The GPSR responsible person for goods made in China

Short answer. The General Product Safety Regulation (EU) 2023/988 has applied since 13 December 2024. A consumer product may only be sold in the European Union if an economic operator established in the EU is responsible for it: the manufacturer, the importer, an authorised representative or a fulfilment service provider. If you are an EU company putting your own name on goods made in China, that operator is you. Your name, postal address and electronic address must be on the product, its packaging or an accompanying document. If your company is outside the EU, you must appoint an authorised representative in the EU before you sell.

This page is general information and not legal advice.

What the regulation covers

The General Product Safety Regulation replaced the 2001 directive. It applies to consumer products placed on the EU market, including products sold online and products that also fall under specific rules such as CE marking, where it fills the gaps. It applies to new, used, repaired and reconditioned products. Food, medicines, living plants and animals and a few other categories are excluded.

Who the responsible person is

Article 16 says a product may be placed on the market only if there is an economic operator established in the Union who is responsible for the tasks in Article 4 of Regulation (EU) 2019/1020. In order of who normally fills the role:

1. The manufacturer, if established in the EU. A brand that puts its own name or trademark on the product counts as the manufacturer, even when a factory in China made it.
2. The importer, the EU company that brings goods from outside the EU into the EU market.
3. An authorised representative appointed in writing by a non-EU manufacturer.
4. A fulfilment service provider in the EU, when none of the above exists.

For a European brand ordering from China under its own name, points 1 and 2 are the same company: you. You do not need to hire anyone; you need to meet the obligations. A brand outside the EU, for example in Switzerland, the United Kingdom or the Caribbean, needs an EU-based authorised representative or an EU importer.

What the responsible person must do

• Check that the technical documentation and, where required, the declaration of conformity exist, and keep them available for the authorities for 10 years.
• Give the authorities the documents and information they ask for, in a language they can understand.
• Inform the authorities when there is reason to believe a product is dangerous, and cooperate on corrective action.
• Make sure the product carries a type, batch or serial number and the manufacturer's name, registered trade name or trademark, postal address and electronic address.
• Report accidents caused by the product through the Safety Business Gateway.

What must be on the label

On the product, or where that is impossible on the packaging or an accompanying document:

• Manufacturer name, postal address and electronic address (email or web form).
• Responsible person name and contact details, if different from the manufacturer.
• Type, batch or serial number so the product can be traced.
• Warnings and safety information in the language of the country of sale.

If you sell through an online marketplace, the marketplace must show the responsible person's details on the listing and will ask you for them before it lists the product.

What this means when you order from China

Put the labelling requirement in the order specification before the factory prints packaging. Ask the factory for the technical documentation at the quote stage, not after shipment. Set up an email address that will exist for 10 years. Keep a complaints register. If your factory offers "a GPSR certificate", decline it: there is no such certificate. What exists is documentation, labelling and an EU operator who answers for the product.

Further reading

Read CE marking for small electronics for the technical documentation side, and the EUR 3 parcel charge guide if you ship small parcels. Equilinq puts the labelling and document requirements into every factory brief through Source.