Ensuring Product Safety Under the GPSR

Anyone selling non-food products, including handmade goods or very small quantities, must meet the EU product safety requirements, whether that is in their own online shop, on online marketplaces, or in brick-and-mortar retail. This applies to manufacturers just as much as to importers and retailers who resell products under their own name.

In brief: The EU General Product Safety Regulation (GPSR, Regulation (EU) 2023/988) and the new German Product Safety Act (Produktsicherheitsgesetz, ProdSG), in force since February 19, 2026, require every seller of non-food products, even for tiny quantities and handmade goods, to appoint a responsible person in the EU, carry out a risk analysis with technical documentation, and provide contact and warning notices, including online. Violations can be fined up to €100,000.

Who is affected?

In principle, every company and individual that places non-food products on the market in the EU is affected, regardless of company size, sales channel, or quantity. There is no minimum threshold, as was sometimes assumed in the past: even someone offering only handmade products on a marketplace or in tiny quantities falls under the GPSR. This applies regardless of whether the sale is a main or a side occupation, and regardless of whether it involves a single product or a broad range. Anyone importing goods from third countries must additionally ensure that an economic operator based in the EU takes on the responsible-person role, since the obligations otherwise cannot be met and the import is effectively blocked. Pure online retailers who do not manufacture products themselves, but only resell them or sell them under their own label, can also face their own obligations depending on the situation. A tool like Company Audit shows which of these obligations specifically apply to your company.

What exactly do you need to do?

At its core, the GPSR requires that a reachable, responsible person be named for every product and that you can demonstrate and document the safety of your products. This duty to provide evidence does not only apply to new products, but also to goods already on the market, for which corresponding documentation must exist. In concrete terms, this results in the following steps:

1. Name a responsible person (economic operator) in the EU for every product.
2. Carry out a risk analysis and create and retain technical documentation for each product.
3. Provide manufacturer or responsible-person details and warning notices on the product and online.
4. Ensure traceability, for example through batch or model labeling.
5. Set up a procedure for corrective action and for reporting unsafe products.

In practice, it is advisable to work through these points separately for each product line, since risk analysis and technical documentation can differ significantly by product category. If you offer several product variants, you should structure your documentation so that it can be produced quickly in the event of an inspection.

By when, and how often?

This is not a one-time deadline, but a permanent obligation: the new ProdSG, which supports the GPSR requirements in German law, has applied since February 19, 2026. Risk analysis, technical documentation, labeling, and warning notices must therefore be in place from now on and kept continuously up to date, for example whenever a product, its manufacturing process, a supplier, or the legal assessment changes. When adding new products to your range, the requirements must also be checked again each time before the product is placed on the market; a later adjustment is not legally sufficient to make goods already sold compliant.

What happens if you violate this?

Violations of the GPSR and ProdSG requirements can be fined up to €100,000. Beyond the fine, Section 29 ProdSG contains its own criminal offense, meaning particularly serious violations can also be prosecuted under criminal law. Besides the financial risk, missing or incomplete documentation can, in a serious case, also lead to sales stops or recalls, because without a risk analysis and technical documentation there is no solid basis for corrective action.

Frequently asked questions

Does the GPSR also apply to tiny quantities or handmade products?

Yes. There is no minimum threshold, as was sometimes assumed in the past; handmade products and tiny quantities are covered too. Anyone who assumes they are automatically exempt as a micro-seller is underestimating a real risk of fines.

What applies when importing from third countries?

When importing from non-EU countries, an economic operator based in the EU must take on the responsible-person role for the product. Without such a responsible person in the EU, the product cannot be placed on the market in a legally compliant way.

Which legal basis is relevant?

The relevant rules are the EU Regulation (EU) 2023/988 (GPSR) as well as the German ProdSG, which has applied in its new version since February 19, 2026. Both sets of rules interlock and apply in parallel.

Must warning notices also be provided online?

Yes, contact and warning notices must be provided both on the product itself and online, for example in the online shop or on the marketplace listing. A warning notice only on the packaging is therefore no longer sufficient if the product is also advertised or sold digitally.

What is the worst-case consequence?

Besides fines of up to €100,000, Section 29 ProdSG provides for its own criminal offense for particularly serious violations. How strictly an individual case is assessed depends, among other things, on whether the missing documentation was intentional or due to a lack of awareness.

Source: Regulation (EU) 2023/988 · ProdSG. This article provides general information and does not replace legal advice for individual cases. As of: July 2026.