General Product Safety Regulation (GPSR), EU Regulation

The General Product Safety Regulation (GPSR) is a key regulation for consumer product safety in the EU. It is to be implemented from 13^th December 2024 and it is replacing the current General Product Safety Directive and the Food Imitating Product Directive.

The GPSR aims to protect consumers by establishing a harmonized framework through the EU Product Safety Regulation, ensuring that products placed on the market are safe to use and do not pose risks to health or safety. It provides obligations requiring responsible behaviour from businesses involved in placing products on the market facilitating the free movement of safe products within the EU market.

Principles of GPSR

Product safety assessment
Mandatory Product labelling Compliance
Product Recall and Monitoring
Due Diligence of Technical Data
Internal Process for product Safety
Applies to all EU Member States
Local Economic Operator / Responsible Person
Mandatory safety assessment
Adverse Event Monitoring, Reporting & Recall
Technical Documentation

Specific Product Types

General consumer and household use products, which are not covered by any specific regulation, will fall under the purview of general product safety regulation.

Stationaries
Art & crafts
Graffiti Removers
Air Fresheners
Reed diffusers
Cleaning & Hygiene products
Articles & Accessories
Candles & Incense sticks
Wax & Polishes
Adhesives
Degreasers
Footwear or Leather Care Products
Furniture Maintenance Product
Jewellery
Other Plastic products

Impacted Sales Channels

Key Activities under GPSR

The major obligations of the economic operators would be to ensure the following:

Product Safety
Ensuring product safety and compliance throughout its lifecycle is essential for market placement.
Get Assessment
Labeling Compliance
Labels of products to be updated to incorporate the mandatory attributes.
Get Compliance
Authorized Representative
Gain the under-hindered market access.
Gain Access
Technical data generation and maintenance
Products must have updated technical data available for 10 years after market placement.
Maintain Records
Due diligence
Compulsory for all economic operators including retailers and e-Commerce industry.
Consult Experts
Product monitoring and recall
Inform competent authorities in case of product recall or safety concerns identified
Report Concerns
Horizontal Regulations
REACH and CLP obligations, including supplying product SDS and poison centre notifications, remain unchanged.
Meet Standards

How Can Freyr Support?

Product safety in the EU is an ongoing concern. GPSR compliance requirements would be a continuous activity. Given the complexity of obligations across the supply chain, Freyr can act as a go-to partner for all the economic operators under GPSR i.e., manufacturers, importers, online marketplaces, or distributors.

Freyr can provide the following end-to-end support throughout the product life cycle:

Authorized representative
Product safety substantiation and GPSR compliance
Ensuring product labeling compliance as per GPSR
Establishing internal systems for safety and compliance
Due diligence and compliance evaluation of technical data
Recommending strategies to eliminate or mitigate identified risks
Coordinating with the supply chain partners
Coordinating with Health Authorities (HAs)
End-to-end solutions for prominent overlapping regulations like EU REACH and CLP

Frequently Asked Questions (FAQs) on GPSR

We are here to provide you with the information you need quickly and efficiently.

01. What is the scope of General product safety regulation GPSR?

The General Product Safety Regulation (GPSR) obligations apply to all consumer products manufactured or imported within the EU including second-hand products or products that are repaired, reconditioned, or recycled, that re-enter the supply chain during a commercial activity. GPSR is also applicable to professional products which have subsequently migrated to the consumer market, and which could pose risks to the health and safety of consumers when used under reasonably foreseeable conditions.

02. What is the Definition of “Safe Product” under GPSR?

“Safe product” is defined as any product which, under normal or reasonably foreseeable conditions of use, including the actual duration of use, does not present any risk or only the minimum risks compatible with the product’s use, considered acceptable and consistent with a high level of protection of the health and safety of consumers.

03. What are the product types that GPSR applies to?

Applies to all products marketed or imported to the EU, that are not governed by their specific regulations. Specific product categories are stationaries, arts and crafts, graffiti removers, air fresheners, reed diffusers, cleaning and hygiene products, candles and incense sticks, wax and polishes, adhesives, degreasers, footwear or leather care products, furniture maintenance products, articles and accessories, jewelry, and other plastic products.

04. Which Sales Channels are impacted by the General Product Safety Regulation?

The sales channels that have been impacted by the General Product Safety Regulation (GPSR) are manufacturers, importers, retailers and distributors, e-commerce, Direct-to-Consumer (D2C), and Business-to-Business (B2B) organization sales (hotels and amenities, aviation, etc.).

05. What are the principles of GPSR?

The principles of GPSR are-Product Safety Assessment, Mandatory Product Labeling Compliance, Product Recall and Monitoring, Due Diligence of Technical Data and Internal Process for Product Safety.

Economic Operator Obligations
	Manufacturer	Importer	Authorized Representative	Distributor/Retailers	Online Marketplaces/E-commerce
Definition	Manufacturer means any natural or legal person who manufactures a product or has a product designed or manufactured, and markets that product under that person’s name or trademark.	‘Importer’ means any natural or legal person established within the Union who places a general product from a third country on the Union market.	‘Authorized representative’ means any natural or legal person established within the Union who has received a written mandate from a manufacturer to act on that manufacturer’s behalf in relation to specified tasks with regard to the manufacturer’s obligations under GPSR.	‘Distributor’ means any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a product available on the market.	An online marketplace is a provider of an intermediary service using an online interface that allows consumers to conclude distance contracts with traders for the sale of products. The online interface can be any software, including a website, part of a website, or an application, including mobile applications.
Product compliance with the general safety requirement	Yes	Yes	Yes (on behalf of the manufacturer)	To verify if the manufacturer or importer has complied with the safety obligations	To verify if the manufacturer or importer has complied with the safety obligations
Establishment of internal processes for product safety in the EU	Yes	Yes	Yes (on behalf of the manufacturer)	Yes (primarily through verification)	Yes [should establish a system such that traders provide mandatory details such as name and address of importer/manufacturer/Responsible Person (RP), warning or safety instructions, etc. on product label or packaging]
Establishing, maintaining, and updating technical data for product safety in the EU	Yes, technical documentation must be stored for up to ten (10) years at the disposal of the market surveillance authorities.	Yes, technical documentation must be stored for up to ten (10) years at the disposal of the market surveillance authorities.	Yes (on behalf of the manufacturer)	No, the primary obligation is to verify the mandatory details such as the name and address of the importer, warning or safety instructions, etc. available on the product label or packaging.	No direct obligation. However, they must ensure traders provide self-declaration stating the GPSR compliance.
Additional mandatory attributes on product labels or packaging	Name, their registered trade name or registered trademark, their postal and electronic address, batch or serial number, clear instructions, and safety information	Name, their registered trade name or registered trademark, their postal and electronic address, batch or serial number, clear instructions, and safety information	Verify if mandatory information is available on the product label.	Verify if mandatory information is available on the product label.	Not applicable.
Supply chain obligations in case of product safety concerns	Inform other actors about product safety concerns.	Inform other actors about product safety concerns.	At the manufacturer's discretion, inform other actors about product safety concerns.	Inform other actors about product safety concerns.	Inform other actors about product safety concerns.
Obligations in case of product safety concerns	Take corrective action (including recall or withdrawal); inform consumers; and inform authorities through the Safety Business Gateway [Rapid Alert System for Non-Food Products (RAPEX)].	Inform the manufacturer; ensure that corrective action is being taken as appropriate; inform consumers; and inform authorities through the Safety Business Gateway (RAPEX).	Inform the manufacturer, cooperate with the market surveillance authority; and upon information from the manufacturer, inform authorities through the Safety Business Gateway (RAPEX).	Inform the manufacturer or the importer; ensure that the corrective measures are taken; and ensure that authorities are informed through the Safety Business Gateway (RAPEX).	Inform the economic operators, inform consumers through their website, inform authorities through the Safety Business Gateway (RAPEX); and coordinate with economic operators and authorities to ensure recall.
Monitoring of product recalls and enforcement actions to determine market trends and risk factors	Maintain communication channels such as telephone number, electronic address, or dedicated section of website accessible to consumers. Establish an internal register for record-keeping purposes (product recall/corrective actions).	Verify if such communication channels are available. Establish an internal register for record-keeping purposes (product recall/corrective actions).	At the manufacturer's discretion.	Verify if information on the communication channel to assist in safety complaints is available on the product label.	Designate a single point of contact for consumers on product safety issues. Collect and record the information.

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