GPSR for sellers outside the EU: a step-by-step checklist

Consumer products are covered whether new or used, unless excluded (food, medicines, antiques and the other groups in Article 2(2)). Products with their own EU safety law, such as toys or electrical equipment, follow that law for most duties, but the GPSR rules on listings and accidents still apply. See GPSR scope.

If the product is sold under your name or brand, you are its manufacturer, even when a factory makes it for you (Articles 3(8) and 13(1)). If you resell another brand's products, that brand owner is the manufacturer. The business that brings the goods into the EU and places them on the market is the importer, and it must be established in the EU (Article 3(10)). If you ship straight to consumers from outside the EU, there may be no importer at all.

A product may only be placed on the EU market if a business established in the EU is responsible for it (Article 16(1)): an EU importer, an authorised representative you appoint by written mandate, or an EU fulfilment service provider that handles your goods. See Responsible person. A free mandate template is on this site.

• a type, batch or serial number or another identifier (Article 9(5));
• the manufacturer's name, registered trade name or trade mark, and postal and email address (Article 9(6));
• the importer's name and contact details, where there is an importer (Article 11(3));
• the responsible person's name and contact details, on the product, its packaging, the parcel or an accompanying document (Article 16(3));
• instructions and safety information in a language consumers in each country of sale easily understand (Article 9(7)).

The label generator puts these details together, ready to print.

Each offer must show the manufacturer's and the responsible person's contact details, a picture and identifier of the product, and its warnings in the language of the country (Article 19). Marketplaces give you fields for this and may remove offers without it. See Online listings.

• technical documentation with an internal risk analysis, kept for 10 years (Article 9(2) and (3)); see Technical documentation;
• a copy the responsible person can hand to the authorities on request (Article 16(1) with Article 4(3) of Regulation (EU) 2019/1020);
• records of who supplied you and whom you supplied, available for six years (Article 15(3) and (5)).

Set up a public way for consumers to send complaints and report accidents (Article 9(11)). Accidents causing death or serious harm to health are notified through the Safety Business Gateway (Article 20). A dangerous product means corrective action, and a recall notice in the set form. See Accidents and recalls.

The GPSR check confirms your role and lists your duties as a checklist you can print.