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GPSR Compliance Checklist (2026) + Free Download

By SafeCart · Updated

Use this GPSR compliance checklist to audit one product and its EU online offers, assign each gap to an owner, and keep the evidence together. Start with scope and your supply-chain role, then check the listing, product information and process for handling safety issues.

Before you start: which rules apply?

The General Product Safety Regulation, Regulation (EU) 2023/988, has applied since 13 December 2024. It covers consumer products within its scope, including products likely to be used by consumers under reasonably foreseeable conditions. Exclusions and product-specific rules matter: food, medicines and antiques, for example, are excluded. Products covered by EU harmonisation legislation require a separate scope assessment under Article 2.

This is a working checklist for EU online sellers. It is not an exhaustive checklist for every product category. Read what GPSR means for sellers if you need the introduction or a reference to the regulation itself.

Older stock needs a date check. Article 51 protects the continued availability of products that complied with the former General Product Safety Directive and were placed on the market before 13 December 2024. Record when the particular goods were first placed on the market; a model's launch date alone does not establish this.

Sources: GPSR, Articles 2–4, 51 and 52. For Northern Ireland, use the UK OPSS guidance, including its transitional arrangements. Great Britain has a separate framework.

The 12-task GPSR compliance checklist

Duplicate the workbook for each product or group with the same safety documentation. Record the SKU, model, batch where relevant, destination markets and listing URLs. Set a task to Done only after adding evidence. If it does not apply, record the reason. The owner is the person doing the work inside your business; assigning an owner does not change the legal obligations of an economic operator.

TaskCheckEvidence to keep
1. Scope and roleIdentify the product rules, destination markets and whether you are manufacturer, importer or distributor.Scope decision, supplier chain and applicable legislation.
2. Safety documentationObtain or prepare the risk assessment and technical documentation required for your role.Document version, product identification and access contact.
3. Responsible economic operatorIdentify the operator responsible for the product in the EU and verify the arrangement.Name, postal and electronic address, role and any written mandate.
4. Product and packagingCheck identification, contact information, instructions and warnings on the physical goods.Label photos and current instruction files.
5. Online offerCheck the four Article 19 information groups on each product offer.Listing URLs and dated screenshots.
6. LanguagesCheck required safety information for each destination market.Approved language versions and the markets they cover.
7. Traceability and retentionLink suppliers, products and business customers; assign the correct retention periods.Supply-chain records and a document retention schedule.
8. Complaints and safety signalsGive safety complaints an owner and review relevant alerts and supplier notices.Complaint process, review log and escalation contact.
9. Dangerous products and accidentsEstablish who stops sales, contacts the manufacturer and makes required notifications.Escalation procedure and Safety Business Gateway responsibilities.
10. Recall readinessPrepare to identify affected buyers, communicate clearly and deliver remedies.Recall procedure, contact method and notice template.
11. Published channel checkConfirm each marketplace or storefront actually displays the submitted information.Public-page checks on desktop and mobile.
12. Review and changesRecheck after a supplier, product, destination, warning or safety-information change.Review date, change log and unresolved actions.

Tasks 11–12 are practical workflow checks. They do not impose a new statutory review interval. The details below explain the legal requirements behind the other tasks.

1. Identify your role and safety evidence

A manufacturer includes a business that has a product made and markets it under its own name or trademark. Importing goods from outside the EU can make you an importer; reselling goods already on the market can make you a distributor. Relabelling or substantially modifying a product can change your responsibilities.

For products to which these provisions apply, manufacturers must carry out an internal risk analysis and prepare technical documentation before placing a product on the market. Importers and distributors have different verification and cooperation duties. A supplier invoice, checklist tick or marketplace approval does not establish that a product is safe.

Record the product's actual risks, the applicable standards or other assessment basis, relevant tests, and who can provide the current documentation. Do not substitute a generic template for a product-specific assessment.

Source: GPSR, Articles 3, 5–9, 11–13.

2. Verify the responsible person and physical information

For products covered by Article 16, an economic operator established in the EU must be responsible for the specified compliance tasks. Depending on the supply chain, this can be the EU manufacturer, importer, an authorised representative with a written mandate, or a fulfilment service provider where the conditions are met. You do not automatically need to buy a separate representative service.

Check the responsible operator's name and contact details and ensure the required information accompanies the product as Article 16 specifies. Also check the manufacturer and importer information, product identifiers, instructions and warnings required for the product. Online information does not replace the applicable physical requirements.

Sources: GPSR, Articles 9, 11 and 16 and Regulation (EU) 2019/1020, Article 4.

3. Check all four Article 19 listing fields

The online offer must clearly and visibly provide:

  1. Manufacturer: name, registered trade name or trademark, plus postal and electronic contact address.
  2. Responsible person when the manufacturer is outside the EU: name, postal and electronic address of the relevant responsible person.
  3. Product identification: a picture, product type and other product identifier.
  4. Applicable warnings and safety information: the information required on the product, packaging or accompanying document, in a language consumers can easily understand as determined by the destination Member State.

Check the public offer, including each relevant variant. A completed field in a seller dashboard is useful only if the required information reaches the offer. Do not rely on a generic store contact page to identify the manufacturer of an individual product.

Source: GPSR, Article 19.

Worked example: checking an online offer

Fictional example: a retailer imports an adult-use fabric storage basket, model BSK-24, from a manufacturer outside the EU. The retailer is the EU importer and relevant responsible operator. Every name, address and identifier below is invented for illustration; the example is not evidence that any real product is safe.

FieldIncomplete draftInformation to verify and publish
Manufacturer“Made overseas”Example Basket Manufacturing Ltd; [full non-EU postal address]; [email protected]. Replace the placeholder with verified details.
EU responsible personRetailer's logo onlyExample Importer Ltd; [full EU postal address]; [email protected]. Confirm the legal role and replace the placeholder.
Identification“Storage basket”Fabric storage basket, model BSK-24, and a clear picture of the actual product. Verify the identifier against the goods.
Safety informationBlank, or generic marketing textPublish the applicable instructions and warnings identified for this product, using the required destination-market languages. Do not invent warnings to fill a field.

The reviewer then compares the offer with the label and documentation, saves a dated screenshot, records discrepancies and assigns corrections. This example remains incomplete until the placeholders, actual product picture and product-specific safety information have been supplied.

4. Use the correct retention periods

Avoid one blanket “keep everything for 10 years” rule. The GPSR distinguishes records, roles and starting dates:

  • Manufacturer technical documentation: Article 9(3) specifies 10 years after the product is placed on the market. Article 11(6) requires importers to retain the copy of technical documentation for 10 years after they place the product on the market.
  • Risk and corrective-measure information requested by authorities: Article 15(2) and (4) specify availability for 10 years after the operator supplies or is supplied with the product, as applicable.
  • Supply-chain identification: Article 15(3) and (5) specify six years after supply or receipt, as applicable. This includes identifying relevant suppliers and business customers.

Check sector-specific rules and data-protection requirements when setting the wider retention schedule. These periods are not an instruction to retain all customer personal data indefinitely.

Source: GPSR, Articles 9, 11 and 15.

5. Prepare for safety signals, accidents and recalls

Give complaints and supplier safety notices a clear route to someone who can act. Review relevant Safety Gate alerts and compare the identifiers and affected batches with your catalogue. The absence of an alert does not prove safety. GPSR does not set a universal “weekly check” rule or a catalogue-size threshold that makes monitoring sufficient.

When a product may be dangerous, follow the duties for your role to stop further supply, investigate, cooperate and take corrective measures, including withdrawal or recall where appropriate. The notification duties for dangerous products and reportable accidents are distinct. Article 20 requires the manufacturer to notify qualifying product accidents through the Safety Business Gateway without undue delay, with duties for other operators to inform and cooperate as specified there.

Prepare a way to identify affected consumers and contact them directly where possible. A recall plan should cover the notice, affected product identifiers, risk, required action, contact details and remedy. Article 37 generally requires a choice of at least two remedies from repair, replacement and refund, subject to its exceptions. Use the EU product recall notice guide and template to prepare the communication.

Sources: GPSR, Articles 9–12, 20 and 35–37. For the operational workflow, read how Safety Gate recalls reach businesses.

Finish the audit and keep it current

For each unresolved task, record an owner, the evidence needed and a review date. Revisit the assessment when the product, supplier, market or safety information changes. Keep previous versions so a future reviewer can see what changed and why.

SafeCart can support catalogue monitoring and compliance-data workflows. Compare the available features on the pricing page after you have identified the gaps you need to manage.

Frequently asked questions

Is there an official GPSR certificate?

GPSR does not establish a general certificate or approval mark. Completing this checklist records your work; it does not certify a product. Determine the safety, documentation and conformity assessment requirements that apply to the particular product.

GPSR, Articles 5–9

Does GPSR apply to B2B sales?

A B2B transaction does not by itself exclude a product. GPSR covers products intended for consumers or likely to be used by consumers under reasonably foreseeable conditions, subject to its scope and exclusions. Check the product and its use, as well as your role in the supply chain.

GPSR, Articles 2–3

What is the penalty for GPSR non-compliance?

Article 44 leaves penalties to Member States, so there is no single EU-wide fine. Authorities can also require corrective action. Check the applicable national rules and the authority responsible for your product and market.

GPSR, Articles 23 and 44

Does GPSR apply if I sell only in the UK?

Distinguish Great Britain from Northern Ireland. EU GPSR applies in Northern Ireland from 13 December 2024, with transitional arrangements for qualifying older products. Great Britain has its own General Product Safety Regulations 2005. A seller based in Great Britain must also consider EU GPSR when supplying the EU or Northern Ireland.

UK OPSS guidance, sections 1, 2 and 7

Does CE marking replace GPSR obligations?

CE marking and GPSR have different scopes. For products covered by EU harmonisation legislation, Article 2 limits which GPSR provisions apply and addresses risks not covered by the specific legislation. Map both sets of rules for your product; do not assume that every GPSR duty applies unchanged or that CE marking removes all GPSR obligations.

GPSR, Article 2