Obligations for Manufacturers & Importers

The GPSR (EU Regulation 2023/988) places obligations on all economic operators who make consumer products available on the EU market. Depending on the role in the supply chain, different requirements apply.

Obligations for Manufacturers

Manufacturers bear primary responsibility for the safety of their products. They must:

• Conduct a safety assessment — An internal risk analysis must be carried out before placing a product on the market.
• Prepare technical documentation — This must be retained for at least 10 years.
• Ensure proper labelling — Product type, batch or serial number, and contact details must be affixed to the product or its packaging.
• Designate a responsible person — Name, postal address, and email address of a contact person based in the EU.
• Take corrective action — In the case of unsafe products, manufacturers must act immediately and notify the relevant authorities.

Obligations for Importers

Importers bring products from third countries into the EU market and assume particular responsibility:

• Verification duty — Importers must ensure the manufacturer has fulfilled their obligations (risk analysis, labelling, technical documentation).
• Own labelling — The importer's name and address must also appear on the product or packaging.
• Storage and transport conditions — Importers must ensure that product safety is not compromised during storage and transport.
• Reporting obligation — Importers must notify authorities if they become aware of safety defects.

Obligations for Online Retailers

Retailers — especially in e-commerce — must verify before selling:

• Are the required manufacturer details present?
• Are warnings available in the language of the target country?
• Has a responsible person in the EU been designated?

Additionally, online retailers must display manufacturer information on the product page — clearly visible and accessible before purchase.

What must appear on the product?

The following details are mandatory on the product or packaging:

Information	Required
Manufacturer name	Yes
Manufacturer postal address	Yes
Email address	Yes
Website / URL	Recommended
Product type / model designation	Yes
Batch or serial number	Yes
Responsible person in the EU	Yes (if manufacturer is outside the EU)
Warnings	Yes (product-dependent)

What happens in case of non-compliance?

Market surveillance authorities in EU member states can take the following action:

• Order products to be withdrawn from the market
• Issue product recalls
• Impose fines
• Block online listings