New GPSR rules effect on preorder products

[Renee_14]

Hi everyone,

I was hoping someone could help me with a question regarding the new GPSR guidelines for the EU that come into effect on December 13th, 2024. I'm based in Australia and own a book box that is preorder based. I have some customers in the EU who have preordered their boxes from me within the last couple of months (prior to Dec 13th) and the items won't be shipped out to my EU customers until early 2025. Will this be an issue? Also, do i need to prove that their order were placed prior to Dec 13th when the gpsr rules came into effect? If so, how do i prove this?

Any answers are much appreciated as it's been difficult finding any answers on the subject. Thanks!

[Jo_EarlyBird · Accepted solution]

Hi @Renee_14, Josiah here. 👋🏻

We run an Aussie-founded pre-order app Early Bird and have been getting inquiries around this recently too.

TLDR, based on what we know so far:

From Dec 13th onwards, you'll need to provide detailed product safety info and contact details when selling to customers in Europe. For pre-orders, this will include setting super clear expectations for customers on the product and the whole pre-order process.

The confusing part for many merchants is there's not a lot of specificity on how much more details they need to provide. (Especially around product safety.)

-----

I know you're selling a book box, not electronics, but to comply with GSPR you need to clearly explain:

• Proof of product safety standards (More on this below)
• How to use the product safely
• Any potential risks
• Who can (or can't) use the product
• Any special instructions for use

And then for pre-orders, if you haven't included this info yet, you must list:

• Full details about the product (even if it's not produced yet)
• Expected delivery date
• What happens if the product is delayed

(Our app helps you prominently display the ETA throughout the purchase journey, and helps you one-click bulk send pre-order delayed emails.)

As for the contact info, you need to have:

• A way for customers in Europe to contact you
• Someone who can answer about the product safety questions

-----

Elaborating on the Proof of product safety standards - in your case it should be relatively straightforward.

See if your manufacturer can provide some docs on safety compliance, e.g.:

• Books are printed on non-toxic paper
• Approved printing inks
• No small parts in the books that could be hazardous to children 

(Surely publishers would already meet these standards by default?!)

Maybe if you want to be 110% certain, include a QR code linking to a simple statement or safety compliance certificate that the book meets EU safety standards for printed materials. For your orders that were placed before Dec 13th as well. (This is my suggestion, not legal advice.)

If you have a website dedicated for EU, then you should add the product safety info to each product listing.

I'm not sure what's the best approach yet if you only have one website selling worldwide.

Maybe add the safety info as an accordion (drop down) on your product page to minimise the visual impact?

-----

Hope this reassures and helps you, even if it's not super clear yet! Might be worth checking out what Amazon's EU sellers are doing - apparently the platform has been implementing compliance checkboxes and safety information sections in their product listings.

Cheers,
Jo

[Renee_14]

Hi Jo,

Thanks so much for your detailed response, i really appreciate it! It's so difficult to find specific answers on these new rules.

I have stopped selling my products to the EU as of December 13th. But for the 15 or so book box preorders that i currently have from EU customers (which were purchased before Dec 13th), would i still have to include the product safety information you shared:

• Proof of product safety standards (More on this below)
• How to use the product safely
• Any potential risks
• Who can (or can't) use the product
• Any special instructions for use
  
  And if so, where exactly do i include this information? On the shipping label?
  
  I will definitely look into your app, it sounds great!
  
  Thanks so much,
  Renee

[Jo_EarlyBird]

Glad we're able to help @Renee_14, and yeah, it's pretty frustrating on the limited info there is out there.

I'd recommend you do so so the preorders purchased before Dec 13th, as you're shipping AFTER the GPSR policy has come into effect.

• The shipping label is too small to include the detailed info, I wouldn't recommend there.
• I'd print all the detailed info out on an A4 paper like an info card. Include it as a packaging insert (not within the book box itself).
• Or use a document enclosed pouch - you know the type where they're designed to attach to the outside of a box for shipping? (Taped to the outside of the package, preferably near the shipping label if there is room.)
• This way you're displaying the info to both the EU Customs AND your EU customers.
• Include General safety info, Manufacturer info, Importer info, the Responsible point of contact in EU.

At the end of the day, the approach we recommend to our merchant is "overprepare the info" (annoying I know... but better be safe than get penalised)!

[Renee_14]

Hi Jo,

Yep this all makes sense, i will definitely include all of the necessary details from here on out. Thank you so much for your help, i really appreciate it!

[Jo_EarlyBird]

We found an official Q&A PDF put together by the European Commission today. It's not comprehensive but has additional questions we haven't come across until now. Thought I'd link you to it!

And this is the link to the full regulation for your reference.

[byteriver]

Here you can find a PDF Step-by-step Guide: How to implement Content alongside the new GPSR with Metafields in Shopify free of charge. The PDF is free.

[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]

Hi Renee,

The new EU General Product Safety Regulation (GPSR) applies to products placed on the EU market from December 13, 2024, onward. Since your book boxes will be shipped in early 2025, they will likely fall under the new GPSR requirements, even if the orders were placed before the regulation took effect.

To determine compliance, the key factor is whether the product is considered “placed on the market” before or after December 13, 2024. According to EU guidance, a product is placed on the market when it is made available for the first time in the EU—meaning when it is shipped or otherwise enters the EU market, not when the order was placed.

If your book boxes are not shipped until 2025, they will likely need to comply with GPSR, including requirements for safety documentation, traceability, and importer responsibilities. If you need assistance with compliance, EaseCert (https://easecert.com/) provides regulatory consulting and certification services for EU product safety requirements, including GPSR compliance.

Feel free to reach out if you need more details. Hope this helps!

Best,

Chris

[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