How to be GPSR compliant and locate a "responsible person" in the EU?

[SquishSquash]

Hi all!

I'm sure this has been asked a million times over, but I've yet to see anyone really find any realistically sustainable/reliable solutions.

What on Earth is going on with the EU's recently updated GPSR, and how are small businesses expected to comply?

Is there any word from Shopify concerning compliance? I was hoping there would be something said, and that Shopify may act as the "responsible person" for countries outside of the EU, but it's seemingly been crickets.

For reference, we're a very small US based company that produces handmade adult toys. We have a not-insignificant EU customer base, and this has left us essentially unable to ship to the EU. Or rather, I've cut off shipping to the EU until I can get this figured out.

I've been shipping internationally with very little issue for about 8 years now across various platforms, and have never dealt with anything beyond basic customs forms before, and I'm honestly not sure which way to turn with these updates. Everywhere I look there's different information.

I've seen an app on the Shopify App Store that will supposedly assist with GPSR compliance (hopefully the new documentation that needs to be affixed to packages) but it's only got twenty-some reviews, and I don't think the app helps you with the "responsible person" within the EU portion.

There seem to be a lot of sketchy, predatory services popping up that look to be preying on small businesses which are freaking out about the changes. I'd prefer to stick with something reputable, but again, I'm having a hard time even discerning what I need to do to be compliant.

Does anyone have any insight into the what's and how's of how to comply, specifically as a small, artisanal business? Or any reputable services that can assist?

[Agreeableagony]

Not to mention they are doubling down with punishing small businesses with the new PPWR:

https://www.exxosforum.co.uk/articles/packaginglaws.html

Unless they come up with some unified portal before august I think we are just going to have to stop shipping to EU

[SquishSquash]

This may be similar to what Germany did a while back, which caused us to cease shipping there.
It ended up being more of a guideline in our experience as when we resumed shipping to Germany we never encountered any issues.

But with all these new regulations that we're being expected to follow, and the lack of transparency on actual real-world implementation, I'm really not sure what to go by.

I may try out one of these GPSR services on some trial orders and see how it goes, though I'm highly suspicious of them. 

[Agreeableagony]

The GPSR services are all somewhat pricey and no one has been able to explain  how I am expected to put serial numbers on things like pieces of rope that dont have any packaging.

I love that the GPSR  effectively requires us to add packaging to products to be able to label them with serial/batch numbers and safety info physically, while the PPWR wants us to reduce packaging footprint.    

They cant make up their minds on what they actually want to accomplish here.
That or they specifically dont actually want as  much free trade as is going on and are hoping this makes more in country only business happen. 

It doesnt hurt big businesses much. Just small ones

[EaseCert]

You would typically be considered the economic operator under GPSR, which means you’re responsible for ensuring compliance.

Here’s what that means for you:

🔹 Responsible Person (RP) – If you’re selling into the EU/NI, you’ll need an EU-based RP to handle compliance documentation, report safety issues, and liaise with authorities. This can be a third-party compliance service, a distributor, or a fulfillment partner that offers this service.

🔹 Supplier Documentation – You don’t necessarily need to provide supplier details in listings, but you must ensure that all components meet EU safety standards. If suppliers provide declarations of conformity, safety test reports, or material composition details (e.g., nickel content in metals), keep these on file.

🔹 Labelling & Documentation – The product itself or packaging must include your name/address (or that of your RP), along with any relevant safety warnings or compliance markings.

It’s definitely a lot, and unfortunately, compliance costs hit small sellers hardest. If you’re looking for a service to help navigate this, EaseCert.com specializes in GPSR compliance, documentation, and EU RP services.

Let me know if you need more details—you’re not alone in this! 💡

[EaseCert]

Hey! These are great questions, and you’re definitely not alone in trying to figure out the details of GPSR. Here’s what I can share based on current guidance:

1️⃣ Product Testing – Whether you need to conduct your own testing depends on the final product and its intended use. If you’re using pre-tested materials (like inks with MSDS), you may not need additional testing, but you should still ensure that the final product meets general safety requirements. For example, if your prints include coatings or finishes that could pose a risk (e.g., flammability, skin contact issues), additional testing might be necessary. More details on compliance requirements are available at EaseCert.com.

2️⃣ Warnings – If there’s no specific hazard associated with your product when used as intended, a general safety statement should suffice. The key is to consider any foreseeable misuse—so while “don’t get a paper cut” might be excessive, something like “Not suitable for children under 3 due to small parts” (if applicable) would be more relevant.

3️⃣ Packaging & Labelling – The responsible economic operator’s name and address must be included, but it doesn’t necessarily have to be on the outer packaging. It can be on the product itself, the accompanying documentation, or the packaging—whichever is most practical. For compliance details, you can check EaseCert.com for guidance on labeling and documentation.

It’s a lot to navigate, but hope that helps! 🚀

[EaseCert]

PS: The main challenge is that GPSR introduces stricter requirements, including the need for an EU-based “responsible person” (RP) for any consumer product sold in the EU, along with enhanced documentation, traceability, and safety requirements.

Since Shopify hasn’t announced any plans to act as the responsible person, businesses outside the EU must appoint one themselves. This must be an entity based in the EU that can ensure compliance, hold technical documentation, and cooperate with authorities if needed.

You’re right to be cautious about predatory services—some companies are taking advantage of the uncertainty. If you’re looking for a reputable compliance partner, EaseCert (https://easecert.com/) provides legitimate GPSR compliance services, including responsible person representation, documentation support, and regulatory guidance for small businesses.

It’s good that you’ve paused EU shipping until you’re confident in your compliance approach. If you need specific guidance on the next steps, feel free to reach out.

[EaseCert]

FYI, here's the latest status:

The European Union has introduced the General Product Safety Regulation (GPSR), which replaces the previous General Product Safety Directive (GPSD). This regulation came into full effect on December 13, 2024, and applies to all consumer products placed on the EU market, including those imported from countries such as the United States, Canada, the UK, Switzerland, and Australia.

For importers and manufacturers selling goods in the EU, it is essential to understand the expanded obligations under the GPSR to ensure compliance and maintain market access.

Key Updates Under the GPSR

1. Expanded Scope and Definitions

• A manufacturer is defined as a company that produces or commissions the production of a product and markets it under its name or trademark.
• An importer is an entity established within the EU that places products from third countries onto the EU market.
• The GPSR broadens the definition of “safe products”, emphasizing that safety considerations must account for foreseeable misuse, evolving functionalities, and other threats.

2. New Risk Analysis and Technical Documentation Requirements

• Manufacturers / importers must conduct a comprehensive risk assessment and prepare technical documentation that demonstrates the product’s safety.
• Importers must retain copies of this technical documentation and ensure manufacturers have conducted proper risk assessments.
• Records must be kept for at least 10 years after a product is placed on the market.

3. Introduction of the “EU Responsible Person” Requirement

• Non-EU manufacturers must designate an EU-based Responsible Person who will act as a point of contact for compliance and product safety issues.
• This entity can be an authorized representative, importer, distributor, or fulfillment service provider.
• The Responsible Person is required to hold access to technical documentation and cooperate with EU regulators.
• An EU Authorised Representative can act as Responsible Person.

4. Stronger Product Traceability and Labeling Obligations

• All products must carry a serial number or equivalent identifier that is visible and legible.
• A manufacturer’s or importer's name, registered trade name, and a physical and electronic address must be clearly displayed on the product or its packaging.
• QR codes cannot replace required physical labeling.

5. Enhanced Market Surveillance and Online Marketplace Compliance

• Online marketplaces must verify that third-party sellers comply with EU safety regulations.
• Operators of an online marketplace in the EU Market, for example a Shopify store, are required by law to register their business with the Safety Gate Portal. Registration ensures compliance with EU regulations and facilitates communication with national market surveillance authorities.
• Importers and manufacturers distributing via e-commerce must ensure their products meet the same safety requirements as those sold in physical stores.
• National authorities will have increased powers to conduct market surveillance and enforce compliance, including product recalls and penalties.

Compliance Checklist for Importers and Manufacturers

To ensure a seamless transition into the new GPSR framework, businesses should take the following steps:

1. Register at the EU Safety Gate: This registration is mandated by GPSR to ensure better communication and compliance with safety requirements.
   
   
2. Appoint an EU-Based Responsible Person: If you are a manufacturer outside the EU, designate a responsible person who can store technical documentation and liaise with authorities. An EU Authorised Representativecan act as Responsible Person.
   
   
3. Ensure Full Product Traceability: Implement batch tracking and serial numbering systems to facilitate recall management and regulatory compliance.
   
   
4. Conduct a GPSR Risk Assessment: Ensure your products comply with EU safety regulations, addressing foreseeable risks and potential misuse.
   
   
5. Update Packaging and Labeling: Confirm that all required identification details (manufacturer / importer name, address, and contact information) are correctly displayed.
   
   
6. Prepare for Enhanced Market Surveillance: Maintain 10-year records of compliance documentation and be ready to provide them to regulators upon request.
   
   
7. Adapt for E-Commerce Compliance: If selling via Amazon, eBay, or other platforms, ensure that all listings meet EU safety regulations.
   
   
8. Monitor EU Regulatory Updates: Keep track of additional guidance from the European Commission and adjust compliance strategies accordingly.

Penalties for Non-Compliance

Failure to comply with the GPSR can result in:

• Product bans or recalls
• Fines and legal action
• Loss of market access in the EU
• Reputational damage for non-compliant brands

Final Thoughts

The GPSR represents a significant shift in EU product safety laws, particularly for importers and manufacturers from third countries. By proactively updating compliance strategies, businesses can avoid costly penalties and ensure a smooth transition into the new regulatory landscape.

For more insights or assistance in navigating the GPSR, stay updated through industry portals and the European Commission’s official channels.

Learn More About GPSR:

• EU Product Safety and GPSR Overview
• General Product Safety Regulation (2023) – EU Summary
• EU Safety Gate – RAPEX Alerts for Dangerous Products