GPSR Compliance Checklist for Online Sellers: What the EU Rule Asks For

The EU General Product Safety Regulation (Regulation (EU) 2023/988, applying since 13 December 2024) asks an online seller to ensure each consumer product has an EU-based responsible person, carries traceable identification and safety information, shows that information in the online listing, and is backed by a technical file and complaint records. AI can draft the paperwork; a person must verify it.

The rule applies to businesses of any size, including sellers outside the EU who sell to buyers inside it. It covers new, used and free items. Toys, electronics and some other categories also come under product-specific EU rules, so they need a legal check beyond this checklist. Treat everything here as practical preparation, not legal advice.

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First decide whether you are in scope

You are in scope if you offer consumer products to buyers in the EU, whether through your own store, a marketplace or social selling, and wherever you are based. The Commission's guidelines for businesses (Commission notice C/2025/6233, November 2025) list a few cases that surprise sellers: second-hand, refurbished and repaired products are covered when a business sells them, an item supplied free of charge in the course of business still counts, and one business can be a marketplace for some listings and a manufacturer, importer or distributor for others.

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Where a product also falls under specific EU safety legislation (toys and many electrical products are examples), the GPSR applies only to the aspects and risks that legislation does not cover, though some chapters, such as those on online sales, accident reporting and marketplaces, still apply. The Commission's guidelines also give the opposite case: childcare articles, gymnastic equipment and furniture have no specific EU safety rules, so the GPSR applies to them in full. If your product sits in a category with its own rules, treat the checklist below as a minimum and take the specific rules to a specialist.

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Write down your role for each product, because the duties differ:

• Manufacturer: you make it or have it made and sell it under your name.
• Importer: you bring a product from outside the EU onto the EU market.
• Distributor: you resell a product someone else made or imported.
• Fulfilment service provider: you store, pack or dispatch for others.

A small brand often holds two of these roles at once, and a dropshipper may be a distributor without ever touching the goods.

Reading each group, and where an assistant fits

Each group below says what is asked, why it matters and how to verify it. The "AI can draft" lines mark where an assistant saves time. It can summarise a product sheet into a first draft, spot gaps between your listing and the list, and write consistent text for forty products. It cannot know whether a product is safe, what a test showed or who is legally responsible, and it will sometimes state a legal requirement with confidence it has not earned. The way to use it is to give it your own documents and the checklist, then verify every claim against the Regulation and the Commission's pages.

Group 1: the responsible person

For a consumer product on the EU market, an economic operator established in the EU must be responsible for it. Article 16 of the GPSR, through Article 4 of Regulation (EU) 2019/1020, sets the order in which that role falls:

1. the manufacturer, if established in the EU;
2. otherwise the importer;
3. otherwise an authorised representative, who must be mandated in writing by the manufacturer;
4. as a last resort, a fulfilment service provider established in the EU, for the products it handles, when none of the above is established in the EU.

• Item: a named EU-established responsible person for every product line.
• Why: authorities need someone in the EU to contact and to hold the technical file.
• Verify: a signed mandate on file if you use an authorised representative, and the contact details match what appears on the label and the listing.
• AI can draft: a one-page mandate outline and a table of "product, role, responsible person, contact". A lawyer or the representative's own terms should settle the real mandate.

Note that the responsible person is not the same as a "single contact point". Manufacturers and importers print a single contact point's address only where it differs from their own, and online marketplaces must designate single points of contact for authorities and for consumers. The two can be the same business, but they are separate duties.

Group 2: risk analysis and the technical file

• Item: an internal risk analysis for each product, and technical documentation that records it.
• What goes in: a general description and the essential characteristics relevant to safety; any risks identified, with the analysis and the solutions used to remove or reduce them; and the relevant EU standards, or where there are none, other national requirements or methods.
• Why: Article 9 requires it before a manufacturer places a product on the market, and the Commission's guidelines say the level of detail should be proportionate to the product's complexity and its possible risks.
• Keep for: at least 10 years, available to market surveillance authorities.
• Verify: the file exists per product, is dated, names who prepared it and is reviewed when the product changes.
• AI can draft: the skeleton and a first pass from the product's specification, material list and any test report you give it.

The Commission's guidelines include a model template for the file (not compulsory), which is a better starting point than a blank page. Ask the assistant to map your product sheet onto that template, and to list the sections for which you gave it nothing.

A prompt for the first draft

I sell the product below to consumers in the EU. Using ONLY the information I give you, draft the headings and contents of a technical file: (1) general description, (2) materials and components, (3) intended use and foreseeable misuse, (4) hazards you can identify from this information alone, (5) measures already in place, (6) standards or tests mentioned in my documents. For every heading where my information is missing, write "NOT PROVIDED, needs [who]". Do not invent test results, standards or certificates.

PRODUCT SHEET:
[paste]

An illustrative reply for a ceramic mug would give a tidy description, flag that food-contact test evidence is "NOT PROVIDED, needs supplier", and list heat and breakage as hazards drawn from the sheet. The blank flags matter more than the prose: they are your to-do list.

Group 3: identification and the label

• Item: each product carries a type, batch or serial number (or another element that allows identification), unless the size or nature of the product makes that impossible, in which case it goes on the packaging or an accompanying document.
• Item: the manufacturer's name, registered trade name or trade mark, and a postal address and an electronic address where they can be contacted.
• Item: where the manufacturer is outside the EU, the responsible person's name and postal and electronic address on the product, packaging, parcel or an accompanying document.
• Item: instructions and safety information that consumers can easily understand, including warnings the product needs.
• Why: traceability. If a batch has a fault, a seller must be able to say which units are affected and who bought them.
• Verify: hold a finished unit as the customer receives it and tick each element against the physical item.

Two clarifications save sellers a reprint. The Commission's guidelines say an "electronic address" can be an email address or a dedicated section of your website through which consumers can contact you directly; a website that does not allow direct contact is not enough. And Article 21 of the Regulation lets you give the same information in digital form, such as a QR code, only in addition to the printed details, never instead of them.

Group 4: the online listing

This is the part online sellers feel most, because it touches every product page and marketplace listing. For offers made online, the Regulation asks that the listing clearly shows, at a minimum:

• the manufacturer's name, trade name or trade mark, and postal and electronic address;
• the responsible person's name, postal address and electronic address, where the manufacturer is not in the EU;
• information that identifies the product, including a picture of it, its type and any other product identifier;
• any warning or safety information that is to be affixed to the product or provided with it, in a language consumers can easily understand.

That list is Article 19 of the Regulation. Marketplaces add their own required fields and formats on top, so check each channel's listing form when you finalise your template.

A reusable block for product pages

Create one standard block and fill it per product, so the information sits in the same place on every page. A filled-in illustration for a made-up desk organiser:

Product information
Product: Walnut desk organiser, model WO-2, batch shown on underside
Made by: [Brand name], [postal address], [email or contact-form link]
EU responsible person: [Name], [postal address], [email or contact-form link]
Safety information: Not suitable for children under 3 (small parts). Keep away from open flame.

An assistant can fill this block for 40 products from a spreadsheet in one pass. Two precautions: tell it never to invent a warning (copy warnings only from the technical file), and check at least five pages in the live shop afterwards, because a template that drops a field on variants is the usual failure. If you publish across several marketplaces, the tutorial on listing one product across several marketplaces shows how to keep each channel's field rules straight.

Group 5: complaints, accidents and recalls

• Item: a way for consumers to contact you about safety, and a log of complaints and what you did about them.
• Item: an accident process. The manufacturer (or, for a manufacturer outside the EU, the responsible person) notifies the authorities through the EU's Safety Business Gateway; importers and distributors who learn of an accident tell the manufacturer without undue delay. Add a rule for acting at once if you find a product is dangerous.
• Item: a recall plan: who contacts buyers, with what message, and what remedy is offered.
• Verify: run a ten-minute dry run once a year: "a customer reports a burn. Who does what in the first hour?"
• AI can draft: the complaint-log template, the incident checklist and a recall notice for you to adapt; it can also sort a year of customer emails to show which mention safety.

For investigating a complaint properly, the structure in answering a customer complaint step by step adapts well to a product-safety report, even though it was written for a factory setting.

Group 6: records you can find in a hurry

The checklist only works if the evidence can be found when an authority or marketplace asks. Keep, per product: the technical file, test reports and certificates, supplier documents showing who made it, the responsible-person mandate, the label artwork, screenshots of the live listing, and the complaint log. Name files by product code and date, and keep the technical file for at least 10 years.

A table helps more than a folder structure. One row per product, columns for each group above with a date, and a "last reviewed" cell. The assistant can build the table from your catalogue and highlight blank cells, which is a fast way to see where you stand.

Worked example: a small seller with two products and two sales routes

This is an illustration with invented details. A small maker based outside the EU sells two products to EU buyers: a ceramic mug and a rechargeable LED desk lamp made by a contract factory. Sales run through its own online store and one marketplace.

The seller gives the assistant its two product sheets and the checklist from this tutorial and asks for a gap list. The reply flags the missing food-contact test evidence for the mug, the missing factory reports for the lamp, and that the marketplace listing shows an email address but no postal address for the responsible person. That last gap is the sort of thing that gets a listing taken down, and it takes five minutes to fix. The seller then spends time where it matters: getting the lamp checked by someone who knows electrical product law, not editing prose.

If you resell or dropship: the distributor's checks

A seller who buys finished goods from a supplier and resells them is usually a distributor, and the duties are lighter but real. Article 12 of the Regulation requires distributors to verify, before making a product available, that the manufacturer and, where relevant, the importer have met the identification, contact-detail and safety-information requirements, and to make sure storage or transport does not compromise the product's safety while it is in their care. In practice that gives you a short routine for each new supplier line:

1. Ask the supplier, in writing, for the manufacturer's name and address, the EU responsible person's details, and a copy of the technical documentation summary or test reports for the product.
2. Receive one sample and check that the label, batch or serial marking and warnings are on the item or packaging, in the language of the buyer.
3. Check the supplier's product photos and your listing show the same product, not a lookalike.
4. Keep the supplier's answers with your product record. If the supplier cannot answer, treat the product as not ready to sell.

An assistant can write the supplier request in a polite, specific form and track which suppliers have replied. A message such as "Under the EU General Product Safety Regulation I need the following for [product code] before I list it: manufacturer name and postal and electronic address; EU responsible person details; batch or serial marking location; summary of risk analysis or test reports" is clear enough that many suppliers will answer it at once. It also records the date you asked, which helps if a question arises later.

Dropshippers face a particular trap: the supplier ships directly to the buyer, so you never see the label or the product. Order one unit to yourself for every new product, and open the box as a customer would. If the parcel arrives with no address for a responsible person, the product is not ready, however good the margin looks.

Where AI helps most, and where to keep it away

The most reliable uses involve your own documents and a fixed list:

• Gap finding. Paste a listing and this checklist; ask which required elements are missing. Quick, and the answer is checkable line by line.
• Consistency. Compare the address on the label artwork, the listing and the mandate. Mismatched addresses are common after a move or a change of representative.
• Bulk fill. Apply the product-information block across a catalogue.
• Translation of safety text. An assistant can draft a translation for each market language, but a fluent human reader must check warnings, because a mistranslated warning is a safety failure.
• Templates. Complaint log, incident checklist, recall notice, review calendar.

Keep it away from deciding whether a product is safe, which standards apply to it, whether a claim of compliance is true, and who the legal responsible person is. Those are judgements for a person, sometimes a specialist, and an assistant's confident answer on any of them is a reason to double-check, not to relax.

A listing that looked complete and was not

In an illustrative case, a seller added a product-information block to 60 listings with an assistant's help. The block was correct. But on products with colour variants, the store's template showed the block only on the first variant's page, and the marketplace export dropped the field for variants altogether. Half of the live offers lacked the information the seller thought was there.

It came to light because the seller opened four random listings on a phone, one of them a variant, as part of a final check. The fix was a template change and a re-export. The lesson is to verify the live page, as a customer sees it, not the spreadsheet you uploaded.

A first-month plan for a small seller

1. Week 1. List products and your role for each. Decide the responsible person and sign any mandate. Flag toys, electronics and anything in a category with specific EU rules for a specialist.
2. Week 2. Draft technical files with the assistant from product sheets. List missing evidence and request it from suppliers.
3. Week 3. Fix labels and packaging at the next print run, and add the product-information block to listings, starting with best sellers.
4. Week 4. Set up the complaint log, the accident-reporting steps and the records table. Check live pages as a customer. Put a yearly review in the calendar.

If you want a second pair of eyes on how this fits your catalogue and workflow, that is part of my AI implementation consultation. For the import side of the same job, the importer's compliance checklist covers the documents an importer holds.

Verifying against the official source

Rules and guidance change. Before you rely on any line above, check it against the text of Regulation (EU) 2023/988 and the Commission's current product safety pages, including its guidelines for businesses. Look in particular at the exact wording on online offers, the responsible-person rules for your sales route, and any product-specific rules for your category. Where a point decides whether you can sell a product at all, ask a qualified adviser who handles EU product rules, and keep a note of what you asked and when.

GPSR questions small sellers ask

Does GPSR apply to a very small online shop?

Yes. The Commission's guidelines for businesses say the obligations are relevant for businesses of all sizes. A few duties of online marketplaces apply only to medium and large marketplace providers, but there is no exemption for a small seller, and a sole trader selling to EU consumers has the same checklist.

Can a QR code on the box replace the printed label?

No. Article 21 of the Regulation allows the information in digital form only in addition to the physical details. Put the required information on the product, or on the packaging or an accompanying document if the product cannot carry it, and add a QR code only as an extra.

Who counts as the responsible person if I sell from outside the EU?

Following the Commission's cascade: the manufacturer if established in the EU, otherwise the importer, otherwise an authorised representative with a written mandate, and as a last resort a fulfilment service provider. A non-EU seller usually needs to appoint one before selling to EU consumers.

Can AI write my technical documentation?

It can draft the structure and a first pass from your product sheet, but it cannot know your product's real risks or test results. A named person must check every statement, and the file must be kept for at least 10 years and be available to market surveillance authorities.

Further reads

• Can AI Check Customs Compliance? What a Person Must Still Verify — What a person must still verify when AI checks import paperwork.
• Bulk Product Description Generator: From CSV Rows to Unique Copy — Fill many listings from a spreadsheet, then check the output.
• Dietary Supplement Claims: What to Cut From AI-Written Product Copy — Another product-copy area where wording must be checked.
• Candle Warning Labels: An AI Draft and a Pre-Print Checklist — A worked example of drafting and checking product warnings.
• Product Data Enrichment for Industrial Catalogues: AI Fills Gaps — Fill gaps in product data before you publish it.
• Best AI for Ecommerce Operations: Orders, Stock, Returns, Suppliers — Orders, stock and returns routines that support batch traceability.
• CE Marking Technical File Checklist: Draft the Outline With AI — A checklist for building a CE technical file outline with AI, and the checks a competent person still has to make.
• Safety Data Sheet Management: Keep SDS Files Current With AI Help — A register-first method for suppliers: AI reads each safety data sheet into a table, flags stale ones and drafts replies, while a person signs off.
• AI Tools and AI Development: The Complete 2026 Guide — the AI hub, including every tutorial in the AI-for-business series.

Sources: Regulation (EU) 2023/988 as published on EUR-Lex, and the Commission notice C/2025/6233, Guidelines on the application of the EU general product safety legislative framework by businesses, both read in November 2026. Check the current Commission product safety pages before relying on any item. This is practical guidance, not legal advice.