EU GPSR: What Every Non-EU Gift Brand Needs to Know

GPSR (Regulation (EU) 2023/988) applies directly across all 27 EU member states from December 13, 2024. Unlike the old GPSD, it requires no national transposition, so there is no variation in scope or timing between Germany, France, the Netherlands, and every other member state. A single product safety standard now covers the whole EU.

The regulation introduces three obligations that US brands typically did not face under the old system: a mandatory EU-based Responsible Person for every non-EU manufacturer's product, a formal technical file documenting the product's safety rationale, and specific disclosure fields on every online listing. These are not optional certification marks. They are base-level requirements.

GPSR Article 3(1) covers products "likely, under reasonably foreseeable conditions, to be used by consumers." The US Trade.gov bulletin explicitly confirms GPSR applies "both directly to consumers AND B2B." A US candle brand selling wholesale to 30 French boutiques through Faire EU is fully within scope. A US ceramics brand selling net-30 to 15 German shops via direct invoice is fully within scope.

The supply-chain roles GPSR creates: Manufacturer (the US brand making and designing the product); Importer (whoever places the goods on the EU market for the first time, could be the brand via DDP shipping, or the EU retailer via EXW); Distributor (any entity in the chain who doesn't manufacture or import); and Responsible Person (a mandatory EU-established economic operator who acts as the brand's regulatory contact).

If you ship DDP to EU customers, meaning you handle customs . you are the importer and carry direct GPSR obligation. If you ship EXW/DAP and the EU buyer imports, they carry the importer obligation, but they will demand RP documentation from you before reordering. Either way, an EU Responsible Person is effectively unavoidable for any brand with meaningful EU wholesale volume.

The Responsible Person (RP) must be established in the EU, meaning a legal address in an EU member state. They sign a written mandate with the manufacturer specifying their obligations: holding or having access to the technical file, verifying compliance, registering on the EU Safety Business Gateway, investigating complaints, liaising with market surveillance authorities, and cooperating with product recalls.

The RP's name and contact details must appear on every product label (or accompanying documentation), and on every online product listing page for EU consumers. A QR code is supplementary; it does not replace the text requirement.

Under Article 9(2), the manufacturer (or their RP on their behalf) maintains a technical file. It must include a general description, materials identification, applicable EU standards consulted, a risk assessment, any test reports, label artwork, and an internal corrective-action procedure. The file is retained for 10 years after the last product placed on the EU market.

The November 2025 Commission Guidelines (C/2025/6233) added new interpretive guidance, including that risk assessments must now consider psychosocial risks for certain product categories. The risk assessment does not need to be long, one to three pages per product group is typical for low-risk gift items, but it must be in writing and evidence-based.

Every product listing visible to EU buyers must include: the manufacturer's name, trade name, and postal and electronic address; the Responsible Person's name and postal and electronic address; a product image; a product type identifier; and any warnings required for safe use, all in the language of the EU member state where the product is offered.