GPSR Compliance Checklist

A working checklist for sellers placing ordinary consumer products on the EU market, with the article behind each step. It is a map of the duties, not a judgement about your product.

1. Work out which role you have

• Manufacturer: you make the product, or have it made and sell it under your own name or trademark. Most of the duties below are yours (Article 9).
• Importer: you place a product from outside the EU on the EU market. You add your own name and postal and electronic address to the product, its packaging or an accompanying document, and keep a copy of the technical documentation for 10 years (Article 11).
• Distributor: you sell products made by others. Before making a product available you verify that the manufacturer and, where applicable, the importer have met their labelling and information duties (Article 12).

Selling a supplier's product under your own brand makes you the manufacturer, with the manufacturer's duties.

2. Make sure there is an economic operator established in the EU

• A product cannot be placed on the EU market unless an economic operator established in the EU is responsible for it (Article 16).
• That operator is an EU manufacturer, or the importer, or an authorised representative with a written mandate, or, where none of those exists, an EU fulfilment service provider (Regulation (EU) 2019/1020, Article 4).
• Its name, registered trade name or trademark, and postal and electronic address go on the product, its packaging, the parcel or an accompanying document (Article 16).
• Instilus is not this operator and does not provide the role.

3. Carry out the risk analysis and write the technical documentation

• Do an internal risk analysis before the product goes on the market (Article 9).
• Draw up technical documentation containing at least a general description of the product and its safety-relevant characteristics (Article 9(2)).
• Where the risks call for it, add the analysis of possible risks, how they were removed or reduced, test report results, and the standards or other elements applied (Article 9(2)).
• Keep it up to date and available to authorities for 10 years after the product is placed on the market (Article 9(3)).
• Use the free templates on this site to structure both parts.

4. Put the required details on the product

• A type, batch or serial number, or another identifier (Article 9(5)).
• The manufacturer's name, registered trade name or trademark, and postal and electronic address (Article 9(6)).
• The importer's name, registered trade name or trademark and postal and electronic address, where there is an importer (Article 11(3)).
• Where the product is too small or it is otherwise not possible, these go on the packaging or an accompanying document.

5. Supply instructions and safety information in the right language

• Clear instructions and safety information in a language consumers can easily understand, as determined by the country of sale (Article 9(7)).
• This does not apply where the product can be used safely and as intended without them.
• A digital format such as a QR code may be provided in addition, not instead (Article 21).

6. Fill in every online listing

• Manufacturer name, registered trade name or trademark, and postal and electronic address (Article 19).
• The EU responsible person's name and addresses, where the manufacturer is outside the EU (Article 19).
• Information identifying the product, including a picture, its type and any other identifier (Article 19).
• Any warnings or safety information, in the language required by the country of sale (Article 19).
• Marketplaces must give you fields for this and display it on the listing (Article 22).

7. Be ready for accidents, complaints and recalls

• Notify accidents causing death or serious harm through the EU Safety Business Gateway without undue delay (Article 20).
• Where the manufacturer is outside the EU, the EU responsible person makes sure the notification happens (Article 20).
• If a product is dangerous, take corrective action immediately, inform consumers and notify authorities (Article 9(8)).
• Have a way for people to complain and to reach you, and keep a register of complaints.

Penalties are set by each EU country, not by the regulation itself (Article 44), so the consequences differ by market.

Common questions

When did GPSR start to apply?

It has applied since 13 December 2024, to products placed on the EU market, including by sellers based outside the EU.

Is there a small-seller exemption?

No. The regulation sets no turnover threshold and no hobby allowance. Duties do differ by role: a distributor carries lighter duties than a manufacturer.

How long must technical documentation be kept?

10 years after the product has been placed on the market, available to market surveillance authorities on request (Article 9).

Can Instilus act as my EU Responsible Person?

No. Instilus prepares documentation from information and documents you supply. The EU operator role is a separate appointment you make yourself.

Sources

• Regulation (EU) 2023/988 (General Product Safety Regulation)
• Regulation (EU) 2019/1020, Article 4 (economic operator for products from outside the EU)
• European Commission Notice C/2025/6233: Guidelines on the application of the EU general product safety legislative framework by businesses