The EU General Product Safety Regulation (GPSR), Regulation (EU) 2023/988, has applied to relevant non-food products since 13 December 2024. For an EU-bound listing, start by matching the product, manufacturer, EU responsible person, warnings and evidence files, then check Amazon’s current account workflow and display fields. This article is a records-review framework, not product-specific legal advice.
1. Separate GPSR from product-specific legislation
GPSR provides a horizontal product-safety framework for relevant non-food products made available online or offline. A product may also fall under sector legislation for toys, radio equipment, machinery, low-voltage equipment, batteries, cosmetics or another product category. Scope, conformity assessment, marking and technical-file requirements must be checked under the applicable sector rules; they should not be inferred from a GPSR summary. Build the register from the product’s function, materials, intended use, destination market and actual version.
2. Match the product to the manufacturer and EU responsible person
For products covered by GPSR, an economic operator established in the EU must generally be available to perform the responsible-person tasks described in Article 16. Record the manufacturer’s legal name, postal address and electronic address. If the manufacturer is outside the EU, also record the EU responsible person’s name and contact details, and confirm that the appointment covers the current product and model. A brand owner, factory, importer, authorised representative and responsible person are not automatically the same entity; a generic supplier document is not a substitute for entity and product matching.
3. Check the information visible in an online offer
Article 19 requires an online or distance-sale offer to show, clearly and visibly, at least the manufacturer’s name and contact details; the EU responsible person’s name and contact details when the manufacturer is not established in the EU; information that identifies the product, including its picture, type and other identifiers; and the warnings and safety information required by GPSR or applicable sector legislation, in a language consumers in the destination Member State can readily understand. Check each SKU’s image, model, label, manual and listing attributes as one version-controlled set.
Amazon’s field names, account entry points and validation workflow may change. Use the GPSR or Regulatory Compliance area in the current seller account as the operational reference, and retain the submitted values and supporting record. A platform status is not a certification of the product’s safety facts.
4. Build a product-linked technical evidence file
For each product version, keep the specifications, model and batch identifiers, design or construction information, applicable-law assessment, risk identification and controls, test or assessment records, labels, packaging and instructions, warning-language versions, and manufacturer/responsible-person records. Each document should answer which product it covers, who issued it, which risk or requirement it addresses, and whether it matches the current version. A test report, certificate or supplier declaration cannot be detached from its scope, entity and version. GPSR does not create one universal “24-month validity” rule for every report.
5. Keep Amazon workflow separate from market surveillance
An Amazon upload, listing display or account notice is a platform process. An investigation, corrective measure or recall by a Member State market-surveillance authority is a public-regulatory process. They may concern the same product information, but the records should not promise approval, guaranteed listing availability, automatic customs detention or a fixed enforcement outcome. Where a product may present a safety risk, follow the applicable law, platform procedure and authority instruction; the measure and timing depend on the facts, risk and procedure.
6. Maintain a one-row-per-SKU evidence register
Keep one record per SKU for the product identifier and version, manufacturer, EU responsible person, applicable product legislation, technical-file location, test or assessment records, label and warning languages, listing images and fields, Amazon submission record, change date and owner. Reassess the linked file after a change to the formulation, construction, key component, packaging, manufacturer or responsible person. Do not automatically treat PPWR, EUDR, CBAM, CPF or another programme’s documents as GPSR evidence. Consult the EUR-Lex regulation, the European Commission business Q&A and Amazon’s GPSR information, and recheck the current versions before submission.
