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- Ajay C Thomas
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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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GPSR and Harmonised Standards: What Manufacturers and Marketplaces Need to Know
Businesses that manufacture or sell consumer products in Europe need to be aware of two key frameworks: the new General Product Safety Regulation (GPSR) and the product-specific EU rules commonly referred to as harmonised legislation.
A common question is whether companies should prioritise one over the other. The answer is straightforward: it is not a case of GPSR vs harmonised legislation. Both apply, and they are designed to complement each other. The GPSR provides overarching safety requirements and closes gaps where no specific legislation exists, while harmonised standards sets detailed rules for certain product categories.
In this article, we will break down how the GPSR works alongside existing product laws, highlight what has changed under the new framework, and share practical examples for both manufacturers and online marketplaces.
The EU Product Safety Puzzle: General vs. Specific Rules
The EU uses a two-layer system to keep products safe:
Harmonised product laws: These are rules made for specific types of products. For example, toys must meet the Toy Safety Directive, electronics follow the Low Voltage and EMC Directives, and cosmetics have their own Cosmetics Regulation. If your product meets these rules, it can carry the CE mark, showing it meets EU safety standards.
The General Product Safety Regulation (GPSR): The GPSR has applied since December 2024, replacing the older 2001 directive. Unlike product-specific laws, it covers almost all consumer products, whether physical or digital, and ensures a consistent baseline of safety across the EU market.
So, is it GPSR vs harmonised legislation? Not really. They’re designed to work together. The specific laws deal with known risks for particular products, while the GPSR acts as a safety net to catch anything the others don’t cover. To be fully compliant, businesses need to follow both.
What Are Harmonised Standards in GPSR?
Harmonised standards are EU-recognised technical specifications, usually EN or ISO standards, that give manufacturers a clear way to show their products comply with the GPSR (Regulation (EU) 2023/988). If a product follows a relevant harmonised standard, authorities will presume it meets the safety requirements of the GPSR. This “presumption of conformity” helps reduce legal uncertainty and makes inspections or audits much easier.
Although they are not legally mandatory, harmonised standards are widely used because they set out clear test methods, safety benchmarks, and documentation requirements. For example, applying an EN standard for toy safety or an ISO method for chemical testing can strengthen a manufacturer’s technical file and recall preparedness.
In the UK, GPSR 2005 does not formally adopt harmonised standards. However, businesses often use British Standards (BSI) or international ISO standards as best practice to demonstrate due diligence if questioned by regulators or online marketplaces.
Examples of How the GPSR and Harmonised Standards Work Together
Take a smart toy robot. Toys in the EU must meet the Toy Safety Directive, which covers things like sharp edges, choking hazards, and toxic materials. If it passes, the toy gets a CE mark.
But because this toy is “smart”, it also includes electronics and AI features. The Toy Safety Directive doesn’t fully cover risks like overheating batteries, cybersecurity threats, or hacked smart functions. This is where the GPSR comes in: it requires manufacturers to look at all foreseeable risks, including those linked to new technology. In practice, that means doing a broader risk assessment under the GPSR to catch anything the toy-specific rules miss.
Now consider furniture, like a crib or bookshelf. There’s no EU “Furniture Safety Directive.” Here, the GPSR is the only rule in play. It requires manufacturers to ensure the product is safe by design. For example, that a crib won’t collapse or trap a child, or that a shelf won’t easily tip over.
To put it simply, if your product falls under a specific EU law (toys, machinery, electronics), you must follow it and use the GPSR to cover any extra risks. If no specific law exists (furniture, childcare articles, gym equipment, etc.), then the GPSR is the main rule that applies. Either way, the end goal is the same: consumers get safe products.
When Does the GPSR Apply? (Scope and Examples)
The GPSR applies in two main situations:
- When a product has no specific EU safety law; or
- When existing legislation doesn’t cover certain risks.
It applies to almost all consumer products, from furniture and childcare items to fitness gear and smart devices, but not to food, medicines, chemicals, vehicles, or medical devices, which have their own regulations.
In simple terms, the GPSR works as a safety net. It makes sure that any consumer product sold in the EU, even those with digital or AI features, meets a clear baseline of safety.
Here are some real-world examples:
- Products without specific EU laws
Items like childcare articles, furniture, or simple sports equipment fall mainly under the GPSR. For instance, a baby’s high chair must be stable and free of choking hazards. There’s no EU “High Chair Directive,” so the GPSR is the main law ensuring safety. Similarly, a home fitness resistance band that snaps due to poor quality would be deemed unsafe under the GPSR, and authorities could order a recall. - Products with partial coverage under specific laws
Some products already fall under harmonised legislation but may still have risks that aren’t fully addressed.
- Example: Electric toy — covered by the Toy Safety Directive. But if it includes a laser pointer, the GPSR requires you to assess and mitigate eye injury risks, even if the toy rules don’t.
- Example: Smart oven — regulated under appliance safety directives (covering fire and electrical hazards). However, if it’s Wi-Fi enabled, the GPSR expects you to consider cybersecurity risks, such as hacking that could cause the oven to switch on remotely.
- Overlap with professional products
The GPSR mainly targets consumer goods, not items sold exclusively for professional use. But if professional tools or equipment are also marketed to, or realistically used by, consumers, they must meet general consumer safety expectations.
Key takeaway
The GPSR applies to all consumer products on the EU market in one form or another. If your product is fully covered by a harmonised law, compliance with that law will usually meet the GPSR’s objectives. But if any safety risk falls outside those rules, or if no harmonised law exists, the GPSR fills the gap.
(Note: The GPSR doesn’t apply to antiques or second-hand products sold specifically for repair or display. But if you sell a used product intended for normal use, it must still be safe under the GPSR.)
If your product already follows a harmonised EU law (like toys, electronics, or machinery), you might wonder: Do I still need to worry about the GPSR? The answer is yes. Some obligations apply to all products, even those already covered by specific directives. These horizontal rules ensure consistent safety practices across the market.
Here are the key GPSR obligations that always apply:
- General principles and definitions
Every product must be safe for consumers. The GPSR clarifies what “safe product” means, who counts as an economic operator (manufacturer, importer, distributor), and how authorities cooperate on surveillance. - Safety requirements for new or uncovered risks
Harmonised laws cover known risks, but the GPSR requires you to assess and address any additional risks. For example, low-voltage rules deal with electric shock, but they don’t cover psychological harm or cybersecurity. Under the GPSR, if a risk exists, you must consider it, even if no specific directive mentions it. - Distance and online sales obligations
If you sell online, the GPSR sets extra rules. Product information must be clearly available digitally, and serious incidents must be reported to authorities. For example, a company selling power tools online must comply with the Machinery Directive and GPSR rules on reporting accidents and displaying clear product information. - Online marketplace responsibilities
Platforms like Amazon, eBay, or Etsy now have direct obligations under the GPSR. They must act quickly to remove or block dangerous products, regardless of category, and inform consumers. Marketplaces can no longer claim they’re just “hosts.” - Safety Gate and incident reporting
The EU’s Safety Gate system (formerly RAPEX) remains the main tool for rapid alerts about dangerous products. Under the GPSR, businesses must also use the Safety Business Gateway. This applies whether it’s recalling a faulty hair dryer under the Low Voltage Directive or a stroller under the GPSR. - Consumer rights to information and remedy
If a product turns out unsafe, businesses must inform consumers directly where possible and provide a fair remedy (repair, replacement, or refund). This applies even to CE-marked products under harmonised rules. Safety always comes first.
In short, even if your product already meets a specific EU directive, the GPSR adds universal obligations around risk assessment, online sales, marketplace duties, recalls, and consumer rights. Full compliance means following both the product-specific rules and these GPSR-wide requirements.
Responsibilities of Manufacturers Under the GPSR
The GPSR sets out clear duties for manufacturers, including brand owners, to ensure consumer products are safe throughout their entire life cycle. Many of these duties align with good practice, but some are new or more detailed than before. Here’s a clear breakdown of what manufacturers must do:
- Design and produce safe products by default
Safety should be built into design and production from the start. That means using safe materials, removing hazards where possible, and applying warnings or safeguards for any remaining risks. Manufacturers must carry out a comprehensive risk assessment, considering not only normal use but also foreseeable misuse — including by vulnerable groups such as children, older people, or persons with disabilities. The GPSR also requires consideration of modern risks like cybersecurity threats or AI/software updates, which may alter a product’s safety after it reaches the market. - Maintain technical documentation
Manufacturers must keep a technical file (e.g., test results, risk assessments, design specifications) for at least 10 years after the product is placed on the market. This serves as proof of compliance if authorities question product safety. - Ensure proper labelling and traceability
Products must carry:
- A model or batch number,
- The manufacturer’s name/brand, and
- A postal address.
Under the GPSR, an email address or website must also be included so consumers and authorities have a direct electronic contact point. Proper traceability is crucial for effective recalls and incident management.
- Appoint an EU-based representative (if outside the EU/EEA)
Non-EU manufacturers must appoint an authorised EU representative or importer to act as the “responsible person” for compliance. Without such representation, products cannot legally be sold in the EU. - Monitor safety once products are on the market
Safety responsibilities continue after sale. Manufacturers must set up accessible channels (such as a hotline, website form, or email) where consumers can report incidents. Reports must be investigated and acted on promptly. For example, if complaints reveal a recurring defect that could cause harm. - Report serious incidents and recalls
If a product poses or causes serious harm, manufacturers must immediately notify EU authorities through the Safety Business Gateway, which allows cross-border alerts. This obligation applies to recalls, withdrawals, or other corrective actions. - Take corrective action quickly
When hazards are identified, manufacturers are expected to act without delay. This may include updating warnings, withdrawing products from sale, or launching a full recall. Acting early and in good faith can also reduce enforcement risks.
New Duties for Online Marketplaces Under the GPSR
If you operate an online marketplace (or sell through one), the GPSR brings in new responsibilities you can’t ignore. Platforms like Amazon Marketplace, eBay, Alibaba, Etsy, or Rakuten are no longer just “neutral intermediaries.” They now play an active role in keeping unsafe products away from consumers.
Here’s what online marketplace operators are required to do:
- Set up clear safety contacts
Marketplaces must have:
- A single point of contact for EU authorities, registered in the Safety Gate portal, and
- A public contact point for consumers, such as an email or web form for reporting unsafe products.
This ensures authorities and consumers can reach the right person quickly when risks are identified.
- Act fast on removal orders
If a national authority flags a dangerous product, the marketplace has just 2 working days to take it down, block access, or post a clear warning. Delays are no longer acceptable — the aim is to stop unsafe products being sold without hesitation. - Monitor Safety Gate alerts
Marketplaces are expected to proactively check EU Safety Gate alerts and remove flagged products from their platforms. For example, if the system reports a charger prone to overheating, the platform must search for that model and ensure it disappears from listings. - Ensure seller transparency
Consumers must see who makes or imports the product and key safety information in the online listing — just like they would in a physical store. Marketplaces must require sellers to provide details such as the manufacturer’s name and address, contact info, product ID, warnings, and age restrictions, and make this visible to buyers. - Process safety notices quickly
Under the GPSR (aligned with the Digital Services Act), platforms must handle user safety notices within 3 working days. That means if a consumer, authority, or manufacturer reports a dangerous item, the platform must review and act on it promptly. - Tackle repeat offenders
If sellers repeatedly list unsafe or non-compliant goods, marketplaces are expected to suspend their accounts for a reasonable period, or permanently in serious cases. This helps stop rogue traders from continually resurfacing with unsafe products. - Cooperate in recalls and corrective actions
When a recall or corrective measure is underway, marketplaces must cooperate. This could include:
- Informing affected customers,
- Posting recall notices on the site, and
- Sharing information with authorities (e.g., sales figures, seller identity).
What this means in practice:
Online marketplaces need to invest in compliance systems, staff training, and monitoring tools to handle these duties effectively. Safety checks, seller oversight, and fast response times are now part of doing business.
The goal is clear: consumers should be just as safe buying online as they are in a brick-and-mortar shop.
Final Takeaway
The EU’s product safety framework isn’t about choosing between the GPSR and sector-specific laws. It’s about how they work together. Harmonised legislation gives detailed rules for certain products, while the GPSR acts as the safety net to cover any gaps. Together, they ensure that whether you produce toys, electronics, furniture, or fitness gear, consumers can trust that safety always comes first.
But compliance doesn’t end once a product passes design and testing. The GPSR also strengthens Europe’s Safety Gate rapid alert and recall system, meaning businesses need to react quickly when something goes wrong. That means being ready to flag incidents, manage recalls, communicate with customers, and work with authorities across the Single Market. It’s a big responsibility — and it can be resource-heavy if you try to handle it all on your own.
That’s where Euverify steps in. We support manufacturers, importers, and online marketplaces in making compliance a smooth and reliable part of your operations. From GPSR safety assessments, documentation, and authorised representation services to GDPR representation, we bring clarity and practical solutions tailored to your business.
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