General Product Safety Regulation (GPSR) - What Every Small Manufacturer Needs to Know

Trust the European Union (EU) to once again at the forefront of regulation: The euro giant has established a new set of rules that will impact small manufacturers everywhere.

The General Product Safety Regulation (GPSR) is intended to ensure consumer safety and the overall integrity of the market. It is a key component of the EU’s product safety legal framework and will replace the current General Product Safety Directive and the Food Imitating Product Directive from 13 December 2024.

It addresses the challenges brought about by the surge of DTC sellers for online sales and marketplaces. This regulation also aims to enhance and improve the efficiency of dangerous product recalls.

So, if you are a small maker that sells online to customers in the EU, it’s crucial to understand and adapt to these new regulations to ensure you aren’t caught on the hop.

In this article, we’ll give you a simplified breakdown of what the GPSR entails along with some recommendations on software solutions that can help you achieve compliance.

What’s inside this article:

• What’s the purpose of the GPSR?
• Online Listing (or Offer) Requirements
• Appointing a European “Responsible Person” and what they do
• Product Traceability Requirements
• Testing Requirements
• Labelling Requirements
• Product Safety Recall Requirements
• Accident Reporting Requirements
• What Do Small Manufacturers Need to Do for GPSR Compliance?
• How Craftybase Can Help You Achieve GPSR Compliance, Fast
• GPSR FAQ

What’s the purpose of the GPSR?

The GPSR mandates that all products within the EU markets are safe. If your business makes products that are non-food related and you directly sell to EU customers via sales channels, then these regulations apply to you.

What products are covered under the GPSR?

The GPSR covers a variety of non-food related products: new, second-hand, repaired and reconditioned (with some caveats on the last two).

Some examples of the products covered include:

• Children’s products (such as high chairs, beds etc.)
• Household goods and cooking equipment
• Gardening Tools
• Furniture and soft furnishings
• Bicycles
• Candles
• Art and hobby materials

Products not covered by the EU GPSR are:

• Medical products for human or animal usage
• Food (this is covered under a completely different EU regulation)
• Feed for animals
• Living plants and animals

What are the GPSR requirements?

As is usual with EU legislation, there is a lot that is covered and much of it is very technical in nature. Lucky for you, we’ve tried to distil the requirements in a more easy to understand format. Let’s cover some of the main requirements now:

Online Listing Requirements

A big part of the new rules involve ensuring that any product that you sell in the EU via an online site much include a listing description (known as an “offer”) containing:

• The details of the manufacturer (if you make your products in-house then this will be your company);
• The details of responsible person in the EU (we’ll cover this one in a bit as it’s a little involved);
• Enough information to identify the product online: this covers the product picture, codes and SKUs
• Any warnings and safety information required, provided in the language of the country of sale.

This safety information should include (but is not limited to):

• CE marks
• toy safety warnings
• energy labels
• chemical hazard warnings
• any other warning or safety information that is affixed to the product or packaging, or included in an accompanying document.

How to update your Etsy listings for GPSR

The most important update you’ll need to make as an Etsy seller to achieve GPSR compliance on your listings is to update your product listings by Dec 13.

Ensure you have added the manufacturer’s name, address, and contact ##details to all of your product listings.

Also ensure that you include the EU Authorised Representative’s name (along with their address, and contact details) and any safety / care instructions required.

The above information has to be provided in the language where you are selling your products.

It’s also a good idea to use the downloadable files feature on Etsy listings to offer safety / care instructions and a summary of the information required - this is however optional.

Appointing a European “Responsible Person”

One of the key steps is to appointing a what is known in the EU lingo as a “Responsible Person”. This requirement is for EU based businesses, and also businesses selling to the EU.

If you are not based in the EU, it’s important to note that you cannot act as the responsible person for your products. If you intend to sell directly to EU consumers, you must find an authorised representative to act on your behalf.

What does a Responsible Person do?

The responsible person must perform certain key compliance tasks:

a. Regularly checking that the product complies with the technical documentation

b. Ensuring that the product comes with the required traceability information

d. Making sure that the correct records are maintained and stored

e. Ensuring that the product comes with the relevant instructions and safety information

f. Cooperating with market surveillance authorities

Who can be a “responsible person”?

The responsible person has to be operating from an EU state and can be one of the following:

1. An EU manufacturer that makes their own products and sells directly under their brand / trademark

2. An EU importer that imports products from outside countries into the EU

3. An EU authorised representative receives written instructions from the manufacturer to act on its behalf for certain tasks

4. An EU fulfilment service provider that offers at least two of the following services: Warehousing, Packaging, Addressing and/or Dispatching

Product Traceability Requirements

One of the big focus pieces of the GPSR sets stringent product traceability requirements, meaning businesses will need to ramp up their tracking capabilities for raw materials right through to sale.

This regulation will require you to start thinking about more comprehensive record-keeping of your product’s journey from production to sale (some suggestions on tracebility software are outlined later in this post).

In particular, Article 9 of the GPSR details the ensure their product’s traceability by providing “product identification elements”. This requires batch, lot numbers and/or serial numbers to be tracked through the production process.

Testing Requirements

When it comes to ensuring the safety and compliance of your EU bound products, testing is now not just an option, but a necessity.

Adherence to EU standards, such as REACH-substance testing, flammability tests, and more, gives you the assurance that your goods are safe and ready for the market and will make sure you are GPSR compliant.

The various types of testing available serve a range of purposes and will differ based on the products you make.

Some examples of testing are:

• Substance testing checks for harmful chemicals and heavy metals in a material, ensuring they fall within acceptable limits.
• Electrical testing covers a broad spectrum, from safety to energy efficiency to wireless communications. Physical or Mechanical
• Property Testing checks for potentially dangerous features, like sharp points and small parts, while
• Flammability testing serves to examine various elements of fire safety (this one is key for candle testing).

The good news is, accredited test laboratories are located all around the globe, not just within the EU region. Whether you’re a manufacturer stationed in the US, India, China, or elsewhere, you can access these crucial safety tests at local labs.

Labelling Requirements

The GPSR now requires manufacturers to provide clear labelling information on their products and packaging. They should also adhere to requirements regarding the placement of such information.

In particular, each product needs to carry a unique identifier - either a lot or batch number or other key identifier that can enable materials to be traced to the source. Warning and safety information should also be clearly displayed on the label.

Product Safety Recall Requirements

Should product recall become necessary, it’s now essential to issue a recall notice using a standardised template that includes:

1. The prominent heading ‘Product Safety Recall’
2. Detailed description of the recalled item with images, name, brand, product ID numbers, and details of sale Clear description of the potential risk associated with the product, avoiding misleading terms such as ‘voluntary’ or ‘in rare situations’
3. A Step-by-step guide for customers, including a request to stop using the product
4. Direct reference to the recourse options

The template highlights the legal mandates in red text and provides additional spaces for voluntary inclusion of:

• A customized apology
• Links to social media/web pages
• QR code or other strategies directing to the product recall page.

Accident Reporting Requirements

Businesses will now be required to report accidents to authorities. This will reinforce market surveillance rules and ensure that unsafe products do not reach or remain in the hands of consumers.

The stringency of reporting has also been turned up a notch: Manufacturers now have to notify Safety Gate if there’s an accident caused by a product.

But when do these reporting obligations kick in? According to the official publication, this requires scenarios where the product use has led to personal harm – be it someone’s death, serious health effects, injuries, other bodily damages, illness, or even chronic health issues.

Promptness is vital with the new requirement. The moment you, the manufacturer, become aware of the incident, it should be reported “without undue delay” according to the new General Product Safety Regulations.

What Do Small Manufacturers Need to Do for GPSR Compliance?

As a small manufacturer, it’s essential to familiarize yourself with the GPSR and understand how it will affect your business. Here are some immediate steps you can take:

1. Ensure you read the GPSR in it’s entirety to understand the regulations and what is required for your business. As this is a new regulation, it’s likely to evolve and update so ensure you keep up to date on any changes (be prepared for a lot of jargon and legalese!)

2. Update all of your online listings to ensure that they reflect the regulations (and ensure you are abiding by the language requirement also)

3. Review your production processes: Ensure that they comply with the safety standards outlined in the GPSR.

4. Ensure all of your products have adequate testing and documentation

5. Implement systems or software that can track and manage product traceability.

6. Establish a solid recall plan that allows you have a clear plan in place for recalling products from the market.

7. Educate your employees: Make sure your team is aware of the new regulations and how to adhere to them.

How Craftybase Can Help You Achieve GPSR Compliance

Craftybase is a comprehensive inventory management software designed specifically for small manufactures that sell across sales channels online. Offering a range of compliance and traceability features specifically designed to support small manufacturers in achieving GPSR compliance, easily and quickly.

With Craftybase, you can streamline your production processes, improve record-keeping, and ensure product traceability all in one cost effective package.

Here’s exactly how Craftybase will ensure you meet your GPSR requirements:

1. Production Process Management

Craftybase allows you to document and manage your production processes, ensuring they align with the safety standards outlined in the GPSR. By maintaining clear and organized production records within Craftybase, you can easily demonstrate compliance during inspections and audits.

2. Product Traceability

Craftybase’s advanced lot and batch tracking capabilities enable you to establish and maintain product traceability.

By recording key details such as batch numbers, materials used, and production dates, you can efficiently track your products throughout their lifecycle. In the event of a safety issue or recall, Craftybase provides the necessary information to quickly identify affected batches and take appropriate action.

3. Document Management

Craftybase allows you to store and manage important compliance documents, such as safety data sheets, test reports, and certificates. With all your documents organized and readily accessible in one place, you can easily provide evidence of compliance when required.

Craftybase empowers small manufacturers like you to navigate the complexities of GPSR compliance with ease and confidence. By leveraging its traceability and compliance features, you can streamline your operations, enhance product safety, and ensure that your business meets the necessary regulatory standards.

It’s important that you don’t wait until 2024 to start preparing for the GPSR: you’ll need to time to get your inventory and compliance systems in place, so the time to get started is now. Give Craftybase a try for free today (plans start from $19/mo) ➝

GPSR FAQ

How does the GPSR apply to second-hand products?

All products, new or second hand are subject to the regulations outlined for GPSR. The only exceptions are for products that are clearly advertised and marked as “repaired” or “reconditioned”, along with antiques.

Does GPSR apply to free products?

Yes, the GPSR is applicable to products given away for free.

I’m a small handmade seller, does GPSR apply to me?

As a general rule, GPSR obligations apply to businesses of all sizes. The idea is that consumers should be able to purchase safe products from small businesses right through to large corporations.

Do all products covered by the GPSR need to have technical documentation?

Yes, all products need technical documentation as outlined above. The amount of information required will differ on the type of product.

Will QR codes suffice as GPSR compliant labelling?

No, it is important to conform with GPSR that a physical label with all necessary information is placed clearly on the product, or alternatively on the packaging for the product. QR codes can be provided as an additional way to provide more information to the customer.