and supporting evidence.
  3. Meet traceability basics: Ensure product identification, manufacturer contact details, and supply chain information are consistent across the product, packaging, and instructions, where required.
  4. Provide clear safety information: Include warnings and instructions in the languages required for the Member States where the product is sold.
  5. Set up accident handling: Monitor complaints and accident information, investigate, and keep an internal register of complaints, recalls, and corrective measures.
  6. Prepare corrective actions: Have a documented process for withdrawal, consumer safety warnings, and recalls, including how you will contact affected consumers.
  7. Ensure an EU-based responsible person where required, especially for distance-sales models where there is no other suitable EU economic operator in the supply chain.

Online marketplaces may request proof that the required economic operator details and product information are in place before listings remain active, so it helps to treat documentation and listing data as part of compliance, not just packaging.

How EARP helps with GPSR compliance and the transition from the GPSD

We help non-EU manufacturers, brands, and sellers meet GPSR obligations with an EU-based compliance setup, including the responsible person role where required, and authorised representative support where applicable. Our work focuses on keeping documentation and communications with authorities organised, consistent, and ready when requested.

  • Acting as the EU responsible person and, where appointed, authorised representative
  • Document presence and completeness checks, plus secure technical documentation storage
  • Liaison with national market surveillance authorities and support during information requests
  • Guidance on labelling, traceability, and required safety information for distance-sales offers
  • Support for corrective actions, including withdrawal and recall readiness

See our services or contact us to discuss your products and the fastest path to GPSR-compliant EU market access.

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