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Understanding the General Product Safety Regulation (GPSR)

The General Product Safety Regulation (GPSR) represents a fundamental shift in how the European Union approaches product safety in the age of digital commerce. Adopted in May 2023 and taking effect on December 13, 2024, GPSR isn't merely an update to existing rules—it's a comprehensive reconceptualization of product safety that reflects the realities of modern e-commerce, online marketplaces, connected devices, and AI-driven product design.

For e-commerce businesses, understanding GPSR means grasping why traditional product safety frameworks were insufficient for the digital age, what new obligations emerge from this regulatory evolution, and how the regulation fundamentally changes the accountability structure for online product sales.

The Context: Why GPSR Exists​

To understand GPSR's significance, it's essential to recognize the regulatory gap it addresses.

The Legacy Framework's Limitations​

The previous regulatory foundation—the General Product Safety Directive (GPSD) from 2001—was designed for a pre-digital economy. In 2001, e-commerce was nascent, online marketplaces didn't exist in their current form, and the concept of "selling into the EU from anywhere in the world" wasn't the operational reality it is today.

The GPSD made assumptions that no longer hold:

  • Physical retail dominance: The directive assumed most consumer transactions occurred in brick-and-mortar stores where products could be physically inspected and where sellers had established local presence
  • Clear jurisdictional boundaries: Product safety enforcement relied on identifying manufacturers and distributors within EU territory
  • Limited cross-border complexity: International commerce existed but wasn't the default mode for millions of daily consumer transactions
  • Traditional supply chains: Supply chains were more linear and transparent, with fewer intermediaries between manufacturer and consumer

The Digital Commerce Transformation​

Between 2001 and 2023, e-commerce fundamentally reshaped retail:

Global marketplace platforms emerged where sellers from any jurisdiction can reach EU consumers without physical presence in Europe. This created enforcement challenges—how do you hold a seller accountable when they have no EU establishment?

Direct-to-consumer models proliferated, eliminating traditional importers and distributors who previously served as checkpoints for product safety compliance.

Product complexity increased with connected devices, AI-enabled products, and sophisticated software-hardware integration. Safety concerns expanded beyond physical hazards to include cybersecurity, data privacy, and algorithmic decision-making.

Rapid product cycles meant products could be designed, manufactured, listed online, and sold to thousands of consumers within weeks—far faster than traditional regulatory oversight could respond.

Recall difficulties became apparent when dangerous products were discovered. Identifying affected consumers and removing products from circulation proved nearly impossible when sellers operated from outside EU jurisdiction and transactions occurred on opaque marketplace platforms.

What GPSR Represents: A Regulatory Philosophy Shift​

GPSR isn't simply "stricter rules"—it represents a philosophical shift in how the EU thinks about product safety responsibility in digital commerce.

From Reactive to Preventive​

Traditional product safety regulation was largely reactive: enforce standards when problems arise, issue recalls when dangers are discovered, penalize manufacturers after harm occurs.

GPSR embraces a preventive philosophy:

  • Pre-market risk assessment is now mandatory, requiring manufacturers to identify potential hazards before products enter the market
  • Traceability from the start ensures that every product can be tracked through its lifecycle, enabling rapid response if issues emerge
  • Continuous monitoring obligations require economic operators to actively watch for safety issues, not just respond when authorities notify them

This shift reflects an understanding that in digital commerce, reactive approaches are insufficient. A dangerous product listed on a marketplace can reach thousands of consumers within days—waiting until harm occurs to intervene is unacceptable from a consumer protection standpoint.

From Location-Based to Responsibility-Based​

The GPSD's location-based approach (regulate entities within EU borders) broke down when sellers could operate entirely outside Europe while selling to European consumers.

GPSR introduces responsibility-based accountability:

  • EU Responsible Person requirement ensures every product has a designated entity within EU jurisdiction accountable for safety, regardless of where the manufacturer operates
  • Marketplace accountability makes platforms responsible for safety oversight, recognizing their role as gatekeepers controlling product access to consumers
  • Traceability obligations create a paper trail connecting products to responsible parties, regardless of geographic complexity

This approach acknowledges that in global digital commerce, regulatory effectiveness requires identifying responsibility rather than merely enforcing geographic presence.

From Limited Transparency to Comprehensive Information​

Traditional retail allowed consumers to inspect products, read packaging, and speak with informed salespeople. Digital commerce removes these touchpoints—you purchase based on product listings, images, and descriptions.

GPSR mandates comprehensive information availability:

  • Digital labeling requirements ensure online product listings contain the same safety information that would appear on physical packaging
  • Accessible contact information guarantees consumers can reach responsible parties with safety concerns
  • Clear manufacturer identification prevents anonymity that previously enabled fly-by-night operations to sell potentially dangerous products

This transparency serves dual purposes: empowering informed consumer decision-making and enabling regulatory enforcement by making responsible parties identifiable.

Core Concepts: Understanding GPSR's Key Requirements​

GPSR introduces several foundational concepts that reshape product compliance obligations. Understanding these concepts reveals why GPSR demands changes to product information management systems.

The EU Responsible Person: Accountability Localization​

Perhaps GPSR's most significant innovation is the EU Responsible Person requirement.

What it means: Every product placed on the EU market must have a designated natural or legal person established within the European Union who accepts responsibility for product safety compliance.

Why this matters conceptually: This requirement solves the jurisdictional challenge of global e-commerce. When a manufacturer operates from outside the EU, traditional enforcement mechanisms (inspections, penalties, legal proceedings) become impractical. By requiring an EU-based responsible person, GPSR ensures there's always an entity within regulatory reach.

The accountability it creates: The responsible person isn't merely a forwarding address—they accept legal accountability for:

  • Ensuring the product complies with applicable safety requirements before it's placed on the market
  • Conducting or verifying that required risk assessments have been completed
  • Maintaining technical documentation demonstrating compliance
  • Cooperating with market surveillance authorities during inspections or investigations
  • Taking corrective action if safety issues emerge, including organizing recalls if necessary

This creates a concrete locus of responsibility. Regulators know exactly who to contact, consumers know who's accountable, and marketplaces can verify that someone with "skin in the game" stands behind each product.

Implications for product information: The responsible person's identity and contact details must be:

  • Included on the product itself (when feasible)
  • Clearly stated on product packaging
  • Present in online product listings
  • Available in documentation accompanying the product

This means e-commerce systems must manage and display this information systematically—it's not optional metadata but mandatory compliance information.

Product Traceability: Creating an Accountability Chain​

GPSR mandates enhanced traceability mechanisms that enable products to be tracked through the supply chain from manufacturing to consumer.

What traceability means: Products must carry identifying information allowing them to be traced back to their origin. This includes:

  • Manufacturer name, registered trade name or trademark, and contact address
  • Batch number, serial number, or other identifying element
  • Product type, batch, or serial identification enabling linking to supply chain documentation

The conceptual purpose: Traceability serves multiple functions:

Rapid risk mitigation: When a safety issue is discovered, traceability enables authorities and economic operators to quickly identify affected product batches and notify consumers who purchased them.

Accountability enforcement: Traceability creates an auditable chain connecting products to responsible economic operators, preventing anonymity that previously shielded bad actors from consequences.

Quality control: Manufacturers can correlate customer reports, defects, and incidents with specific production batches, enabling targeted quality improvements.

Market surveillance efficiency: Authorities can sample products from retail or online marketplaces, trace them to their source, and verify compliance documentation without extensive investigation.

Why this differs from traditional approaches: Previously, traceability was common for regulated products (pharmaceuticals, automotive parts) but not universally required for consumer goods. Many products lacked identifying information beyond brand names. If problems emerged, identifying which units were affected was guesswork.

GPSR makes systematic traceability universal for consumer products, reflecting an understanding that in modern supply chains with global sourcing and rapid distribution, traceability isn't a luxury—it's essential infrastructure for effective safety oversight.

Implementation implications: E-commerce businesses must systematically capture and display traceability information:

  • SKU management systems need fields for batch numbers, serial ranges, and manufacturer identifiers
  • Product listings must communicate relevant identifying information to consumers
  • Internal systems must link products to supplier documentation demonstrating traceability compliance

Information and Labeling: Bridging Physical and Digital​

GPSR establishes comprehensive information and labeling requirements specifically adapted for distance selling and online marketplaces.

The fundamental principle: Consumers purchasing online must receive the same safety information they would receive purchasing in a physical store. The medium of sale (digital vs. physical) shouldn't diminish access to safety-relevant product information.

What this encompasses: For distance sales, product offers must include:

  • Manufacturer and responsible person identification and contact details (including electronic addresses)
  • Product identification enabling traceability (model numbers, batch identifiers)
  • Safety warnings and precautions relevant to product use
  • Compliance documentation or references (declarations of conformity, safety certificates)
  • Instructions for safe use and disposal where applicable

The conceptual challenge: Physical retail provides ambient information through packaging, labels, and in-store context. Digital commerce strips this away—consumers see what sellers choose to display. GPSR mandates that this discretion be constrained by comprehensive disclosure obligations.

Why electronic addresses matter: GPSR specifically requires electronic contact addresses (email or web forms) in online product listings. This recognizes consumer behavior in digital commerce—physical mail is impractical for quick safety inquiries or incident reporting. Electronic communication is the native medium of digital commerce, and safety compliance must operate through channels consumers actually use.

Implications for product data management: E-commerce systems must systematically manage safety and compliance information:

  • Product databases need structured fields for manufacturer contacts, responsible person details, certifications, warnings, and documentation references
  • Templates and workflows must ensure required information is captured during product onboarding
  • Product listing generation must automatically include mandatory compliance information—it can't be treated as optional marketing content

cobby's role becomes relevant here: managing this compliance information systematically across potentially thousands of products demands structured data management that scales beyond manual processes.

Risk Assessment and Documentation: Formalizing Safety Analysis​

GPSR formalizes risk assessment obligations that were previously implicit or unsystematic.

The requirement: Before placing a product on the market, manufacturers must conduct an internal risk assessment identifying potential hazards from normal or reasonably foreseeable use.

What risk assessment entails:

  • Hazard identification: Systematically considering how the product might cause harm (physical injury, chemical exposure, electrical hazards, choking risks for children, etc.)
  • Exposure assessment: Evaluating how consumers will interact with the product and what populations might be exposed to identified hazards
  • Risk characterization: Determining the likelihood and severity of potential harm
  • Mitigation evaluation: Assessing whether design features, warnings, or usage instructions adequately reduce risks to acceptable levels

The documentation obligation: Risk assessments must be documented and retained, available for review by market surveillance authorities upon request.

Why this matters conceptually: Risk assessment formalizes safety as a design input, not an afterthought. Products aren't safe by default—safety results from deliberate analysis and mitigation during development. By requiring documented risk assessment, GPSR ensures manufacturers can demonstrate they've systematically considered safety rather than merely asserting products are "safe enough."

The accountability it creates: Documented risk assessments create evidentiary records:

  • If incidents occur, authorities can evaluate whether hazards were identified and adequately mitigated during design
  • Manufacturers must justify design decisions with safety implications
  • The documentation trail creates accountability—claiming ignorance of hazards becomes untenable when risk assessment was required pre-market

Implications for e-commerce operations: While risk assessment is primarily a manufacturer obligation, e-commerce businesses must verify that suppliers have completed required assessments:

  • Onboarding processes should request confirmation of risk assessment completion
  • Supplier management systems should track compliance documentation
  • Product data should include references to relevant safety analyses, particularly for products with notable hazards

Online Marketplace Obligations: Platform Accountability​

GPSR extends obligations directly to online marketplace operators, recognizing their structural role in connecting sellers with consumers.

Key marketplace obligations:

Single point of contact: Marketplaces must designate and publish a single point of contact for market surveillance authorities, enabling efficient regulatory communication.

Safety Gate Portal registration: Marketplaces must register with and actively engage with the EU Safety Gate Portal (formerly RAPEX), the rapid alert system for dangerous products.

Corrective action obligations: When notified by authorities that a listed product is dangerous or non-compliant, marketplaces must:

  • Remove or disable access to the product listing
  • Inform the seller of the reasons and regulatory basis for action
  • Notify consumers who purchased the product when contact information is available

Proactive monitoring (emerging): While current GPSR requirements focus on responsive action, the regulatory trajectory suggests marketplaces may face expectations to proactively monitor for non-compliant products using automated systems.

Why this represents a philosophical shift: Previously, marketplaces could characterize themselves as neutral platforms merely providing infrastructure for third-party transactions. GPSR rejects this characterization for product safety purposes—marketplaces control access to consumers and therefore bear responsibility for safety oversight within their ecosystems.

The practical implication: Marketplaces become partners in safety enforcement, not obstacles to it. Regulators gain leverage: rather than pursuing thousands of individual sellers, they can require marketplaces to systematically remove non-compliant products.

Relevance for sellers: Sellers operating on marketplaces must understand that compliance failures can result in:

  • Immediate delisting of non-compliant products
  • Account suspension or termination by the marketplace
  • Visibility to regulators through marketplace reporting obligations

This creates dual accountability: regulatory authorities and marketplaces both have mechanisms to enforce compliance.

The Implications: What GPSR Means for E-Commerce Businesses​

Understanding GPSR's conceptual framework illuminates its practical implications for e-commerce operations.

Compliance as Systematic Data Management​

GPSR compliance isn't achievable through ad-hoc processes—it requires systematic product data management.

Consider the information GPSR mandates:

  • EU Responsible Person details (name, address, contact information)
  • Manufacturer identification and contact information
  • Product traceability identifiers (batch numbers, serial numbers, model identifiers)
  • Risk assessment documentation references
  • Compliance declarations and certifications
  • Safety warnings and usage instructions
  • Electronic contact addresses for safety inquiries

For an e-commerce catalog with hundreds or thousands of products, managing this information manually is impractical. Spreadsheets become unmanageable, errors proliferate, and ensuring consistency across multiple sales channels becomes nearly impossible.

This is where cobby's architectural approach becomes relevant.

cobby positions itself as a structured data management layer between business workflows (Excel's familiarity and flexibility) and e-commerce platforms (Magento, Shopware). By centralizing product data management with systematic fields, validation, and synchronization, cobby enables businesses to:

  • Capture compliance information systematically during product onboarding using structured columns for required data elements
  • Validate completeness by filtering products missing required GPSR information before they go live
  • Maintain consistency across multiple storefronts or marketplaces by synchronizing from a single managed dataset
  • Update efficiently when supplier information changes or new certifications are obtained, applying updates across entire product families simultaneously
  • Audit compliance by generating reports showing which products have complete GPSR information and which require attention

GPSR transforms product information management from "nice to have structured data" to "regulatory necessity."

Supplier Relationship Management Becomes Critical​

GPSR's requirements cascade through supply chains, making supplier management and documentation operationally critical.

E-commerce businesses must now systematically collect from suppliers:

  • Confirmation of EU Responsible Person designation
  • Traceability documentation (batch number schemes, manufacturer identifiers)
  • Risk assessment confirmation or documentation
  • Compliance declarations demonstrating conformity with applicable safety standards
  • Technical documentation supporting safety claims

This isn't one-time information—it requires ongoing management:

  • Onboarding processes must capture required documentation before products are listed
  • Supplier databases must track compliance documentation status and expiration dates
  • Change management must update product information when suppliers change responsible persons, certifications expire, or new safety information emerges

For businesses sourcing from numerous suppliers (particularly common in dropshipping or marketplace models), this represents significant operational overhead. Systematic data management tools become essential infrastructure, not optional optimization.

The Cost of Non-Compliance Escalates​

GPSR substantially increases both regulatory risk and marketplace risk for non-compliant businesses.

Regulatory penalties: GPSR empowers member state authorities to impose significant penalties for non-compliance, potentially including:

  • Financial penalties scaled to the severity and extent of violations
  • Product recalls at the business's expense
  • Prohibition from placing products on the EU market
  • Public naming in safety alerts, damaging brand reputation

Marketplace enforcement: Beyond regulatory penalties, marketplace operators will enforce compliance to protect themselves from liability and regulatory scrutiny:

  • Products lacking required information may be delisted
  • Sellers with repeated compliance failures risk account suspension or termination
  • Marketplace algorithms may deprioritize sellers with incomplete compliance information

Consumer protection ramifications: Non-compliance creates direct consumer harm exposure:

  • If a safety incident occurs and the business cannot demonstrate compliance with GPSR risk assessment and documentation requirements, liability arguments become significantly more difficult
  • Lack of proper traceability hampers incident response, potentially expanding exposure by making recalls less effective

Competitive implications: As GPSR enforcement matures, compliant businesses gain competitive advantage:

  • Consumers may prefer sellers demonstrating clear compliance (particularly for products with safety implications)
  • Marketplace search algorithms may favor listings with complete compliance information
  • B2B buyers will increasingly require GPSR compliance documentation from suppliers

The Timeline: A Fundamental Shift, Not a Checkbox​

GPSR's December 13, 2024 applicability date is not a "one-time compliance project" deadline—it marks the beginning of a new regulatory paradigm.

Initial compliance (by December 13, 2024) requires:

  • Designating EU Responsible Persons for products lacking them
  • Ensuring product listings include required information
  • Establishing processes for capturing and managing compliance documentation
  • Updating existing product data to include GPSR-required information

Ongoing compliance (post-December 2024) demands:

  • Systematic onboarding processes ensuring new products include required information
  • Continuous monitoring for supplier changes affecting responsible person designations
  • Documentation management maintaining current risk assessments and certifications
  • Incident response capabilities enabling rapid action if safety issues emerge

Evolving interpretation will emerge as:

  • Market surveillance authorities issue guidance on specific product categories
  • Court cases clarify ambiguous requirements
  • Industry best practices develop for risk assessment documentation and traceability implementation

Businesses must adopt compliance as ongoing operational practice, not treat GPSR as a one-time project completed and forgotten.

The Broader Context: GPSR as Regulatory Philosophy​

GPSR exemplifies broader trends in how the EU approaches digital economy regulation.

Digital Accountability as Regulatory Priority​

GPSR parallels other EU digital regulations (GDPR for data protection, Digital Services Act for online platforms, AI Act for artificial intelligence) in establishing accountability frameworks for digital operations.

Common themes across these regulations:

  • Responsibility designation: Requiring identifiable entities accountable for compliance, regardless of operational complexity
  • Transparency obligations: Mandating information disclosure enabling informed decision-making and regulatory oversight
  • Proactive risk management: Requiring systematic assessment of potential harms before operations commence
  • Cross-border enforcement mechanisms: Creating legal hooks for regulating entities operating outside EU territory but serving EU consumers

GPSR applies these principles to product safety, recognizing that digital commerce enables global actors to reach EU consumers without the accountability traditional physical presence created.

Consumer Protection in Digital Commerce​

GPSR reflects the EU's commitment to equivalent consumer protection across physical and digital retail.

The underlying principle: consumers shouldn't sacrifice safety assurances or recourse mechanisms simply because they purchase online rather than in physical stores.

This principle challenges business models built on information opacity:

  • Dropshipping models where sellers have minimal product knowledge face pressure to establish supplier management systems ensuring compliance information availability
  • Marketplace models where platform operators claim neutrality face direct obligations to participate in safety enforcement
  • Cross-border models where businesses operate outside EU jurisdiction face responsible person requirements creating EU-based accountability

The regulatory message is clear: digital commerce flexibility doesn't exempt businesses from fundamental consumer protection obligations.

The Precautionary Approach to Emerging Risks​

GPSR's structure reveals the EU's precautionary approach to product safety in the age of connected devices, AI, and rapid innovation.

By mandating risk assessment, establishing traceability, and creating rapid response mechanisms, GPSR builds infrastructure for addressing:

  • Connected device vulnerabilities where security flaws can create safety hazards (IoT devices with inadequate cybersecurity enabling unauthorized access to homes, vehicles, or personal data)
  • AI-driven product behavior where algorithmic decision-making may produce unexpected safety consequences
  • Rapid product iteration where software updates can fundamentally change product characteristics and risk profiles after purchase

GPSR's framework is designed to be adaptable, enabling authorities to respond to novel risks as technology evolves rather than requiring new legislation for each emerging product category.

Looking Forward: GPSR as Business Context​

For e-commerce businesses, GPSR represents the new baseline for operating in the EU market. The regulation clarifies expectations, establishes accountability, and creates enforcement mechanisms that will shape the competitive landscape.

Strategic positioning requires:

Viewing compliance as operational capability: Businesses that build systematic compliance processes gain efficiency advantages over competitors treating GPSR as administrative burden. Structured data management, supplier relationship protocols, and documentation systems create operational leverage.

Leveraging compliance as differentiation: As GPSR awareness grows among consumers, demonstrated compliance becomes a trust signal. Clear responsible person information, transparent traceability, and accessible safety documentation can differentiate brands in crowded marketplaces.

Anticipating enforcement evolution: Initial GPSR enforcement will likely focus on obvious violations and high-risk products. Over time, enforcement will become more sophisticated and systematic. Early adoption positions businesses ahead of competitive pressure and regulatory scrutiny.

Integrating compliance into workflows: GPSR compliance is most efficient when integrated into existing workflows rather than treated as separate compliance work. Product onboarding, supplier management, and product information systems that incorporate GPSR requirements by default reduce compliance friction.

This is where cobby's value proposition intersects with GPSR compliance.

By providing structured, scalable product data management integrated with familiar Excel workflows, cobby enables businesses to systematically capture, validate, and maintain GPSR-required information without abandoning efficient working methods. Compliance becomes part of product management workflows rather than a separate administrative burden.

To deepen your understanding of regulatory compliance and product data management:

  • Implementing GPSR Requirements in cobby — Practical guide for capturing and managing GPSR compliance information in your product data (how-to guide)
  • Product Data Governance — Best practices for maintaining data quality, consistency, and completeness across large catalogs (coming soon)
  • Supplier Management Workflows — Strategies for collecting and managing compliance documentation from suppliers (coming soon)
  • Risk Management in E-Commerce Operations — Understanding operational risks beyond product safety, including data protection and platform compliance (coming soon)
Understanding Enables Action

Now that you understand why GPSR exists and what it means conceptually, you're equipped to implement systematic compliance processes. The GPSR Implementation Guide provides practical steps for capturing and managing required information in cobby.