GPSR for US brands: your EU responsible person, your label and your listing

For many US brands, the EU's General Product Safety Regulation first shows up as a new mandatory field in a marketplace listing form. Behind it is a simple rule: since 13 December 2024, a consumer product can only be sold in the EU if someone established in the EU is responsible for it.

What GPSR is

The General Product Safety Regulation, Regulation (EU) 2023/988, replaced the EU's 2001 product safety directive. It has applied across the EU since 13 December 2024, and in Northern Ireland as well.

It covers consumer products sold in shops and online, including products shipped from outside the EU. An online offer counts as made available in the EU when it is directed at EU consumers, for example by delivering there or showing prices in a local currency.

Which products it covers

Most non-food consumer products: home goods, apparel, accessories, toys, electronics, cosmetics. Where sector rules already deal with safety, as they do for toys, electrical goods and cosmetics, GPSR fills the gaps, such as online listing information and accident reporting.

Food, including food supplements, and medicines are outside GPSR. They follow their own rules.

The EU responsible economic operator

Under Article 16, a product covered by GPSR cannot be placed on the EU market unless an economic operator established in the EU is responsible for it. That operator can be:

• the manufacturer, if it is established in the EU;
• the importer;
• an authorized representative with a written mandate from the manufacturer;
• a fulfilment service provider, where none of the above exists.

For a US brand selling from the US or through an EU 3PL, it is usually an authorized representative. Their tasks include checking that your technical documentation exists and is in order, cooperating with market surveillance authorities, and making sure corrective action is taken if a product turns out to be unsafe. That is why a serious representative reviews your documents before signing a mandate.

What has to be on the product

• The manufacturer's name, registered trade name or trademark, and postal and electronic address.
• If the manufacturer is outside the EU, the name and contact details of the EU responsible operator.
• A type, batch or serial number that identifies the product.
• Warnings and safety information in a language consumers in that country can easily understand.

Where the product is too small, this information goes on the packaging or an accompanying document.

What has to be in your online listing

Article 19 brings the label online. Every offer to EU consumers, in your own store and on marketplaces, must show:

• the manufacturer's name, trade name or trademark, and postal and electronic address;
• if the manufacturer is outside the EU, the name, postal and electronic address of the EU responsible person;
• a picture of the product, its type and any other identifier;
• warnings and safety information, in the local language.

Marketplaces now have their own obligations under GPSR. They must give sellers a way to display this information and act on unsafe products, which is why incomplete listings get blocked.

What sits behind the scenes

• Risk analysis and technical documentation for each product, kept for ten years.
• Accident reporting. Accidents caused by a product that lead to death or serious harm to health must be reported to the authorities through the EU's Safety Business Gateway.
• Complaints and recalls. Consumers need an accessible way to complain, and in a recall you must contact affected customers directly. Multilingual customer support that knows your products makes this manageable.
• Product liability insurance. GPSR itself does not require it, but most representatives, including us, ask for it before accepting a mandate.

How the UK differs

• Great Britain is not covered by the EU GPSR. General consumer products there fall under the General Product Safety Regulations 2005, and there is no direct equivalent of the EU rule that every product needs a locally established responsible operator. Sector rules still apply: cosmetics need a UK Responsible Person and must be notified before they go on sale, and many regulated products must show the UK importer's details.
• Northern Ireland applies the EU GPSR, so products sold there need an operator established in the EU or Northern Ireland.
• The Product Regulation and Metrology Act 2025 gives the UK government powers to update product rules, and it has said online marketplaces come first.

In practice: plan the EU GPSR for the EU and Northern Ireland, and check your sector rules for Great Britain, especially for cosmetics.

A checklist for US brands selling into the EU

• Confirm which of your products are in scope
• Appoint an EU responsible operator with a written mandate
• Update labels or packaging with manufacturer and operator details
• Update every listing: your store, Amazon and any other marketplace
• Prepare risk analysis and technical documentation for each product
• Set up complaint handling and accident reporting
• Translate warnings for each country you sell in
• For cosmetics: a Responsible Person and product notification in both the UK and the EU

Planning to hold stock in Europe as well? Read our guide to UK and EU VAT for US brands.

Questions

Is a GPSR representative the same as a cosmetics Responsible Person?
No. For cosmetics, the key role is the Responsible Person under the cosmetics rules, who notifies each product before sale, in the UK and in the EU separately. GPSR adds requirements around it, such as online listing information.

Can my 3PL be my responsible operator?
Only as a fulfilment service provider, and only where no manufacturer, importer or authorized representative is established in the EU. Many 3PLs don't take on the role.

Does GPSR apply if I only sell on Amazon?
Yes. Marketplaces must make sure listings show the required information, and they remove those that don't.

Does GPSR apply in the UK?
Only in Northern Ireland. Great Britain has its own product safety rules.

Sources

• EUR-Lex: Regulation (EU) 2023/988 on general product safety
• European Commission: GPSR overview for businesses
• GOV.UK: EU GPSR, detailed guidance for Northern Ireland
• Fieldfisher: new obligations under the GPSR
• legislation.gov.uk: General Product Safety Regulations 2005
• legislation.gov.uk: Product Regulation and Metrology Act 2025
• GOV.UK: submit a cosmetic product notification