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Regulation Update

CE Marking vs GPSR: Are They the Same? What Sellers Need to Know (2026)

CE marking and GPSR are not the same thing. If your product has a CE mark, you may still be missing key GPSR requirements. Here is what the difference actually means for sellers.

SellSafe TeamApril 9, 20265 min read

Quick Summary

CE marking and GPSR are not the same thing. If your product has a CE mark, you may still be missing key GPSR requirements. Here is what the difference actually means for sellers. Read on for the complete breakdown, action checklists, and compliance strategies.

If your product has a CE mark, you might assume you are GPSR compliant. You are not — at least not automatically. CE marking and GPSR are two separate compliance requirements that overlap in some areas but leave significant gaps when treated as interchangeable. This confusion is the most common compliance mistake we see across seller communities.

This post explains the difference, where the two frameworks overlap, and what CE-marked product sellers still need to do to meet GPSR obligations. For Amazon sellers working through the basics, start with the [GPSR Compliance Checklist for Amazon Sellers](/resources/blog/gpsr-compliance-checklist-amazon-sellers).

CE marking — what it means and what it does not mean

CE marking is a product-specific declaration that your product meets the requirements of specific EU harmonised technical directives. Which directives apply depends on the product category:

  • **Low Voltage Directive (2014/35/EU)** — electrical equipment operating between 50V and 1000V AC
  • **Toy Safety Directive (2009/48/EC)** — toys intended for children under 14
  • **PPE Regulation (EU) 2016/425** — personal protective equipment
  • **Machinery Directive 2006/42/EC** — powered machinery and safety components

CE marking is self-declared by the manufacturer for many product categories. There is no government body that approves a CE mark — you assess conformity against the applicable standards, generate a Declaration of Conformity referencing those standards, and affix the mark. For higher-risk categories (certain PPE, lifts, some medical devices), independent assessment by a Notified Body is required.

What CE marking covers: technical safety requirements for the product's design, construction, and performance. It answers the question: does this product meet the technical standards for this category?

What CE marking does NOT cover: post-market obligations, product traceability requirements, responsible person requirements, or ongoing surveillance obligations. This is where GPSR comes in.

GPSR — a different layer of compliance

The General Product Safety Regulation (EU 2023/988), in force since December 13, 2024, is a broader market access framework that applies to almost all consumer products — including those that also carry a CE mark.

GPSR covers what CE marking does not:

  • **Product traceability** — batch or lot numbers on products or packaging, and manufacturer contact information visible on the product or packaging
  • **Responsible Person** — if you are not established in the EU, you must appoint an EU-based Responsible Person who holds your technical documentation and liaises with regulators
  • **Post-market surveillance** — a documented process for collecting consumer complaints and incident reports, monitoring relevant standards changes, and annual documentation reviews
  • **Incident reporting** — serious accidents must be reported to the EU Safety Gate system within three business days
  • **Consumer-facing safety information** — in the official language of each EU market where you sell

The critical point: GPSR requirements apply on top of CE marking requirements, not instead of them. A product can be fully CE-marked and still be non-compliant with GPSR. These are different checklists addressing different compliance dimensions.

Where CE marking and GPSR overlap — and where you still have gaps

Some requirements overlap, but the details differ enough to create practical compliance gaps for sellers who assume one covers the other:

RequirementCE MarkingGPSR
Technical safety standardsYesNo
Declaration of ConformityYes (directive-specific)Yes (GPSR obligations separate)
EU Responsible PersonNoYes (if non-EU manufacturer)
Batch/lot number on productNoYes
Post-market surveillanceNoYes
Incident reportingNoYes
Safety information in local languagePartiallyYes (expanded requirements)

The Declaration of Conformity deserves attention. CE marking requires a DoC that references the applicable harmonised directives and standards. GPSR has its own documentation obligations — your existing CE marking DoC does not cover GPSR's additional traceability and responsible person requirements. Most DoCs drafted before 2024 will not reference EU 2023/988 at all. You may need to issue a supplementary declaration or update your existing one.

You have a CE mark — here is what GPSR still requires

If your product is already CE-marked, work through this checklist:

  • [ ] **Check your Declaration of Conformity** — does it reference GPSR (EU 2023/988) explicitly? If not, issue a supplementary declaration or update the existing one.
  • [ ] **Appoint an EU Responsible Person** — required if you are not established in the EU. For guidance on finding and appointing one, see the [EU Authorised Representative guide](/resources/blog/eu-authorised-representative-gpsr-guide).
  • [ ] **Add batch/lot number to product or packaging** — if not already present. If the product size makes direct marking impractical, it may appear on the smallest accompanying document.
  • [ ] **Establish a post-market surveillance process** — at minimum: a process for reviewing customer complaints for safety implications, and an annual documentation review. Document the process itself in your technical file.
  • [ ] **Verify safety information is in local language** — for each EU market where you sell. GPSR expanded the language requirements beyond what some earlier directives specified.
  • [ ] **Check Amazon's Regulatory Compliance Portal** — Amazon requires GPSR-specific fields (manufacturer information, Responsible Person details, safety attestation) regardless of CE marking status. CE marking alone does not satisfy Amazon's GPSR submission requirements.

Takeaways

CE marking covers technical safety requirements for specific product categories. GPSR is an additional compliance layer covering traceability, responsible persons, post-market obligations, and incident reporting. Having a CE mark does not exempt you from GPSR, and assuming it does is the most common compliance gap regulators and Amazon are now enforcing against.

Not sure which GPSR requirements still apply to your CE-marked product? The [SellSafe audit wizard](https://sellsafe.eu/audit?utm_source=blog&utm_medium=organic&utm_campaign=ce_vs_gpsr) maps your product against the regulations that apply to it in 15 minutes. Free to start, no registration required.

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