A trading name of A Star Supply · ContactA trading name of A Star Supply · ContactSellers of downloads, templates, apps and digital art keep asking whether the EU product safety rules reach them. The regulation itself does not use the word "digital" in its definition of a product, but the Commission's guidelines do. Here is what each source actually says.
Article 3(1) defines a product as any item, whether or not it is interconnected to other items, supplied or made available, whether for consideration or not, including in the context of providing a service, which is intended for consumers or is likely, under reasonably foreseeable conditions, to be used by consumers even if not intended for them.
Three things follow from the wording. It says "item", not "goods". It covers things supplied free of charge. And it covers items supplied as part of a service.
The exclusions in Article 2(2) are a closed list: medicinal products, food, feed, living plants and animals and GMOs, animal by-products, plant protection products, certain ride-on or travel equipment operated by a service provider, certain aircraft, and antiques. Digital items are not on that list.
The Commission's November 2025 guidelines for businesses say the GPSR product definition is wide enough to cover "any item", whether tangible or non-tangible or of a mixed nature, and that it includes apps and software products, including for example chatbots, and sets requirements for their safety.
That is the clearest official statement on the point. It is also guidance rather than law: the guidelines state that they are intended purely as a guidance document, that only the text of the EU legislation itself has legal force, and that binding interpretation is the exclusive competence of the Court of Justice of the European Union.
The Commission names apps and software. It does not give a worked example of a downloadable file such as a pattern, a printable or an ebook, and neither does the regulation.
The guidelines put it directly: services are not covered by the GPSR, but products provided to consumers in the context of a service are covered. Their examples are a rented bike used away from the provider's premises, gym machines the consumer operates, and cosmetics or tattoo inks applied to consumers during a service.
So the question is not whether money changed hands for a service. It is whether an item reaches the consumer.
Where software sits inside something physical, the regulation is explicit. Recital 25 says new technologies might substantially modify the original product, for instance through software updates, which should then be subject to a new risk assessment if the modification has an impact on safety.
The guidelines add that a modification by physical or digital means that was not foreseen in the initial risk assessment is a substantial modification, and that where it is not done by the consumer, the product is considered a new product from a different manufacturer, with the person making the modification treated as the manufacturer for the modified part.
Article 15 requires economic operators to be able to identify any operator that supplied them with a part, a component or any software embedded into the product, and Article 15(5) sets that record period at six years.
Etsy states that GPSR applies to all types of products, both physical and digital, unless they are covered by other safety regulations. Its opt-out setting is built the same way: under Shop Manager, Settings, Options, "Choose how you sell to GPSR states", physical items and digital items are separate choices.
A marketplace's policy is not the law, but it is what decides whether your listing stays visible. Etsy also says it cannot advise whether you qualify as a trader.
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Article 4 matters too: an offer online is treated as making the product available on the EU market if it is targeted at consumers in the EU. The guidelines list the factors weighed case by case, including where you ship to, the languages of the offer, the payment methods and the currency or domain name you use.
No official source we could find applies the GPSR to a plain downloadable file such as a PDF pattern or a set of printables. The regulation gives no digital exclusion, the Commission points at apps and software, and marketplaces like Etsy apply their fields to digital listings anyway.
If the answer changes what you sell or how you price it, that is a question for your own legal adviser. Instilus does not give compliance verdicts and is not a Responsible Person.
The regulation defines a product as "any item" and does not exclude digital items. The European Commission's 2025 guidelines say the definition is wide enough to cover any item, tangible or non-tangible, and that it includes apps and software products. Those guidelines are guidance, not binding law.
Etsy says GPSR applies to all types of products, both physical and digital, unless covered by other safety regulations, and its GPSR opt-out treats physical and digital items as separate choices. That is Etsy's policy; the regulation itself does not single out digital files.
No. The Commission's guidelines say services are not covered, but products provided to consumers in the context of a service are, giving rented bikes, gym machines and tattoo inks as examples.
It can. Recital 25 says a substantial modification, for instance through a software update, should be subject to a new risk assessment where it affects safety, and the guidelines say the person making a substantial modification is treated as the manufacturer for the modified part.
No. Article 21 allows information to be made available additionally in a digital format. It is in addition to the information required by Articles 9, 11 and 16, not instead of it.
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