Do Mobile Apps Fall Under the GPSR? What Digital Brands Must Know
Most digital businesses assume the EU’s General Product Safety Regulation (GPSR) applies only to physical goods like toys, electronics or household products. But the moment a mobile app interacts with a real product, influences user behaviour or affects consumer wellbeing, it can fall squarely under the GPSR.
The European Commission’s Guidelines on the Application of the General Product Safety Legislative Framework by Businesses – C(2025) 7699 final, further clarify that digital elements, software functions and connected behaviours can all influence product safety. These guidelines make it clear that mobile apps are no longer outside the scope of consumer safety law, especially when they form part of how a product operates or is used.
This is one of the most overlooked areas of the new regulation. It is also one of the biggest opportunities for digital brands to prepare early and stay ahead of compliance requirements.
If your app connects to a product, guides the use of a product or could impact consumer safety in any way, you should understand what the GPSR expects. This article explains clearly and shows how digital businesses can stay compliant.
Do Mobile Apps Fall Under the GPSR?
Yes, in more cases than you think.
The GPSR recognises that software, digital features and mobile apps are now inseparable from how many consumer products function. According to the official EU Guidelines, product safety today includes risks linked to “software, algorithms, data systems and cybersecurity issues” and their effects on both physical and mental wellbeing (European Commission, 2025, p. 6).
This means that mobile apps can fall under the GPSR when they:
- control or interact with a physical consumer product
- influence the safe use of a product
- provide digital instructions or warnings
- enable product updates or behavioural changes
- contain features that may mislead, confuse or harm consumers
- impact mental health, cognitive load or stress
- are used by vulnerable consumers like children or persons with disabilities
The moment your app becomes part of a product’s safety chain, GPSR obligations apply.
How Apps Become “Components” of Consumer Products Under the GPSR
Even if your business does not sell physical goods, your mobile app can still be considered part of a consumer product if:
- the app controls or adapts how the physical product works
- key safety functions rely on the app
- the user cannot operate the product safely without the app
- the product is updated through the app
- the app provides safety instructions or alerts
The Guidelines highlight that risks related to software, algorithms and digital systems must be considered when assessing a product’s safety, especially when digital elements influence how the product is used (European Commission, 2025, p. 6).
They also explain that when a product includes digital or connected functions, economic operators must consider how these digital features may affect safety throughout the product’s lifetime (European Commission, 2025, p. 14).
Examples of apps that fall under GPSR:
- Apps that control smart home devices
- Fitness tracker companion apps
- Apps used to set up or calibrate wellness devices
- Apps used for children’s toys or smart gadgets
- Apps that warn users about risks, heat, weight limits or dangerous conditions
- AR apps for interactive toys
- Apps that guide product installation or safe use
If your app is a medical device, or controls one, the Medical Device Regulation (EU) 2017/745 applies instead. The GPSR only covers risks that the MDR does not.
Mental Health and Cognitive Safety: A New Requirement Under GPSR
One of the biggest changes in the GPSR is that it recognises mental health risks.
Article 6 of the GPSR says businesses must consider the health risks of digital connected products, including risks to mental health. This matters most for vulnerable consumers, especially children.
The Guidelines state that a safe product is one that does not cause unacceptable risks related to “cognitive abilities, depression, anxiety or sleep quality” (European Commission, 2025, p. 6).
For mobile apps, this includes:
- confusing interfaces that lead to misuse
- dark patterns or manipulative designs
- stress-inducing notifications
- excessive demands on attention or cognition
- misleading instructions or visuals
- apps designed for children with overstimulating elements
Earlier EU product safety rules focused on physical harm. The GPSR now makes mental health part of the safety assessment for connected products. Digital brands should build it into their risk thinking from the start.
Child-Appealing Apps and Vulnerable Users: What the Law Expects
If your app is likely to be used by vulnerable groups, your obligations increase.
The Guidelines require economic operators to consider consumer vulnerabilities such as:children, older persons, persons with disabilities, cognitive limitations and gender-specific differences (European Commission, 2025, p. 13).
This applies directly to mobile apps when:
- the app has child-appealing visuals
- the app could mislead a child into unsafe behaviour
- children may use the app unintentionally
- accessibility barriers prevent safe use
- voice assistants or chat features impact vulnerable users
- instructions or warnings are not adapted to the target audience
Digital brands must demonstrate in their risk assessment how they considered these groups.
App Design, UX, and Safety: Why Your Interface Now Matters Legally
Under the GPSR, unclear or misleading safety information can make a product unsafe.
The Guidelines explain that safety information and instructions must be accessible, clear and suitable for all intended users, taking into account differences in abilities and vulnerabilities (European Commission, 2025, pp. 17–20).
This means:
- your app cannot rely only on complex visuals
- mandatory safety information must be easy to find
- warnings must not be hidden in menus
- accessibility features must be available for persons with disabilities
- safety messages must be clear, readable and actionable
If an app’s design leads users to misuse the product, authorities may see it as a safety risk.
Connected Apps Must Report Safety Issues Through Proper Channels
If your app is part of a consumer product’s safety system, your brand may have obligations such as:
- collecting consumer complaints
- monitoring safety issues
- reporting accidents through the Safety Business Gateway
- cooperating with national authorities
These duties apply to economic operators like manufacturers, importers, authorised representatives and responsible persons.
If your app is tied to a physical product, your brand must ensure these processes exist. If you are not based in the EU, you must appoint an EU Authorised Representative or Responsible Person to fulfil these duties.
Do App-Only Businesses Need an EU Authorised Representative?
It depends on who places the product on the EU market.
If you make and sell a physical product that works with your app, and your business is outside the EU, you need an EU-based economic operator. This can be an Authorised Representative or a Responsible Person under Article 16 of the GPSR.
If you only build the app and another company makes and sells the product, the main GPSR duties usually sit with that manufacturer. You may still need to support them with safety information, updates and fixes.
What the manufacturer must do:
- Carry out the risk analysis
- Prepare the technical documentation
- Provide clear instructions and safety information
- Take corrective action when a safety issue appears
What your EU representative does:
- Checks that the technical documentation exists and keeps it available for authorities
- Acts as your contact point for market surveillance authorities
- Cooperates with authorities on safety issues
- Helps make sure accidents are reported and corrective action is taken
Your representative supports your compliance. They don’t replace your own safety work as the manufacturer.
New EU Laws That Affect Apps
The GPSR is not the only law digital brands need to watch. Two newer laws now apply directly to software.
Cyber Resilience Act (EU) 2024/2847
The CRA covers products with digital elements. That includes connected devices and the software that runs them. Since 11 September 2026, manufacturers must report actively exploited vulnerabilities and severe security incidents. An early warning is due within 24 hours, through the EU’s single reporting platform. The CRA’s full security requirements apply from December 2027.
Product Liability Directive (EU) 2024/2853
The new PLD treats software, including apps, as a product. It also covers medically recognised psychological harm. It applies to products placed on the market after 9 December 2026. This means app makers can face liability claims if a defect in their software causes harm.
What about standalone apps?
The European Commission’s GPSR Q&A confirms the regulation applies to all types of products, including software, unless other specific EU laws cover them. So a standalone app aimed at consumers can be in scope when it creates a safety risk.
Final Thoughts
Yes, mobile apps can fall under the GPSR. This includes standalone apps when they impact consumer wellbeing and all apps that interact with physical consumer products. The GPSR demands that digital brands take safety seriously, not only in function but in design, communication and user experience.
The good news is that compliance does not have to slow innovation. With the right processes and the right EU partner, digital brands can meet their obligations while continuing to build engaging, safe and user-friendly apps.
Euverify can serve as your EU Authorised Representative or Responsible Person, helping you fulfil the GPSR’s digital safety requirements with confidence and clarity.
References
European Commission. (2025). Guidelines on the Application of the EU General Product Safety Legislative
Framework by Businesses. C(2025) 7699 final.
Regulation (EU) 2023/988 on General Product Safety
Regulation (EU) 2019/1020 on Market Surveillance
Directive (EU) 2019/882 on Accessibility Requirements
European Commission Safety Gate Portal
Regulation (EU) 2024/2847 (Cyber Resilience Act)
Directive (EU) 2024/2853 (Product Liability Directive)
Regulation (EU) 2017/745 (Medical Device Regulation)
European Commission, GPSR Questions and Answers
