GPSR Compliance for EU/UK Sellers: What You Actually Need

EU Responsible Person

Every non-EU manufacturer selling into the EU must appoint an EU Responsible Person — a legal entity established inside the EU. This person's name and postal or electronic address must appear on the product or its packaging. The RP acts as the official compliance contact for EU authorities, holds the technical documentation, and is legally responsible for ensuring the product satisfies GPSR. For UK businesses post-Brexit, a UK-based company no longer qualifies. You need a separate EU-based entity: your EU distributor, or a specialist RP service provider. Missing or invalid RP details are the leading cause of GPSR enforcement action on online marketplaces.

Technical Documentation and Declaration of Conformity

GPSR requires economic operators to prepare and maintain technical documentation demonstrating product safety. This includes risk assessments, test reports, component specifications, and manufacturing process details. The technical file must be retained for 10 years from the date the product was first placed on the EU market. A Declaration of Conformity referencing EU 2023/988 is also required for relevant product categories. This documentation must be made available to national market surveillance authorities on request — failure to produce it within the required timeframe is itself a compliance breach under Article 9.

Correct Labelling

Products sold in the EU under GPSR must carry specific traceability information at the unit level — not just on outer cartons. The manufacturer's name, trademark, and postal or electronic address must appear on the product or its individual packaging. If you are a non-EU manufacturer, the EU Responsible Person's details are also required. Products must include batch or serial numbers for traceability purposes. Warnings and instructions must be in the official language(s) of the country where the product is sold. Labelling deficiencies are among the most common triggers for marketplace enforcement action and authority inspections.

Post-Market Monitoring

GPSR compliance does not end at the point of sale. Sellers and manufacturers must actively monitor products after they reach consumers: tracking complaints, reviewing injury reports, conducting sample testing where appropriate, and taking corrective action — including voluntary recalls — when safety concerns emerge. If a product poses a serious risk to consumer safety, you must notify the relevant national authority. Post-market monitoring is the GPSR obligation most frequently overlooked by smaller sellers managing large catalogues, and it is increasingly a focus of national enforcement programmes.

Many sellers either skip the EU Responsible Person requirement entirely or appoint someone who does not qualify — for example, a UK-based company, or a logistics provider with no actual compliance mandate. Amazon and other EU marketplaces now require valid RP details at the point of listing. Products found without a compliant EU RP risk immediate delisting, and enforcement authorities can issue market withdrawal orders without further warning. Getting the RP right is the single most important first step.

Some sellers issue a DoC that references the wrong regulation, covers the wrong product range, or was originally prepared for CE marking and incorrectly repurposed for GPSR. A valid GPSR Declaration of Conformity must specifically reference EU 2023/988, clearly identify the product by type and batch or model number, and be signed by an authorised representative. Marketplace compliance teams are increasingly checking DoC validity — a CE marking DoC does not automatically satisfy GPSR obligations.

Missing manufacturer address, absent batch numbers, and wrong-language warnings are the most frequent enforcement triggers under GPSR. Many sellers place labelling information only on outer cartons rather than on the product or individual unit packaging. GPSR requires traceability at the unit level. When a marketplace or national market surveillance authority inspects a product and finds incomplete labelling, the standard response is delisting first and investigation second — restoring a suspended listing typically takes weeks.