General Product Safety Regulation: Who's Your Responsible Person?
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A new EU regulation is being introduced that will affect almost all products sold on Amazon.
From 13 December 2024 the General Product Safety Regulation (GPSR) will come into force, replacing the General Product Safety Directive. This applies to most non-food consumer products for sale in the EU.
Its biggest impact is that almost all products sold in the EU now need to have a Responsible Person (RP), based in the EU, named on the product.
What’s significant about this?
The new GPSR rule apes the EU Market Surveillance Regulation, which requires all CE-marked products to have a dedicated RP established in the EU to act as a point of contact for product compliance.
Now, it’s not just CE-marked products: when GPSR comes in in December, almost all consumer non-food items will need an RP and changes to product labelling, which must be applied to all products sold on Amazon in the EU and Northern Ireland before the deadline date.
Non-compliant products after this date may result in listings removal or even suspension of your Amazon account.
Where does GPSR apply?
GPSR is EU-wide. Be careful with the UK: it does not apply in Great Britain (England, Scotland, and Wales), but it applies in Northern Ireland under the Northern Ireland Protocol.
What products are affected?
Almost all of them - it’s quicker to list the exceptions:
- Medicinal products for human / veterinary use
- Food and beverages
- Animal feed
- Living plants and animals (including genetically modified organisms and genetically modified microorganisms in contained use, as well as products of plants and animals relating directly to their future reproduction)
- Animal by-products and derived products
- Plant protection products (for example, pesticides)
- Equipment on which consumers ride or travel when that equipment is directly operated by a service provider within the context of a transport service provided to consumers, and not operated by the consumers themselves
- Aircraft
- Antiques.
What’s required from manufacturers?
It’s required to have a Responsible Person (RP) based in the EU. This could be one of the following:
- An individual from the manufacturer/brand, if based in the EU
- An importer established in the EU
- An authorised EU-based representative, appointed as RP in writing
- A fulfilment service provider established in the EU.
To comply with GPSR, manufacturers must label their products with contact information including postal address and email of the manufacturer, and the name, address and email of the Responsible Person.
The labelling must be placed on the product, or if this isn’t possible - for example, because the product is too small - on the packaging or a separate document that accompanies the product.
It can be included with the other information that’s legally required on the product, such as the serial number and safety warnings.
What does the Responsible Person do?
The RP’s duties include:
- Collecting the product’s EU declaration of conformity (or declaration of performance), and ensuring that documents demonstrating the conformity of the product with EU law can be made available on request in a language understood by the relevant authority
- In some cases, informing authorities of any risk posed by the product
- Cooperating with market surveillance authorities, including ensuring that the manufacturer or brand owner takes actions to remedy non-compliance issues
- Checking for compliance with technical documentation, product and manufacturer information, instructions, and safety information
- Providing evidence of checks performed on request by authorities.
How does this new ruling affect listings on Amazon?
As well as ensuring your labelling complies with the new rules, your listings should include the information too.
Sellers must display the manufacturer’s name and contact information, and the Responsible Person’s name and contact information, on the product detail page.
If your product is associated with a brand in Amazon Brand Registry, you can use the Add Compliance Information widget to provide your Responsible Person information and manufacturer information. This widget should be in the bottom-right corner of Account Health, or the top-right corner of Manage Your Compliance.
What documents are needed to prove compliance?
There are various documents you can use to prove compliance with GPSR on your product detail pages, for consumer peace of mind.
You can upload documents in Seller Central for your products. Documents that can be used to demonstrate compliance include:
- A fact sheet
- An installation manual
- Instructions for use
- A user guide
- A user manual
- Safety information.
The document should be uploaded as a URL for direct download.
Amazon should review your product documents for adherence to the Amazon guidelines within seven days.
eComas’s Retail Support Manager Efigenia Miranda says: “At e-Comas we are actively reaching out to our clients to ensure their products will be ready for the new regulation when it comes into force in December.
“We recommend clients talk to their legal teams to ensure they know what categories their products fall under, and whether they fall under the scope of the new rules.”