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# EU GPSR Importer and Distributor Obligations: What Changed in 2024

The EU's General Product Safety Regulation replaced the old GPSD on 13 December 2024 — and it raised the bar significantly for importers and distributors. The 3-day notification rule, new traceability requirements, explicit online marketplace obligations, and a mandatory EU Responsible Person mean your compliance setup needs a hard look. This guide breaks down exactly what changed and what you need to do.

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At a glance

Replaces

GPSD (from 13 December 2024)

3-day notification

Serious risks to market surveillance

Importer on product

Name + email + address required

Online marketplaces

Explicitly regulated for first time

## Key concepts: GPSR obligations for importers and distributors

### GPSR replaces GPSD — key transition date and scope

Regulation (EU) 2023/988 (General Product Safety Regulation, GPSR) replaced Directive 2001/95/EC (General Product Safety Directive, GPSD) from 13 December 2024. Unlike its predecessor, GPSR is a Regulation — it applies directly in all EU member states without national transposition, creating a fully harmonised product safety framework across the bloc. GPSR applies to all consumer products placed on the EU market that are not exclusively covered by sector-specific Union legislation with equivalent safety requirements, making it the safety net for products only partially or not at all addressed by specific directives. GPSR explicitly extends obligations to online marketplaces and digital products for the first time, closing a major enforcement gap left by the GPSD. Products bearing CE marking (under LVD, RED, Machinery Regulation, and equivalent) are not directly subject to GPSR's conformity assessment requirements for aspects covered by those directives, but GPSR's economic operator obligations — traceability, notification, corrective action — still apply on top.

### Importer obligations under GPSR Article 10

GPSR Article 10 sets out specific obligations for importers, defined as natural or legal persons established in the Union who place a product from a third country on the EU market for the first time. Key obligations include: verifying that the manufacturer has carried out the applicable conformity assessment and drawn up required documentation; ensuring the product ships with instructions and safety information in a language easily understood by consumers in the member state of intended sale; affixing the importer's name, registered trade name or trademark, and contact address (both email and postal) to the product, packaging, or an accompanying document so the importer is traceable from the product; confirming the manufacturer's name, address, product type, and batch or serial number appear on the product; investigating complaints and taking corrective action — including notification to authorities — if there is reason to believe the product presents a risk; and retaining technical documentation and cooperating with market surveillance authorities on request.

### Distributor obligations under GPSR Article 11

Distributors are defined under GPSR as any person in the supply chain — other than the manufacturer or importer — who makes a product available on the EU market. Distributor obligations are lighter than importer obligations but have been meaningfully strengthened compared to the GPSD. Under Article 11, distributors must: act with due care to verify the manufacturer's name and address appear on the product, that a model identifier is present, and that instructions and safety information are included before placing the product on the market; store and transport products in conditions that preserve their safety; immediately inform the manufacturer or importer if they believe a product poses a safety risk — and suspend distribution of that product until the issue is resolved; cooperate with market surveillance authorities after a risk has been identified; and maintain supply chain records enabling traceability in both directions — who supplied the product and to whom it was supplied.

### The 3-day safety notification requirement — Article 35

GPSR Article 35 introduces one of the most operationally significant new obligations in the regulation: economic operators who know or have reason to believe that a product they have placed on the EU market presents a serious risk to consumer health or safety must notify the relevant national market surveillance authority within three working days of becoming aware of the risk. This obligation applies equally to manufacturers, importers, and distributors. The notification must be submitted through the Safety Business Gateway — the EU's mandated online notification platform — and must include product identification, the nature of the risk, corrective measures already taken or planned, and whether other member states have been notified. Critically, the 3-day clock starts when the operator has reason to believe a serious risk exists, not when they have definitive proof — a credible customer complaint describing injury, a pattern of field failures, or a test result indicating a hazard may trigger the obligation before any formal investigation is complete.

### Online marketplace obligations — GPSR Chapter VI

GPSR for the first time directly regulates online marketplaces in EU product safety law — a significant departure from the GPSD, which did not address platforms at all. Under GPSR Articles 22–30, online marketplaces must: register on the Safety Business Gateway and serve as active contact points for market surveillance authorities; process notices from authorities to remove or restrict unsafe products within the required timeframes; implement and maintain internal procedures to address product safety compliance; display product safety information provided by sellers — including traceability data and safety warnings — on product listings; and implement measures to identify and suspend sellers who repeatedly list unsafe products. Platforms such as Amazon Marketplace, eBay, and AliExpress are now directly regulated under EU product safety law when they facilitate sales to EU consumers, regardless of where the platform itself is established.

### Responsible Person under GPSR — the EU-based contact point

GPSR Article 16 requires that every product placed on the EU market has an economic operator established in the EU who is accountable for product safety — the Responsible Person. For products manufactured outside the EU, the Responsible Person is: the importer, a distributor or another EU-established person explicitly designated as Responsible Person by the manufacturer in a written mandate, or the EU Authorised Representative appointed under a specific product regulation where one applies. The Responsible Person's name and contact details must appear on the product or packaging, making them identifiable by both consumers and market surveillance authorities. Crucially, GPSR Responsible Person obligations apply even to CE-marked products — CE marking does not exempt a product from needing an identifiable EU Responsible Person who verifies manufacturer compliance, holds technical documentation, and cooperates with market surveillance on request.

## GPSR compliance process for importers and distributors

01

Determine your role in the GPSR supply chain — manufacturer, importer, or distributor — as defined by GPSR Articles 3 and 4. This role determines which set of obligations applies to your business. If you are established in the EU and bring in products from outside the EU for the first time, you are the importer. If you distribute products already placed on the EU market by another economic operator, you are a distributor. The role can shift: a distributor who rebrands, relabels, or modifies a product becomes the manufacturer for regulatory purposes under GPSR.

02

As an importer, verify manufacturer documentation before placing the product on the EU market. Request and review: safety test reports or a technical file demonstrating the product is safe; conformity assessment documentation if applicable under sector-specific legislation; and instructions and safety information in the official languages of every EU member state in which you intend to sell. Do not place the product on the market if the manufacturer cannot provide adequate documentation — proceeding without it creates direct importer liability under GPSR Article 10.

03

Ensure your importer details appear on the product or its packaging. GPSR Article 10 requires your name, registered trade name or trademark, postal address, and email address to be affixed to the product, packaging, or an accompanying document. If the product is too small to carry this information directly, the details go on the packaging or a document inside the packaging. GPSR permits digital labelling (e.g., a QR code linking to an online page containing the required information) for certain information categories — check the current Commission guidance on which fields may be provided digitally.

04

As a distributor, conduct documented due diligence checks on every product received from your supplier before making it available downstream. Confirm the manufacturer's name and address are present on the product or packaging, that a model identifier exists, and that safety information is included in the required language(s). Do not distribute products where these basics are missing — contact the supplier and request compliance before proceeding. Keep written records of these checks; they demonstrate due diligence to market surveillance authorities if a product is later found unsafe.

05

Register on the Safety Business Gateway (safety-business-gateway.ec.europa.eu). This is the EU platform for economic operators to submit product safety notifications and communicate directly with market surveillance authorities across member states. Registration is the gateway to fulfilling the GPSR Article 35 notification obligation — an operator who lacks an account cannot submit a notification within the 3-day window. Establish your account and verify access before you have an urgent notification to file.

06

Establish a written internal product safety incident response procedure that explicitly addresses the GPSR 3-working-day notification timeline. The procedure must enable rapid risk assessment (is this a serious risk or a minor issue?), a documented decision to notify or not with rationale, submission through the Safety Business Gateway, and initiation of corrective measures — voluntary recall, stop-supply instruction to distributors, consumer communication — all within the 3 working days from the moment the operator has reason to believe a serious risk exists. Test this procedure with a tabletop exercise before a real incident occurs.

07

Audit your supply chain records to confirm backward and forward traceability. GPSR requires economic operators to identify the economic operator from whom they received each product and — for manufacturers and importers — the economic operators to whom they supplied it. Retain traceability records for 10 years from the date of placing the product on the market or making it available. E-commerce sellers on online marketplaces must ensure their marketplace listings carry all GPSR-required traceability information in the product listing itself.

08

If you operate an online marketplace or sell through one, review the specific GPSR Chapter VI obligations that now apply. As a marketplace operator, register on the Safety Business Gateway, implement product safety information display requirements on listings, and establish procedures to respond to authority notices within GPSR's required timeframes. As a seller on a marketplace, ensure every listing includes GPSR-required product information: manufacturer's name and address, model identifier, and safety information. Non-compliant listings risk removal by the marketplace under its own GPSR compliance obligations.

## Frequently asked questions

### What is the GPSR 3-day notification rule?

Under GPSR Article 35, economic operators — manufacturers, importers, and distributors alike — must notify the relevant national market surveillance authority within three working days of becoming aware that a product they have placed on the EU market presents a serious risk to consumer health or safety. The notification is submitted through the EU's Safety Business Gateway platform and must describe the product, the nature of the risk, measures already taken or planned, and whether other member states have been informed. The 3-day window is particularly demanding because it starts when the operator has reason to believe a serious risk exists — not when a formal investigation confirms it. A credible consumer complaint describing an injury, a pattern of field failures pointing to a hazard, or a test result revealing a dangerous defect may each independently trigger the notification obligation before any investigation is complete. Operators should treat early warning signs seriously and act promptly rather than waiting for certainty.

### As an EU importer, must my name appear on the product under GPSR?

Yes. GPSR Article 10 requires EU importers to affix their name, registered trade name or trademark, and contact address — both postal and email — to the product, its packaging, or a document accompanying the product. This requirement makes the importer traceable directly from the physical product, enabling market surveillance authorities and consumers to identify who is legally responsible for the product in the EU. Where product size or nature makes it impossible to affix importer details directly — for example, on small electronic components — the information may appear on the packaging or in an accompanying document. Importer details supplement but do not replace the manufacturer's name and address; both must be present. Non-EU manufacturers should note that GPSR requires an EU-based Responsible Person who is identifiable on the product — structuring the import arrangement so the importer serves as the visible Responsible Person on the product is the standard approach for non-EU manufacturers selling into the EU.

### Does GPSR apply if a product already has CE marking?

Partially yes. GPSR applies to all consumer products placed on the EU market, but for products covered by EU harmonisation legislation — such as the Low Voltage Directive, Radio Equipment Directive, or Machinery Regulation — the conformity assessment obligations of those sector-specific instruments take precedence over GPSR's conformity assessment requirements for the aspects they cover. However, GPSR's economic operator obligations apply on top of CE marking requirements and are not displaced by it: the Responsible Person obligation under Article 16, the 3-day serious risk notification under Article 35, traceability record-keeping, corrective action duties, and cooperation with market surveillance all apply to CE-marked products. In practice, CE marking addresses technical conformity for defined hazard categories, while GPSR provides the overarching economic operator responsibility and market surveillance framework — the two regimes are complementary, not alternatives.

### Who is the GPSR Responsible Person and how do you appoint one?

The GPSR Responsible Person is the EU-established entity accountable for a product's safety on the EU market under Article 16. For EU manufacturers, the manufacturer itself is the Responsible Person. For products imported from outside the EU, the Responsible Person is: (1) the EU importer, (2) a person established in the EU explicitly mandated in writing by the non-EU manufacturer, or (3) the EU Authorised Representative where one is appointed under a specific product regulation. The written mandate must clearly specify the scope of the Responsible Person's authority and include their name and EU contact details. Third-party Responsible Person services are commercially available — firms established in the EU accept the RP role for non-EU manufacturers, typically for an annual fee, in exchange for holding technical documentation and acting as the regulatory contact. The Responsible Person's name and contact details must appear on the product or packaging so they are identifiable by consumers and market surveillance authorities without any further investigation.

**Disclaimer:** Educational resource only. Regulatory requirements change. Consult a qualified compliance specialist before making decisions.

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