The EU General Product Safety Regulation, Regulation (EU) 2023/988 (GPSR), has applied to relevant non-food consumer products since 13 December 2024. It requires economic operators to place or make available only safe products and to connect product identification, risk analysis, technical documentation, warnings and corrective-action records. This page is a record-preparation reference. It does not replace product-specific Union harmonisation legislation, national rules, market-surveillance decisions or customer requirements, and it does not promise a platform, customs or market outcome.
1. Confirm where GPSR fits
GPSR provides a general product-safety framework. Toys, batteries, radio equipment, machinery, electrical equipment, cosmetics and other categories may also be governed by specific Union rules. A GPSR file should not be presented as a substitute for requirements that apply to the same product under specialised legislation. For each SKU, record the product, model or batch, intended Member States, manufacturer and importer, applicable specific legislation, relevant standards or other safety basis, and open risk questions.
Online offers can count as making a product available on the Union market when they target consumers in the Union. Separate the legal GPSR record from voluntary certifications, retailer specifications and a platform's own document request; these may overlap but are not the same source of obligation.
2. The manufacturer's technical file
Article 9 requires the manufacturer to perform an internal risk analysis before placing the product on the market and to draw up technical documentation. The file must at least describe the product and the essential characteristics relevant to assessing its safety. Where appropriate to the risks, it should also document the risk analysis, measures adopted to eliminate or reduce risks, test reports, and relevant European standards or other elements used to meet the general safety requirement. The record should map to the actual model, configuration, materials, software version and production changes.
- Identification: model, batch or serial number linked to packaging, instructions, orders and samples.
- Product information: specifications, construction or formulation, key materials and reasonably foreseeable use, including interaction with other products where relevant.
- Risk record: hazards, exposure scenarios, user groups, design controls and warnings, with the supporting assessment or test basis.
- Instructions: assembly, use, maintenance and safety information in a language easily understood by consumers in the relevant Member State.
- Change and production controls: impact reviews for model, material, supplier, software or packaging changes, and procedures for series production.
Manufacturers must keep the technical documentation for ten years after the product is placed on the market and make it available to market-surveillance authorities on request. Ten years is a document-retention rule, not a universal validity period for every test report. Whether a report still supports the current SKU depends on the sample, method, applicable rule and product changes.
3. Responsible person, importer and distributor records
A product covered by GPSR must have an economic operator established in the Union responsible for the tasks referenced in Article 16 before it is placed on the Union market. The responsible person's name, registered trade name or trademark, postal address and electronic address must appear on the product, packaging, parcel or an accompanying document. For a manufacturer outside the Union, a generic supplier certificate does not replace responsible-person information or product-specific records.
Importers and distributors should check that product identification, manufacturer and responsible-person details, warnings and accompanying documents match the goods received. Keep records of the direct upstream and downstream economic operators. A SKU index linking legal entity, product, file and batch is more useful than a folder of unrelated certificates; reassess it when the entity, address or configuration changes.
4. Four information groups for an online offer
Under Article 19, an online or other distance-sale offer must clearly and visibly show at least:
- The manufacturer's name, registered trade name or trademark, postal address and electronic address.
- When the manufacturer is not established in the Union, the responsible person's name, postal address and electronic address.
- Information identifying the product, including its picture, type and other product identifier.
- Warnings and safety information required on the product, packaging or accompanying document under GPSR or applicable Union harmonisation legislation, in a language easily understood by consumers in the relevant Member State.
Review the same model and version across the title, picture, variants, warnings, packaging label and instructions. If they conflict, pause the uncertain claim and reconcile it against the technical file, risk record and physical sample. Adding “certified” or “globally compliant” to a page does not establish a GPSR conclusion.
5. Accidents, complaints and corrective actions
Keep traceable records of product-safety issues, consumer complaints, accidents, supply-chain notifications and investigation outcomes. When a manufacturer becomes aware of an accident caused by its product, the accident is to be reported through the Safety Business Gateway to the competent authority of the Member State where it occurred, without undue delay. If a product may be unsafe, determine and document appropriate corrective action, the affected model or batch, notified parties and completion status; do not substitute a future test cycle for that assessment.
6. Suggested fields for one SKU record
- Identity: brand, manufacturer, Union responsible person, model/batch/serial number and product or variant images.
- Scope: target Member States, sales channel, specific legislation, standards or other safety basis.
- Technical file: specifications, materials or formulation, construction, software version, risk analysis, tests and warning design.
- Page and label: manufacturer/responsible-person details, product identifier, warning language, packaging and accompanying-document version.
- Maintenance: supplier and entity changes, complaints or accidents, corrective actions, notifications, document versions and retention location.
Source basis: EUR-Lex, Regulation (EU) 2023/988, Articles 4, 5, 9, 16, 19 and 20, and the European Commission product-safety information. Regulations, product-specific requirements and Member State implementation information may change; verify the current official text, product scope and language requirements before use. 绿色方舟（深圳）认证有限公司 can help organise a product-to-evidence index, while the applicable economic operator and authority determine the position for the actual product.
