GPSR requirements for online sellers

Who and what GPSR covers

GPSR applies to consumer products placed or made available on the EU market, including products sold online to EU consumers by businesses outside the EU. It acts as a safety net: where other EU legislation sets specific safety requirements for a product, those rules take precedence for the aspects they cover, and GPSR applies to the remaining aspects.

Obligations differ by role. Manufacturers, importers, distributors, and online marketplaces each have their own duties, and an online seller may hold one or more of those roles depending on how products are sourced and sold.

Information required in online listings

For distance sales, Article 19 of GPSR requires the offer to show certain information clearly and visibly. In summary, the listing should include:

• The manufacturer’s name, registered trade name or registered trade mark, and postal and electronic address.
• Where the manufacturer is not established in the EU: the name, postal and electronic address of the responsible person in the EU.
• Information identifying the product, including a picture, its type, and any other product identifier.
• Any warning or safety information that must be affixed to the product or accompany it, in a language easily understood by consumers in the Member State where it is sold.

The responsible person in the EU

A product covered by GPSR can only be placed on the EU market if there is an economic operator established in the EU responsible for certain safety tasks, as set out with reference to Article 4 of the Market Surveillance Regulation (EU) 2019/1020. This can be the manufacturer itself if it is established in the EU, an importer, an authorized representative, or a fulfilment service provider.

For sellers sourcing from non-EU manufacturers, identifying the responsible person and keeping their details current on every relevant listing is often the most work-intensive part of GPSR.

Product identification and traceability

GPSR expects products to carry identification such as a type, batch or serial number, together with manufacturer contact details on the product, its packaging, or an accompanying document, as applicable. These identifiers should match what the listing shows, so customers and authorities can link an online offer to the physical product.

A practical GPSR listing checklist

Before publishing a listing for the EU market, check that you have:

• Confirmed whether the product is a consumer product within GPSR’s scope, and which other EU product rules apply.
• Recorded the manufacturer’s name and postal and electronic address.
• Identified the EU responsible person when the manufacturer is not established in the EU, and recorded their details.
• Added a product picture, type, and identifiers (such as model, batch, or GTIN) consistent with the product and packaging.
• Included the warnings and safety information that apply to the product, translated as required for each target market.
• Kept supplier documents that support the information you publish, and a process to update listings when it changes.

Managing GPSR information across a catalog

Most of the information GPSR asks for already exists in supplier documents — data sheets, labels, manuals, and declarations. The challenge is collecting it consistently for hundreds of products and keeping it in sync across shops and marketplaces.

Doc2Shelf extracts manufacturer details, product identifiers, and warning text from supplier PDFs and drafts a GPSR information block for each listing, including responsible-person details when the manufacturer is not established in the EU. A person reviews the applicable fields before anything is published; Doc2Shelf does not assess whether a product is safe or compliant.

Article 19 listing elements in detail

Article 19 GPSR lists the minimum an online or other distance-sales offer must “clearly and visibly” indicate. The same four items apply to offers on online marketplaces through Article 22(9). The table below breaks them into the individual data points a catalog team has to collect; the example values are placeholders.

Article 19 applies to consumer products covered by CE-marking legislation as well: for those products the GPSR’s general safety requirements step back for the risks the sector law covers, but the distance-sales information, accident reporting and recall rules still apply.

GPSR obligations by seller role

An online seller can be a manufacturer, an importer, a distributor, or several of these at once. Article 13 GPSR also turns anyone who places a product under their own name or trade mark, or substantially modifies it, into a manufacturer with the full Article 9 duties — which matters for private-label sellers.

Technical documentation and the internal risk analysis

Before placing a product on the market, the manufacturer must carry out an internal risk analysis and draw up technical documentation (Article 9(2) GPSR). For general consumer products not covered by CE-marking legislation, the GPSR does not require an EU declaration of conformity or a CE mark; the technical documentation is the core record instead.

At minimum the documentation contains a general description of the product and its essential safety-relevant characteristics. Where appropriate it also contains an analysis of possible risks and the solutions adopted, including test reports, and the list of European standards or other elements applied, identifying any standards applied only in part.

• Technical documentation: kept up to date and available to market surveillance authorities for 10 years after the product is placed on the market (Art 9(3)); importers keep a copy for the same period (Art 11(6)).
• Information on risks, complaints and corrective measures: presentable for 10 years (Art 15(4)).
• Supply-chain traceability — who supplied you and whom you supplied: presentable for 6 years (Art 15(5)).
• Internal register of complaints, recalls and corrective measures: personal data in it kept only as long as needed and at most 5 years after entry (Art 9(12)–(13)).

Accidents, dangerous products, and recalls

When a product causes an accident — an occurrence resulting in death or serious adverse effects on health and safety — the manufacturer must ensure it is notified without undue delay through the Safety Business Gateway to the authorities of the Member State where it happened (Article 20). Importers and distributors inform the manufacturer, and when the manufacturer is not established in the EU, the responsible person ensures the notification is made. If a product is dangerous, the manufacturer must also take corrective measures, inform consumers and notify the authorities through the Safety Business Gateway (Article 9(8)).

In a recall, affected consumers who can be identified must be notified directly, using customer data already held; otherwise the recall must be disseminated widely (Article 35). The remedy must be effective, free of charge and timely, and in general the consumer chooses from at least two of repair, replacement or a refund of at least the price paid (Article 37).

A written recall notice must contain the elements in Article 36(2), in the language of each Member State concerned. The Commission has also adopted a recall-notice template in Implementing Regulation (EU) 2024/1435; check the current text and guidance on whether you must use its exact form — the Article 36(2) elements are required either way.

• The headline “Product safety recall”.
• A clear product description: picture, name and brand; batch or serial numbers and where to find them; and, if available, when, where and by whom it was sold.
• A clear description of the hazard, avoiding wording that lowers the perceived risk, such as “voluntary” or “precautionary”.
• What consumers should do, including an instruction to stop using the product immediately.
• The available remedies.
• A free phone number or an interactive online service.
• Where appropriate, encouragement to share the information.

The May 2026 amendment: emergency procedures

Regulation (EU) 2024/2748 amended the GPSR with effect from 29 May 2026 by inserting a new Chapter IIa, Articles 8a to 8c, on emergency procedures for “crisis-relevant goods”. These provisions only bite if an internal-market emergency is activated under Regulation (EU) 2024/2747.

For day-to-day online selling, the amendment does not change the Article 19 listing information. It matters if you sell goods that could be designated as crisis-relevant during a declared emergency, in which case you should watch for Commission measures under that framework.

Marketplace notes in general terms

Because Article 22(9) requires online marketplaces to let traders provide the Article 19 information, expect to be asked for manufacturer, responsible-person and safety data when you create or edit a listing. How that data is collected — for example as reusable contact records or as listing attributes — and which values are mandatory differs between marketplaces and can change over time.

Rather than relying on any one marketplace’s field labels, keep a single verified record per product — manufacturer, responsible person where it applies, identifiers, warnings in each language — and map it into each channel. Check each marketplace’s current seller documentation, and do not read a marketplace’s acceptance of a listing as confirmation that the product or listing complies.

Printable GPSR checklist by stage

Use this alongside the listing checklist above when onboarding a new supplier or product line.