FLEX. Fulfillment
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This guide covers GPSR — the EU General Product Safety Regulation — for non-EU brands selling on Amazon Europe and other EU channels. It explains what GPSR requires, who the responsible person is and how to appoint one, what labelling and documentation your products need, how Amazon enforces compliance, and how your EU prep centre fits into the compliance chain. It is written for sellers in the UK, US, Hong Kong and Australia who are new to EU product safety law.
What Is GPSR
GPSR is the EU's overarching product safety law, in force from 13 December 2024. It replaces the 2001 General Product Safety Directive and applies to virtually all consumer products placed on the EU market — including products sold through online marketplaces like Amazon. Its core principle: every consumer product on the EU market must be safe, and there must be an identifiable EU-based entity accountable for that safety. For non-EU sellers, GPSR is significant because it creates explicit obligations for overseas brands — not just for EU manufacturers — and because Amazon has integrated GPSR compliance checks directly into its listing and inbound processes.
GPSR covers all consumer products unless a more specific EU regulation already applies to that product category — medical devices, food, pharmaceuticals, and aviation products have their own frameworks. In practice, the vast majority of products sold on Amazon EU fall under GPSR: electronics, toys, apparel, cosmetics, sporting goods, home goods, tools, garden products, baby products, and accessories of all kinds. If your product is sold to consumers and is not explicitly excluded, assume GPSR applies. GPSR also covers second-hand goods and refurbished products sold online.
Yes — explicitly. Amazon has required GPSR compliance for all products listed on Amazon EU since December 2024 and has been sending enforcement notifications to sellers with non-compliant listings. Missing or incorrect responsible person information results in listing suppression. Amazon checks GPSR compliance status per ASIN through Seller Central and flags non-compliant products. The enforcement is not theoretical — sellers who have not appointed a responsible person and updated their listings have had ASINs removed. The EU market entry checklist covers GPSR as part of the full pre-launch compliance sequence.
CE marking is a specific conformity marking required for certain regulated product categories: low voltage electrical products, toys, personal protective equipment, machinery, radio equipment and others. It demonstrates conformity with the specific EU directive that applies to that category. GPSR is broader: it applies to all consumer products regardless of whether they carry CE marking. CE marking satisfies the GPSR safety requirement for the specific aspects it covers — but GPSR also requires responsible person appointment, traceability information and labelling that CE marking alone does not address. Think of it this way: CE-marked products still need GPSR compliance; non-CE-marked products need GPSR compliance but not CE marking.
The Responsible Person
The responsible person (RP) is an EU-established individual or company named on the product who accepts legal responsibility for product safety compliance. The RP must be: established in the EU (with a genuine EU address, not a PO box), reachable by EU market surveillance authorities, able to provide product documentation within 3 business days of a request, and capable of initiating corrective actions or recalls if a safety issue arises. For non-EU brands, the RP is almost always a third-party EU entity contracted to act in that capacity — a compliance service provider, an importer, or in some cases an EU-based distributor.
Three types of entity can act as responsible person for a non-EU brand: (1) an EU-based importer of your goods, if they are the first to place the goods on the EU market; (2) an authorised representative — a third-party EU company you contract specifically to act as RP, which is the most common arrangement for direct-to-consumer non-EU sellers; (3) an EU-based subsidiary of your own company, if you have one. Amazon itself does not act as responsible person. Your freight forwarder, customs broker, or 3PL does not automatically become the RP by receiving your goods — the appointment must be explicit, documented, and agreed by the entity taking on the role.
The responsible person must: hold the product's technical documentation (safety assessments, test reports, declarations of conformity) for 10 years from the date the product was placed on the market; cooperate with EU market surveillance authorities on request, providing documentation within 3 business days; take corrective action — including product recall — if a safety issue is identified; maintain records of complaints and corrective actions; and ensure the product's labelling information remains accurate and up to date. The RP assumes real legal liability, not just an administrative role. They can face personal liability for product safety failures if they have not performed adequate oversight.
No. FLEX. is a logistics and prep service provider, not a product safety compliance entity. FLEX. can ensure your products are physically prepared for EU compliance at inbound — verifying that responsible person labelling is present, applying label overlays where needed, and flagging products that arrive without required information. But the legal appointment of a responsible person must be made separately with a specialist compliance or legal services provider. FLEX. recommends engaging a dedicated GPSR responsible person service before your first EU shipment. Numerous EU-based compliance providers offer this service for annual fees ranging from a few hundred to a few thousand euros depending on product category and volume.
Labelling Requirements
GPSR requires the following information to be visible on the product itself or its packaging: the product name or type, the manufacturer's name and registered address, the name and EU address of the responsible person, a batch or lot number or serial number for traceability, the country of origin, and any safety warnings or instructions for use required for that product type. For products sold online, the responsible person's details must also appear on the Amazon product listing — in the product description or a designated compliance field. Labels must be durable, legible, and in the language of the country where the product is sold.
Yes — safety warnings and instructions for use must be in the official language of the EU member state where the product is sold. For sellers using Pan-EU FBA, this means your packaging must include safety information in German, French, Italian, Spanish, Polish and any other languages covering your active Amazon marketplaces. The most practical approach for multi-market sellers is a multi-language label or insert that covers all relevant languages. For products where space is limited, a separate multilingual instruction sheet is acceptable. Label overlays applied at the prep centre can add market-specific language content if your original packaging does not include it.
Yes — this is one of the most common tasks at FLEX. for non-EU sellers. Products arrive from the manufacturer without EU-compliant responsible person details, without local language safety warnings, or with incorrect batch information. FLEX. applies sticker overlays or replacement labels before forwarding to Amazon FCs — adding the required GPSR information without needing to return goods to the manufacturer or repackage entirely. This requires you to provide: pre-approved label artwork with the correct responsible person details, the batch or lot number for each SKU, and confirmation of which products require which language overlays. Kitting and assembly in Germany and Poland covers the full range of product preparation services available at FLEX.
Documentation
GPSR requires maintaining: a Declaration of Conformity (DoC) confirming the product meets applicable EU safety requirements; a technical file containing risk assessments, test reports, design and manufacturing specifications, and a list of standards applied; instructions for use where relevant; and a record of complaints received and corrective actions taken. Documentation must be held for 10 years from when the product was last placed on the EU market and must be made available to market surveillance authorities within 3 business days of a request. The documentation does not need to be filed proactively — it is held by the responsible person and produced when required.
GPSR does not specify mandatory tests but requires products to be demonstrably safe. In practice, third-party test reports from accredited laboratories are the primary evidence used to demonstrate safety compliance — particularly for products in categories with established testing standards (EN safety standards for electrical goods, EN 71 for toys, etc.). For products in unregulated categories, a documented risk assessment prepared by or on behalf of the responsible person may suffice. The risk of not having test reports: if a market surveillance authority investigates and finds no documented evidence of safety assessment, the product is presumed non-compliant. Testing costs vary from a few hundred to several thousand euros depending on product complexity.
Product Categories and Additional Requirements
Yes. Several product categories have their own EU directives or regulations that apply alongside or instead of specific GPSR provisions: electronics and electrical products must comply with the Low Voltage Directive (LVD) and EMC Directive and carry CE marking; toys must comply with the Toy Safety Directive (EN 71) and carry CE marking; personal protective equipment has its own PPE Regulation; cosmetics are regulated separately under the EU Cosmetics Regulation (not GPSR); chemicals and materials in products are subject to REACH restrictions. For Amazon sellers: certain categories trigger additional compliance documentation requirements at listing level, and inbound shipments in flagged categories may be held at the FC pending documentation review.
Enforcement
Consequences operate at two levels. Amazon level: immediate listing suppression for affected ASINs, potential account suspension if non-compliance is systemic. EU market surveillance level: authorities can ban sale of the product, order a product recall at the seller's expense, impose fines (proposed maximum: 4% of EU annual turnover or €10 million, whichever is higher), and pursue criminal liability against the responsible person for serious safety failures. Market surveillance authorities in Germany, France and the Netherlands are the most active in the EU — and they conduct regular test purchases on Amazon EU as part of their monitoring programmes.
Yes. Since December 2024 Amazon has been rejecting FBA inbound shipments where GPSR responsible person information is missing from the product or listing. Seller Central shows a GPSR compliance status per ASIN — non-compliant ASINs are flagged and may be suppressed. Amazon sends automated compliance notifications to seller accounts with outstanding GPSR issues. The enforcement has accelerated since mid-2025: sellers who treated the December 2024 deadline as theoretical have been receiving listing removal notices. If your Seller Central account has unresolved GPSR notifications, addressing them before your next inbound shipment is the immediate priority.
How Your Prep Centre Helps
A prep centre acts as a physical compliance checkpoint between your manufacturer and Amazon. When goods arrive at FLEX., the inbound inspection can identify: missing responsible person information on packaging, absent or incorrect language labels, missing batch or lot numbers, and damaged or non-compliant packaging. Issues identified at the prep centre can be corrected before goods reach Amazon — avoiding the FC rejection, listing suppression, or market surveillance action that non-compliant goods reaching consumers would generate. The prep centre does not replace the responsible person or the technical documentation — but it provides the last practical opportunity to correct physical labelling issues before the product enters the EU market. FBA prep centre in Germany handles inbound compliance checks as part of the standard receiving workflow.
Before your shipment arrives, provide FLEX. with: pre-approved label artwork containing the responsible person's name and EU address, the batch or lot number for each SKU in the shipment, a declaration of conformity for any products in regulated categories (electrical, toys, PPE), and confirmation of which products require language overlay stickers and in which languages. If your products require full label replacement rather than overlay, send the replacement labels pre-printed. The more complete your documentation at the time of booking, the faster and more accurately the prep centre can process your inbound without holds. Amazon FBA prep in France and Germany follow the same compliance documentation process.
Timeline and Upcoming Requirements
GPSR was published in the EU Official Journal in July 2023 and applied from 13 December 2024. There were no transitional arrangements for existing stock — compliance was required from the application date regardless of when goods were manufactured. Products already in FBA on 13 December 2024 that did not meet GPSR requirements were immediately non-compliant, and Amazon began enforcement notifications from that date. If you have pre-December 2024 stock still in FBA without compliant responsible person labelling, it is non-compliant and should be addressed through a removal order and relabelling process.
The Digital Product Passport (DPP) is a product data carrier — typically a QR code or RFID tag on the product — linking to a machine-readable record of the product's key data: materials, manufacturer, responsible person, safety information, and sustainability characteristics. DPP is being phased in under the EU's Ecodesign for Sustainable Products Regulation (ESPR) rather than GPSR directly, but the two frameworks share the same traceability objective. DPP for batteries is live from 2026 under the Battery Regulation. For textiles, electronics, and other consumer categories, mandatory DPP is proposed from 2027 to 2030 depending on category. It does not affect most Amazon sellers today — but brands in battery-containing product categories should be preparing their data infrastructure now.
Related Services
GPSR compliance support across the FLEX. network:
- Kitting and assembly in Germany and Poland — label overlays, language stickers and packaging adjustments at prep stage
- FBA prep centre in Germany — inbound inspection and GPSR labelling checks
- Amazon FBA prep in France — same GPSR prep workflow for Amazon.fr inbound
- FBA prep centre in Europe — full prep service overview across Germany and Poland
Located in the center of Europe, FLEX. Fulfillment provides FBA prep with GPSR labelling checks, language overlay application and inbound inspection for non-EU brands entering the EU market.
Get in touch for a free quote and assessment tailored to your GPSR compliance and FBA prep requirements.