GPSR Importer Checklist: Five Evidence Gaps to Close

Regulation (EU) 2023/988, the General Product Safety Regulation (GPSR), applies from 13 December 2024. The checklist below is for consumer products within its scope. Product-specific Union harmonisation legislation may add or replace requirements, so start from the exact product rather than a generic “GPSR certificate”.

1. Identify the responsible economic operator established in the EU

Article 16 says a covered product cannot be placed on the Union market unless an economic operator established in the Union is responsible for the specified tasks. Which operator fills that role depends on the supply chain and Regulation (EU) 2019/1020; it is not always an authorised representative. Article 16(3) allows the responsible operator’s name and postal and electronic address on the product, packaging, parcel or an accompanying document.

2. Obtain the risk analysis and technical documentation

Article 9(2) requires the manufacturer to carry out an internal risk analysis and draw up technical documentation with at least a general product description and safety-relevant characteristics. The depth should reflect the risks and may include test reports and standards applied. Importers must check the manufacturer has complied and keep the documentation available for authorities as Article 11 requires.

GPSR does not create a generic EU declaration of conformity for every consumer product. A declaration and CE marking may be required under applicable sector legislation; verify that separately.

3. Reconcile identifiers, contacts and safety information

Check that product type, batch or serial identifiers, manufacturer details, importer details and required instructions or warnings match the product and packaging. The regulation allows some information in packaging or an accompanying document where placement on the product is not possible. Record the product-specific reason and applicable language requirement.

4. Check online offers before publication

Article 19 requires distance-sale offers to display specified manufacturer information, the EU responsible person where the manufacturer is outside the Union, product identification and applicable warning or safety information. Audit the live product page rather than assuming the physical label covers the online listing.

5. Build a post-market and accident workflow

Economic operators need internal product-safety processes. Manufacturers and importers have complaint, dangerous-product, corrective-action and authority-notification duties. Article 20 covers accidents that resulted in death or serious adverse health and safety effects and requires notification without undue delay—not a universal two-working-day deadline. The Commission’s Safety Business Gateway guidance explains the roles of manufacturers, importers, distributors and the responsible person.

What to retain

Keep the dated product scope, operator roles, risk analysis, technical documentation, test evidence, label and online-listing screenshots, complaints and corrective actions, Safety Gate searches and review dates. A supplier statement is an input; the importer still needs to verify the obligations that apply to its own role and product.

Sources and scope

• Regulation (EU) 2023/988 (GPSR) on EUR-Lex
• Commission guidelines for the Safety Business Gateway
• European Commission Safety Gate alert search

Last reviewed 13 August 2026. Operational guidance, not legal advice. Recommendations labelled as judgement should be tested against the product, supplier, contract and market involved.