GPSR enforcement in 2026: Amazon suspensions, EU fines, and what sellers face right now
Sixteen months since GPSR became mandatory, enforcement is escalating. Amazon is suspending listings at scale. EU market surveillance authorities in Germany, France, and the Netherlands are actively investigating. Here is a clear-eyed account of what is actually happening — and what it means for sellers who are still exposed.
Quick Summary
Sixteen months since GPSR became mandatory, enforcement is escalating. Amazon is suspending listings at scale. EU market surveillance authorities in Germany, France, and the Netherlands are actively investigating. Here is a clear-eyed account of what is actually happening — and what it means for sellers who are still exposed. Read on for the complete breakdown, action checklists, and compliance strategies.
The General Product Safety Regulation (GPSR, EU 2023/988) became mandatory on December 13, 2024. Sixteen months later, the "transition" narrative is over. Enforcement is not a theoretical future risk — it is a documented present reality, and the volume of actions is increasing.
This post gives sellers an honest account of what is happening: what Amazon is doing, what EU market surveillance authorities are doing, what the consequences look like, and what sellers who have not yet complied need to prioritise.
Amazon's enforcement is systematic, not occasional
Amazon has integrated GPSR verification into its core marketplace infrastructure. This is not a manual review process — it is a rules-based system applied across every EU marketplace: Amazon.de, Amazon.fr, Amazon.it, Amazon.es, and Amazon.nl.
When a listing triggers a GPSR compliance flag, Amazon's standard response is suspension. Sellers receive a notification in [Seller Central's Account Health dashboard](https://sellercentral.amazon.com/help/hub/reference/external/GVLMMND7YWLQLYDU), typically citing specific missing information. The most common triggers:
- **No EU Responsible Person (Authorised Representative) recorded** — Amazon requires an AR name and EU contact address in every product listing where the seller is not EU-established. Missing this field alone is sufficient to suspend a listing.
- **Incomplete Regulatory Compliance Portal submission** — Amazon requires manufacturer details, AR details, and a safety attestation. Partial submissions do not satisfy the requirement.
- **Missing product label documentation** — Amazon asks for images showing that batch and lot numbers, manufacturer contact, and AR contact appear physically on the product or packaging.
- **Product category flagged for known documentation gaps** — Electronics, toys, sporting goods, and personal care products face elevated scrutiny.
The process after suspension matters. Sellers who immediately raise disputes or appeals consistently report longer resolution times than sellers who go directly to the Regulatory Compliance Portal and submit the missing documentation. Amazon's system is designed to receive documentation, not to negotiate about it. Work within the system.
Sellers who relist a suspended ASIN through a variant ASIN, a different marketplace account, or product bundling to escape the flag risk account-level enforcement rather than listing-level enforcement. Amazon's compliance system is sophisticated enough to identify these patterns.
EU market surveillance authorities are acting
Amazon enforcement is only one channel. EU market surveillance authorities operate independently of Amazon and have significantly broader powers.
Each EU member state has designated market surveillance authorities under GPSR. The most active in cross-border e-commerce enforcement are:
Germany: Multiple authorities operate depending on product category — the Bundesamt für Verbraucherschutz und Lebensmittelsicherheit (BVL) for consumer goods, state-level Landesämter for specific product categories, and the Bundesnetzagentur for radio equipment. Germany has a long history of aggressive product safety enforcement and regularly contributes the highest volume of notifications to the EU Safety Gate system.
France: The Direction Générale de la Concurrence, de la Consommation et de la Répression des Fraudes (DGCCRF) conducts systematic market sweeps across e-commerce platforms, including investigation of products sold by non-EU-established sellers through EU marketplaces.
Netherlands: The Nederlandse Voedsel- en Warenautoriteit (NVWA) has explicit e-commerce enforcement programmes targeting non-compliant products sold into Dutch markets through online platforms.
These authorities do not require a consumer complaint to investigate. They conduct proactive market surveillance — sampling products from online listings, requesting documentation, and escalating where documentation is missing or inadequate.
Under GPSR, authorities have extensive enforcement powers: they can order immediate market withdrawal, issue mandatory product recalls, require corrective labelling, and impose bans on further sales. Serious infringements can be referred to criminal prosecution channels under national law.
The EU Safety Gate system — the EU's rapid alert system for dangerous products — publicly records product withdrawals and recalls. Notifications in this system are searchable and permanent. Being listed in the EU Safety Gate as a product subject to a safety withdrawal or recall carries reputational consequences that extend well beyond the immediate enforcement action.
What non-compliance actually costs
GPSR Article 45 requires member states to establish penalties for infringements that are "effective, proportionate and dissuasive." Member states have implemented this through national legislation with varying specific amounts, but the principle is consistent: penalties are designed to be meaningful relative to the economic benefit of non-compliance.
Beyond financial penalties, the real costs of enforcement action are often operational:
Sales suspension: From the moment a market surveillance authority issues a sales ban, you cannot legally sell the product in that member state. If the authority refers the matter to the EU Safety Gate, the action becomes visible across all EU markets.
Recall costs: If an authority orders a recall, you are responsible for the full cost of the recall process — consumer communications, collection logistics, refunds or replacements, and disposal. For a product with significant market penetration, recall costs can far exceed any financial penalty.
Amazon account consequences: A formal enforcement action in a member state is grounds for Amazon to take account-level action, not just listing-level action. A seller subject to a regulatory withdrawal order in Germany risks losing EU marketplace access entirely.
Documentation demands with short windows: Market surveillance authorities can demand your technical file within 10 days of a request. If you cannot produce one — because it does not exist, or because your AR no longer holds your documents — you are in immediate default with no recourse.
The violations authorities are finding most often
Based on enforcement activity across EU markets since GPSR mandatory status began, certain compliance gaps appear consistently:
Missing or unqualified EU Authorised Representative. The AR must be incorporated in an EU member state, hold your technical documentation, and be reachable by authorities. AR services that provide only a postal address without actually holding documents are not GPSR-compliant and do not satisfy the requirement. Several providers operating in this model have attracted authority attention.
Generic Declarations of Conformity. A Declaration of Conformity that does not cite specific harmonised standard numbers — or that cites outdated standard versions — does not satisfy GPSR. Authorities are finding DoCs that reference regulations without naming specific standards, DoCs signed before test reports were completed, and DoCs issued by suppliers without the brand owner's knowledge or active review.
Safety information not in the local market language. Safety warnings and instructions must appear in the official language of each member state where the product is sold. A product sold in Germany, France, and Spain with only English-language safety information is non-compliant in all three markets. This is one of the easiest violations to identify in a market sweep — and one of the most common.
No product traceability — missing batch or lot numbers. Products must carry a batch or lot identifier linking the physical product to its production documentation. Products without this marking cannot be traced if a safety incident occurs, which is precisely why GPSR requires it. Authorities conducting physical product checks flag this immediately.
Inadequate post-market surveillance processes. GPSR requires a documented system for collecting and reviewing complaints and incident reports, and for reporting serious incidents to the EU Safety Gate within three business days. "We read the reviews" does not constitute a documented process. Authorities looking at systematic compliance will ask whether a process exists and whether it is followed.
What sellers with open exposure need to do now
The practical priority is documentation. Most Amazon sellers with GPSR gaps are not selling dangerous products — they are selling products that may be safe in practice but lack the documentation to demonstrate it. That is a fixable problem, but it is only fixable if you act before you receive an enforcement notice rather than after.
Appoint an EU Authorised Representative first. If you are not EU-established, get this in place before anything else. An AR appointment cannot be backdated — your exposure window runs from the day your product went on sale in EU markets to the day your AR appointment takes effect. For full guidance on what an AR does and how to choose one, see the [EU Authorised Representative GPSR guide](/resources/blog/eu-authorised-representative-gpsr-guide).
Review your technical file and test reports. The technical file is what everything else rests on. If your file is incomplete — missing an accredited test report, missing a risk assessment, missing traceability records — you cannot sign a credible Declaration of Conformity. Commission any missing accredited laboratory testing as a priority. Test reports must come from ISO 17025 accredited laboratories; factory test reports do not satisfy the requirement.
Produce a correct Declaration of Conformity. With your technical file in order, produce a DoC that cites specific harmonised standards by version number and lists all applicable EU directives. A generic DoC is worse than no DoC — it creates a record of a specific claim that can be shown to be wrong. See the full requirements in our [Declaration of Conformity guide for GPSR and CE marking compliance](/resources/blog/declaration-of-conformity-gpsr-ce-marking-2026). If your product requires CE marking, understand how [CE marking and GPSR interact — they are not the same requirement](/resources/blog/ce-marking-vs-gpsr).
Verify product labelling across your active inventory. Check that every active SKU carries the required physical information: manufacturer contact, batch and lot number, AR contact, CE mark if applicable, and safety warnings in the language of each target market. The practical checklist is in the [GPSR Compliance Checklist for Amazon Sellers](/resources/blog/gpsr-compliance-checklist-amazon-sellers).
Complete Amazon's Regulatory Compliance Portal submission. With documentation in order, complete your Seller Central Regulatory Compliance Portal submission. This removes the product from Amazon's automatic flag queue and records your compliance attestation.
Document your post-market surveillance process. A written process for complaint review, incident escalation, and annual documentation review is a GPSR obligation. It does not need to be elaborate — it needs to be documented and consistently followed.
The enforcement window sellers should understand
Enforcement is escalating but it is not yet uniformly comprehensive. Market surveillance authorities have finite capacity, and resources are concentrated on the highest-risk product categories and the most visible non-compliance. Sellers who get compliant before receiving a notice avoid the hardest consequences. Sellers who start the compliance process after receiving a notice are managing enforcement outcomes, not preventing them.
The compliance gap between sellers who have sorted their documentation and sellers who have not is becoming a commercial advantage. Compliant sellers can hold their listings. Non-compliant sellers face uncertainty with every Amazon update and every market sweep.
[Start the free SellSafe audit](https://sellsafe.eu/audit?utm_source=blog&utm_medium=organic&utm_campaign=gpsr_enforcement_2026) — it maps your products against every applicable regulation, identifies documentation gaps, and gives you a prioritised action plan in 15 minutes. No consultant required, and free to start.
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