Consumer Electronics – EU Representation for GPSR Compliance
Ensure your consumer electronics and smart devices meet EU GPSR rules with EARP’s independent Representation services.
Smart products need solid compliance
Consumer electronics and smart devices have become central to daily life but they also pose specific risks that EU rules are designed to manage. Risks include electrical shocks, overheating batteries, electromagnetic interference, misuse injuries, and even data privacy breaches for connected devices.
In the EU, the General Product Safety Regulation (EU) 2023/988 (GPSR) applies to all consumer electronics regardless of CE marking under directives like the Radio Equipment Directive (RED) or Low Voltage Directive (LVD). The GPSR governs safety labeling, user instructions, robust documentation, and post-market traceability to ensure products remain safe and compliant throughout their lifecycle.
For non-EU manufacturers, meeting these requirements is critical to avoid customs delays, online platform removals, or regulatory enforcement. EARP specializes in supporting electronics brands with GPSR compliance for a seamless, compliant route to EU markets.
What the GPSR implies for electronics
Under the GPSR you must be able to show that your device is safe for its intended use and foreseeable misuse, and that authorities can reach an EU contact quickly if something goes wrong. To do so, you must complete a risk analysis and keep technical documentation that describe your product and explains your design, hazards, test evidence and solutions.
Present the product clearly: manufacturer identity and a postal address, product identification (model/batch/serial) for traceability, and instructions/warnings that match the risks, including software or interconnectivity aspects that can affect safety.
Common risk to address
Failures in electronics cluster around energy and change. Chargers and power stages run hot under misuse, cells degrade and swell, and software updates can alter behaviours your original tests never covered. Document how your design remains safe across realistic abuse, such as blocked vents, cheap cables, aged cells and show how firmware or app updates are validated for safety, not just features..
What are consumer electronics & smart devices?
This category covers a wide range of powered consumer products, from simple electrical devices to advanced app-connected or IoT-enabled gadgets. Examples include:
Household electronics (hair dryers, shavers)
Audio devices (radios, portable speakers)
App-connected kitchen appliances
Smart hygiene devices (toothbrushes, massagers)
Internet-connected toys and personal gadgets
Wearables or gadgets with Bluetooth or Wi-Fi connectivity
All consumer electronics sold in the EU must be safe for their intended and foreseeable use, with clear labeling, comprehensive technical documentation, and accessible user instructions.
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 consumer electronics or smart devices to EU consumers, you must have an EU-based Responsible Person as required by GPSR Article 16(1). This obligation exists even for CE-marked products since the GPSR applies in parallel to ensure post-market safety and documentation.
If no importer, distributor, or fulfillment provider formally accepts this role, appointing an Authorized Representative is the established way to meet this legal requirement. Given the higher regulatory scrutiny for electronics (due to electrical safety, overheating risks, and data security concerns), an Authorized Representative helps maintain smooth customs clearance, platform listings, and ongoing market access.
We can act as your Authorized Representative and your EU-based Responsible Person. Find out who we are.
Helpful ArticleWhy Choose EARP as Your Responsible Person
EARP offers specialized services tailored to consumer electronics and smart device manufacturers. Our support includes:
- Acting as your official EU contact point for regulatory authorities and market surveillance teams
- Verifying safety documentation under GPSR Article 9, including risk assessments, labeling, and user instructions
- Ensuring accurate traceability labeling and authorized EU contact details on packaging or manuals
- Cooperating with EU authorities during inspections, complaints, or investigations
- Supporting post-market obligations like recalls or safety communications when needed
- Providing guidance and templates to help build a complete, compliant GPSR technical file
We keep roles clear, coordinate with authorities, and help your team keep documentation, labelling and post-market actions aligned, so you can sell confidently across the EU. Read more about EARP’s representation services.
We operate independently of your importers or distributors, giving you flexibility in your commercial strategy while meeting strict EU compliance requirements.
FAQs – Consumer Electronics & Smart Devices
Yes. The GPSR always applies in parallel, ensuring labeling, documentation, and post-market safety obligations are met even for CE-marked devices.
If sold to EU consumers, they still need to meet GPSR requirements. You must appoint an AR unless another operator formally assumes the role.
Yes. Devices with wireless features are governed by the RED, and embedded AI may trigger AI Act obligations. GDPR also applies for personal data processing. EARP supports GPSR obligations but does not directly provide GDPR or AI Act compliance.
