EU Authorized Representative & GPSR Compliance for Clothing & Textiles
Ensure your clothing and wearables meet EU GPSR requirements with EARP’s trusted Authorized Representative services.
What you wear must comply
Clothing and wearable accessories might seem low-risk, but they can pose serious safety concerns, especially for children and infants. Risks include choking from detachable parts, flammability in sleepwear, entrapment hazards (like drawstrings), and exposure to harmful chemicals in textiles or dyes.
The General Product Safety Regulation (EU) 2023/988 (GPSR) ensures that clothing sold in the EU includes clear labeling, robust safety documentation, and traceability. This helps protect consumers, particularly children, by ensuring garments meet safe design and material standards.
Under the GPSR you’re expected to show that your products are safe for their intended users and conditions, and that authorities can reach an EU contact quickly if something goes wrong. For non-EU brands, meeting these requirements is essential to avoid customs blocks, retailer delistings, or enforcement actions. EARP supports global clothing brands in achieving GPSR compliance for seamless access to EU fashion markets.
What the GPSR expects for apparel
Before placing products on the EU market, complete a risk analysis and keep technical documentation that explains the product, hazards considered, and measures chosen, which must be supported by tests where appropriate. Present the product clearly to consumers: identity and a postal address for contact, a model or batch reference for traceability, and instructions or warnings that match the risks. For non-EU brands, ensure there is an EU-based Responsible Person (RP); a manufacturer may appoint an Authorized Representative (AR) by written mandate and designate that AR to act as the RP.
What authorities flag
Most enforcement in apparel starts with chemistry and small design details. For chemistry, azo dyes in dark or intense colours, chromium VI formation in certain leathers, and nickel release from trims top the list. For children’s clothing, cords and drawstrings are a recurring design hazard. Build your file around these realities and test what you actually ship and make sure labels and care instructions align with the material choices you’ve made.
Safety documentation that helps demonstrating compliance:
- A trim & material map (all fabrics, leathers, inks, metal parts) tied to the purchase order and batches.
- Current lab reports for the exact article/colourway and metal components that touch skin.
- Pattern notes confirming no prohibited cords/drawstrings for the intended age range.
Which Clothing & Textile Products Are Covered?
This category includes all non-CE-marked consumer clothing and textiles sold to EU consumers, including products for infants, children, and adults. Items sold via online stores, global retailers, or fashion brands must meet GPSR requirements. Examples include:
Seasonal outerwear and accessories
Children’s pyjamas and sleepwear
Thermal or heated garments
Reflective vests and visibility gear
Fashion items with functional features
Everyday casual and loungewear
All clothing and wearable products must be safe under normal use, with clear labeling, age suitability warnings if needed, and accessible technical documentation.
Relevant legislation
Disclaimer: This list is not exhaustive and may not apply to all products; manufacturers must identify all applicable EU requirements.
Do you need an EU Responsible Person?
Yes. If you are a non-EU manufacturer selling clothing or textiles to EU consumers, you must ensure these products have an EU-based Responsible Person under GPSR Article 16(1). This rule applies to items sold via online marketplaces, fashion retailers, or global fulfillment providers.
If no importer, distributor, or partner formally assumes this role, appointing an Authorized Representative is the recognized way to meet your legal obligations. For clothing, this is crucial given the risks of chemical exposure, flammability, or small parts in children’s wear and ensures your products remain accessible in the EU without customs issues or retailer removals. Many brands choose an independent AR and designate it as RP to avoid conflicts of interest and to centralise documentation and authority communications across Member States.
We can act as your Authorized Representative and your EU-based Responsible Person. Find out who we are.
Read this Helpful Article for more informationWhy Choose EARP as Your Responsible Person
EARP offers specialized AR and RP services for clothing and wearable brands entering the EU market. Our support includes:
- A named EU contact point and the right to use our EU address on product/pack/instructions where required.
- Labelling and information review for identity, traceability, and warnings that match your risk profile.
- A practical check of your technical documentation against GPSR expectations; gap notes and suggested test evidence.
- Support to prepare and submit Safety Business Gateway notices without undue delay when serious risks or accidents arise.
- Coordination with market surveillance during complaints, withdrawals/recalls, and follow-up updates.
- Providing templates and guidance to help build GPSR-compliant technical files
Read more about EARP’s representation services.
We deliver these services independently of your supply chain partners, offering flexibility while ensuring full EU compliance for clothing and wearable products.
FAQs – Clothing & Wearables
GPSR requires products to be safe under normal use. Testing may be necessary to demonstrate safety, which especially applies to flammability in children’s sleepwear or chemical content under REACH.
Yes. If you’re outside the EU, the GPSR requires you to appoint an EU-based AR to ensure traceability and compliance.
Yes. If EARP is your AR, our verified EU contact must appear on the product, packaging, or an accompanying document, as per GPSR Article 16(3).
No. EARP doesn’t test products but verifies documentation and guides you on meeting GPSR administrative obligations.
