GPSR After 18 Months: The 5 Gaps Still Catching Importers Off Guard

The General Product Safety Regulation (GPSR, EU 2023/988) has been fully applicable since 13 December 2024. Seventeen months in, market surveillance authorities across Italy, Germany, and Spain have shifted from awareness-raising to active enforcement - and the patterns emerging from formal notices reveal the same five gaps, repeatedly.

1. No EU-based Responsible Person named on the product

This is the most common gap by far. Article 16 of GPSR requires every product placed on the EU market to have a named EU Responsible Person (RP) - either the EU-based importer themselves, or an authorised representative. The name, address, and contact details must appear on the product or its packaging, not only in a PDF filed away in a folder.

If you import and sell under your own brand, you are automatically the Responsible Person. If you source from a Chinese supplier and sell under their brand, you still need to nominate an EU RP. Many small importers have not done this yet.

2. Declaration of Conformity is generic, not product-specific

A DoC that states ‘compliant with GPSR’ with no reference to specific standards tested is not a valid declaration. It must reference the actual harmonised standards (e.g. EN 71 for toys, EN 62115 for battery-operated products), the notified body where applicable, and the specific model it covers. Chinese suppliers often use template documents that look compliant without being so. Cross-check that the standards cited actually apply to your product category and that the test date is recent (within 3 years for most categories).

3. No documented risk assessment

GPSR requires that the economic operator placing a product on the market has conducted a risk assessment appropriate to the product. For most consumer goods, this does not require an external laboratory - it means a documented process showing you checked the product against applicable safety standards and considered foreseeable misuse. A two-page internal document is sufficient for most SME importers. The absence of any documentation is not.

4. GPSR obligations not included in supplier contracts

Article 9 of GPSR places specific obligations on manufacturers. Your purchase contract should require Chinese suppliers to provide compliant documentation, notify you of safety issues discovered post-shipment, and maintain their own technical file. Very few importer-supplier contracts currently include this language.

5. No incident reporting process in place

Article 20 requires economic operators to report serious risks and accidents to national authorities within two working days of becoming aware. Most Italian SME importers have no process for this. A complaint on Amazon.it or an issue flagged in a product review counts as ‘becoming aware.’

What to action first

Three highest-priority steps: (1) confirm your EU Responsible Person is named correctly on every product you currently sell; (2) request updated, product-specific DoCs from all active Chinese suppliers; (3) create a simple incident log - a spreadsheet is enough - so you can demonstrate a reporting process if a surveillance authority requests it.

Every SinoSource report includes a GPSR compliance check for shortlisted suppliers, covering EU RP availability, DoC status, and Safety Gate history. See our subscription plans.