GPSR Compliance: What Happens to Products Manufactured Before 13 December 2024?
GPSR
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Founder of Euverify | EU & UKCA Compliance Expert
Ajay is an eCommerce expert with 17+ years of experience as an Amazon, eBay, and Etsy seller and a Shopify specialist. He excels in EU and UK compliance, including GPSR and UKCA, helping businesses expand into European and UK markets. Ajay is the founder of Sweans, a London-based eCommerce agency, and Euverify.com, a SaaS platform streamlining compliance for non-EU sellers.
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- March 10, 2025Compliance News & UpdatesGPSR Compliance: What Happens to Products Manufactured Before 13 December 2024?
GPSR
With the General Product Safety Regulation (GPSR) (EU) 2023/988 now in effect as of December 13, 2024, businesses selling consumer products in the EU need to be clear on the new GPSR compliance requirements.
One of the most common questions we hear is:
What happens to products made before December 13, 2024? Are they exempt from GPSR?
In this guide, we’ll break down Article 51 of GPSR and explain what businesses need to do to stay compliant.
Understanding Article 51: The Transition Rule
What Does Article 51 Say?
GPSR Article 51 (Transitional Provision) of Regulation (EU) 2023/988 clearly states:
“Member States shall not impede the making available on the market of products covered by Directive 2001/95/EC which are in conformity with that Directive and which were placed on the market before 13 December 2024.”
This means that if a product was already placed on the EU market before December 13, 2024, it remains compliant under the previous General Product Safety Directive (GPSD) 2001/95/EC and is not subject to GPSR.
However, if a product was not yet placed on the EU market before this date, it must comply with GPSR compliance before importation.
What Does "Placing on the Market" Mean?
GPSR compliance defines “placing on the market” as the first time a product is made available for distribution, consumption, or use in the EU.
- If a product was already for sale in the EU before December 13, 2024 → It remains compliant and can continue to be sold.
- If a product was manufactured before December 13, 2024, but is still outside the EU → It must comply with GPSR before being imported.
How GPSR Affects Your Existing Stock
Scenario 1: Products Already Placed on the EU Market Before December 13, 2024
These products are exempt from GPSR compliance and can continue to be sold.
No additional compliance steps are required as long as the product was legally placed on the market before the deadline.
Scenario 2: Products Manufactured Before December 13, 2024, But Still Outside the EU
- These products are NOT exempt from GPSR if they are imported into the EU after December 13, 2024.
- They must comply with GPSR before entering the EU, including:
- Traceability Requirements – Products must have proper labeling, identification, and documentation.
- Risk Assessment & Technical Documentation – A formal safety evaluation must be completed.
EU-Based Responsible Person – A legal representative must be appointed under Article 16 of GPSR.
Steps to Ensure Compliance for Your Products
Steps to Ensure Compliance for Your Products
1. Check Where Your Stock Is Located
- If your stock is already in the EU, it remains compliant under Article 51.
- If it is outside the EU, make sure it meets GPSR compliance requirements before importation.
2. Provide Proof of Manufacture Date
To support customs and compliance checks, businesses should prepare a statement confirming their stock was manufactured before December 13, 2024, and was legally placed on the market before the deadline.
This declaration can be:
- Added to your website for reference.
- Included in shipment documentation.
3. Prepare for Future Shipments
If you plan to import products into the EU after December 13, 2024, make sure you:
- Ensure compliance with GPSR safety requirements.
- Appoint an EU-based Responsible Person to meet legal obligations.
- Update documentation to include risk assessments and traceability details.
Why GPSR Compliance Matters
GPSR introduces stricter safety requirements and greater accountability for businesses selling in the EU. Companies that fail to comply risk delays, fines, and even product bans.
At Euverify, we help businesses navigate EU compliance requirements, ensuring their products meet all GPSR standards.
Final Thoughts
Transitioning to GPSR compliance is a crucial step for businesses selling in the EU. Article 51 provides a grace period for products already in the market, but products still outside the EU must comply before importation.
Need help with GPSR compliance, an EU Responsible Person, or documentation?
Contact Euverify today and make sure your business is fully prepared!
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GPSR
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Products Before 13/12/24
-
Founder of Euverify | EU & UKCA Compliance Expert
Ajay is an eCommerce expert with 17+ years of experience as an Amazon, eBay, and Etsy seller and a Shopify specialist. He excels in EU and UK compliance, including GPSR and UKCA, helping businesses expand into European and UK markets. Ajay is the founder of Sweans, a London-based eCommerce agency, and Euverify.com, a SaaS platform streamlining compliance for non-EU sellers.
- April 11, 2025Industry InsightsTop Reasons for Consumer Electronics Bans in the EU & UK (And How to Avoid Them)
- April 2, 2025Compliance News & UpdatesHow to Make Your Printful Dropshipping Products GPSR Compliant (and Use Euverify to Stay Ahead)
- April 2, 2025Compliance News & UpdatesHow to Make Your Etsy Listings GPSR Compliant and Add Your EU Economic Operator
- March 10, 2025Compliance News & UpdatesGPSR Compliance: What Happens to Products Manufactured Before 13 December 2024?
With the General Product Safety Regulation (GPSR) (EU) 2023/988 now in effect as of December 13, 2024, businesses selling consumer products in the EU need to be clear on the new GPSR compliance requirements.
One of the most common questions we hear is:
What happens to products made before December 13, 2024? Are they exempt from GPSR?
In this guide, we’ll break down Article 51 of GPSR and explain what businesses need to do to stay compliant.
Understanding Article 51: The Transition Rule
What Does Article 51 Say?
GPSR Article 51 (Transitional Provision) of Regulation (EU) 2023/988 clearly states:
“Member States shall not impede the making available on the market of products covered by Directive 2001/95/EC which are in conformity with that Directive and which were placed on the market before 13 December 2024.”
This means that if a product was already placed on the EU market before December 13, 2024, it remains compliant under the previous General Product Safety Directive (GPSD) 2001/95/EC and is not subject to GPSR.
However, if a product was not yet placed on the EU market before this date, it must comply with GPSR compliance before importation.
What Does "Placing on the Market" Mean?
GPSR compliance defines “placing on the market” as the first time a product is made available for distribution, consumption, or use in the EU.
- If a product was already for sale in the EU before December 13, 2024 → It remains compliant and can continue to be sold.
- If a product was manufactured before December 13, 2024, but is still outside the EU → It must comply with GPSR before being imported.
How GPSR Affects Your Existing Stock
Scenario 1: Products Already Placed on the EU Market Before December 13, 2024
- These products are exempt from GPSR compliance and can continue to be sold.
- No additional compliance steps are required as long as the product was legally placed on the market before the deadline.
Scenario 2: Products Manufactured Before December 13, 2024, But Still Outside the EU
- These products are NOT exempt from GPSR if they are imported into the EU after December 13, 2024.
- They must comply with GPSR before entering the EU, including:
- Traceability Requirements – Products must have proper labeling, identification, and documentation.
- Risk Assessment & Technical Documentation – A formal safety evaluation must be completed.
EU-Based Responsible Person – A legal representative must be appointed under Article 16 of GPSR.
Steps to Ensure Compliance for Your Products
Steps to Ensure Compliance for Your Products
Check Where Your Stock Is Located
- If your stock is already in the EU, it remains compliant under Article 51.
- If it is outside the EU, make sure it meets GPSR compliance requirements before importation.
Provide Proof of Manufacture Date
To support customs and compliance checks, businesses should prepare a statement confirming their stock was manufactured before December 13, 2024, and was legally placed on the market before the deadline.
This declaration can be:
- Added to your website for reference.
- Included in shipment documentation.
Prepare for Future Shipments
If you plan to import products into the EU after December 13, 2024, make sure you:
- Ensure compliance with GPSR safety requirements.
- Appoint an EU-based Responsible Person to meet legal obligations.
- Update documentation to include risk assessments and traceability details.
Why GPSR Compliance Matters
GPSR introduces stricter safety requirements and greater accountability for businesses selling in the EU. Companies that fail to comply risk delays, fines, and even product bans.
At Euverify, we help businesses navigate EU compliance requirements, ensuring their products meet all GPSR standards.
Final Thoughts
Transitioning to GPSR compliance is a crucial step for businesses selling in the EU. Article 51 provides a grace period for products already in the market, but products still outside the EU must comply before importation.
Need help with GPSR compliance, an EU Responsible Person, or documentation?
Contact Euverify today and make sure your business is fully prepared!
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