GPSR for Chinese sellers: selling products in the EU

GPSR for Chinese sellers: selling products in the EU means ensuring consumer products are safe, traceable and supplied with the required information. Since 13 December 2024, a seller or manufacturer established in China must identify the relevant EU economic operator, prepare compliance evidence and complete product listings before making products available to EU customers.

Key takeaways

• Regulation (EU) 2023/988 applies to consumer products made available in the European Union, including products manufactured, shipped or sold from China.
• For many products from a non-EU manufacturer, an EU-established responsible economic operator must be identifiable before the product is placed on the market.
• An online product listing must show the GPSR safety and traceability information required for distance sales, alongside any marketplace-specific fields.
• GPSR does not replace sector-specific rules: toys, electrical equipment, radio equipment and cosmetics may also be subject to specific legislation and CE marking.
• Prepare documents before sending stock: responding to an authority request or a blocked listing is harder once goods are in a warehouse or already on sale.

Does GPSR apply to a seller established in China?

Yes. GPSR applies to consumer products made available on the EU market, even if your company is established in Shenzhen, Guangzhou, Hong Kong or another non-EU jurisdiction.

Regulation (EU) 2023/988 on general product safety, commonly called the GPSR, has applied since 13 December 2024. It covers general product safety, traceability, economic-operator duties, distance sales and cooperation with market-surveillance authorities.

Where the parcel starts its journey does not change that position. If you target EU consumers through your Shopify store, Amazon, eBay, Etsy, Temu or another marketplace, your products must meet the rules that apply in the market you are targeting. This remains true when you ship directly from China.

Imagine a Chinese brand selling decorative lamps to customers in France. If the lamps are offered on Amazon.fr, GPSR may apply, but the lamp may also fall within rules on electrical equipment, electromagnetic compatibility or low-voltage equipment, depending on its characteristics. GPSR then complements sector-specific requirements; it does not remove them.

If you do not yet know which rules to review for your product, storage countries and sales countries, an EU market-entry compliance assessment helps you organise the product, customs, VAT, packaging and regulatory-data checks to plan.

EU Seller Kit — For a first EU launch, start with an EU market-entry compliance assessment, then consider an EU GPSR responsible person where your situation requires an EU-established economic operator.

Which products and businesses are covered by GPSR for Chinese sellers: selling products in the EU?

GPSR mainly covers products intended for consumers, or reasonably likely to be used by them. It applies to each actor in the supply chain that places a product on the market or makes it available in the EU.

Common situations for Chinese sellers

You are likely to be concerned if you:

• sell directly to EU consumers from your China-based website;
• send stock to an Amazon FBA warehouse in Germany, France, Spain or another Member State;
• supply own-brand products to an EU distributor;
• have a product made in China and market it under a brand owned by your non-EU company; or
• use a marketplace that makes your offers available to EU consumers.

The manufacturer is the person or business that makes the product, or has it designed or manufactured and markets it under its own name or trademark. The importer is the EU-established operator that places a product from a third country on the EU market. A distributor then makes that product available further along the commercial chain.

Where the manufacturer is outside the EU, you must also establish which EU-based economic operator authorities can contact. GPSR sets out this requirement for products within its scope. For the practical responsibilities of that operator, see our guide to the GPSR responsible person: role and obligations.

Products subject to sector-specific rules

A common mistake is to treat GPSR as a general permission to sell. It is not. Some products are covered by specific harmonised EU legislation. For those products, GPSR does not apply, or applies only in a complementary way, to risks not covered by that legislation.

Product	Rules to check	Practical consequence
Toy	Directive 2009/48/EC	Prepare CE marking, safety assessment, warnings and technical documentation.
Radio equipment	Directive 2014/53/EU	Check radio compliance, EMC, safety and documentation duties.
Electrical equipment	Low Voltage and EMC Directives, depending on the product	Assess conformity before affixing the CE marking.
Cosmetic product	Regulation (EC) No 1223/2009	Appoint the specific responsible person and meet cosmetics-specific duties.

Key legislation includes the Toy Safety Directive, the Radio Equipment Directive (RED), the Low Voltage Directive and the Electromagnetic Compatibility Directive.

For a CE-marked product, check the specific requirements before import using our guide to CE marking for products made in China. You must never add CE marking simply because a marketplace asks for it: it follows from the conformity-assessment procedure that applies to the product.

Which responsible person must you appoint in the European Union?

For GPSR products manufactured outside the EU, an EU-established economic operator must be identifiable. This responsible person acts as a regulatory contact point and must be able to cooperate with the competent authorities.

Article 16 of GPSR states, among other things, that where a manufacturer is not established in the Union, the product may be placed on the market only where an EU-established economic operator is entrusted with tasks defined by the Regulation. Depending on your supply chain, this may be an importer, an authorised representative or a responsible person established in the EU.

In practice, do not assume that Amazon, a freight forwarder, an FBA warehouse or your software subscription automatically becomes your responsible person. Appointment requires an appropriate contractual relationship and, depending on the service, product acceptance, entity assignment, a signed mandate and active payment.

An EU GPSR responsible person is a service to consider if you are a non-EU seller or manufacturer and no EU importer is taking that role. Activation is not automatic: it takes place only after product review, entity assignment, a signed mandate and active payment.

Do not confuse a GPSR responsible person with a CE authorised representative

The word “representative” can describe different roles. A GPSR responsible person is not necessarily an authorised representative under CE legislation, and the reverse is also true. For a product subject to CE marking, the manufacturer must first carry out its own conformity assessment, compile technical documentation, arrange necessary testing and draw up the EU declaration of conformity where required.

A CE authorised representative may be appointed by written mandate where the applicable legislation permits it. It does not replace the manufacturer’s conformity assessment, testing, technical file or EU declaration of conformity. The European Commission’s Blue Guide explains economic-operator roles and the EU framework for harmonised products.

What information must appear on the product and online listing?

You must provide traceability and safety information on the product, its packaging or an accompanying document where appropriate. For online sales, the product listing must also display the required information before the customer buys.

On the product, packaging or accompanying document

GPSR requires the product to be identified by a type, batch, serial number or another traceability element. The manufacturer must also state its name, registered trade name or registered trademark, plus a postal and electronic contact address. Where the manufacturer is outside the EU, the details of the EU-established economic operator must be provided in line with the applicable framework.

Warnings and safety information must be clear and written in a language that consumers in the target market can easily understand. The precise language requirements depend on the Member State or States where you sell. An English-only instruction leaflet may therefore be insufficient for a product aimed at consumers in France.

Information must fit the product. A simple non-electrical accessory does not need the same warnings as a charger, a toy containing small parts or a chemical product. Use our guide to mandatory GPSR labelling information to organise the checks.

On the online product listing

Article 19 of Regulation (EU) 2023/988 sets specific requirements for distance-sale offers. The online presentation must enable the manufacturer to be identified and, where it is established outside the EU, the responsible economic operator in the Union. It must also identify the product and show relevant warnings or safety information.

A photograph of the label is not always enough if it cannot be read on a mobile screen, is incomplete or sits in a hard-to-find secondary image. Add information to the marketplace’s structured fields where available, then check how the published page actually displays. Our guide to GPSR Article 19 and online product listings explains the requirement in more detail.

Before publishing, use the marketplace product compliance scanner to flag traceability, safety and compliance information to check on an Amazon, eBay, Etsy, Shopify or other marketplace listing. It does not replace a regulatory assessment of the product, but it helps identify missing listing information.

EU Seller Kit — If your catalogue is already online, use the marketplace product compliance scanner before publication or after a listing block. For Amazon-specific requirements, see our guide to Amazon GPSR compliance information.

How do you prepare GPSR compliance before shipping from China?

Prepare compliance before final production and before stock leaves China. You can then correct a label, request a test report or amend a listing without leaving a pallet held in an EU warehouse.

A seven-step method

1. Describe the product and intended use precisely. Record materials, components, user age, accessories, any power supply, batteries and destination markets. “Kitchen gadget” is not a sufficient description for determining applicable rules.

2. Identify applicable legislation. Check whether the product is covered only by GPSR or also by sector-specific rules, particularly for toys, electronics, radio equipment, cosmetics or textiles. Country Compliance helps organise checks by origin, storage and destination country; it does not replace a decision by the competent authority.

3. Check the supplier before placing the order. Request the manufacturer’s exact identity, specifications, available test reports, relevant certificates, label photographs and traceability evidence. Supplier Check centralises identity, payment and delivery information so that inconsistencies can be reviewed.

4. Carry out or document the risk assessment. Identify foreseeable hazards from the product, normal use and reasonably foreseeable misuse: cuts, burns, choking, electric shock, instability, substances or overheating. A risk assessment should lead to practical measures, such as a design change, warning, age restriction, instructions or stronger quality control. Our GPSR risk-assessment method can provide a working structure.

5. Build an evidence file. Keep documents that support safety and compliance: specifications, risk assessments, test reports, production controls, label photographs, instructions, declarations and manufacturer correspondence. The exact content depends on the product and applicable legislation.

6. Appoint the appropriate EU economic operator. Clarify the role of the importer, distributor, GPSR responsible person or, where relevant, CE authorised representative. Do this before placing the product on the market, not after Amazon or an authority asks.

7. Publish and check sales information. Check displayed contact details, product identification, warnings and languages. Keep a dated version of the published listing, as it can be useful evidence during an inspection or dispute.

Checklist before shipment or publication

• I have identified the actual manufacturer, brand and exact product model.
• I have checked whether the product is covered by GPSR alone or by sector-specific CE legislation.
• I have collected specifications, the risk assessment and relevant testing or inspection evidence.
• I have prepared a batch, model or serial identification system that supports traceability.
• I have checked the manufacturer’s details and those of the relevant EU economic operator.
• I have adapted warnings, instructions and safety information for the destination markets.
• I have checked that the online listing shows the required GPSR information before purchase.
• I have retained final versions of labels, packaging, instructions and the product listing.

Which documents should you keep and provide during an inspection?

You must be able to show that the product is safe and that the information you provide matches the product actually sold. Exact documents vary by product category, but evidence spread across your factory, sourcing agent and marketplace creates an operational risk.

For a product mainly covered by GPSR, prepare an organised file containing product and variant identification, contact details for relevant actors, the risk assessment, specifications, available test results, quality controls, labelling photographs, warnings, instructions and batch-traceability records.

For a CE-marked product, the manufacturer will generally need technical documentation and, where the legislation requires it, an EU declaration of conformity. Content depends on the relevant directive or regulation. Your Europe’s CE marking guidance confirms that CE marking is the manufacturer’s responsibility and is not a general European certificate.

Example: a seller ships a Bluetooth-enabled device from Shenzhen to an FBA warehouse in Germany. The seller should be able to link the model sold to its technical documents, relevant testing, labelling, economic-operator details and the version of the Amazon listing. A generic certificate for a different model or brand does not establish that connection.

Market-surveillance authorities can request information, inspect products and take measures where a risk is identified. Regulation (EU) 2019/1020 on market surveillance sets out the framework for authority powers and cooperation in this area.

How should you manage import, VAT and Amazon FBA storage?

GPSR addresses product safety; it does not replace customs formalities or VAT duties. If you import stock from China, plan these matters in parallel before the goods depart.

An EORI number identifies operators in EU customs formalities. The European Commission explains the purpose of EORI. Whether you need one depends on your role in the customs declaration, your establishment and the trade flow. An EORI is not a VAT number and does not appoint a GPSR responsible person.

If you send stock to Amazon FBA in Germany, determine who is the importer, who submits the customs declaration, where stock is imported and stored, and which VAT duties may follow. Where an EORI is needed, use EORI file preparation to prepare the application file; the customs authority issues the number, and the preparation service is a one-time service unless included in a SaaS plan quota.

Tariff classification affects customs duty and sometimes import measures. The HS classification assistant generates candidate HS subheadings for you to confirm in the Combined Nomenclature or TARIC. You can then consult the European Commission’s TARIC database to check applicable tariff treatment.

To estimate known shipment costs, the customs cost simulator structures customs value, duty where a valid tariff rate is available, and import VAT. To compare VAT scenarios, including EU stockholding and direct sales, use the EU VAT calculator. OSS and IOSS should be assessed against your sales model; the Commission explains both schemes through its OSS/IOSS portal.

Which mistakes most often lead to a blocked listing or document request?

Blocks often result from an incomplete or inconsistent file rather than one missing label. Prevention means linking the physical product, supporting documents and sales listing to the same product reference.

Treating a supplier certificate as proof of conformity

A supplier may send a document called a “CE certificate” or “test report”. That does not automatically prove that your product, model, brand and production version comply. Check the laboratory identity, exact reference, date, standards tested, covered variants and consistency with the goods shipped.

Displaying an address that has no regulatory role

The address of a logistics agent, freight forwarder or warehouse is not automatically the address of the responsible economic operator. Using an address without a mandate or genuine role can complicate an authority request and lead to a listing or labelling correction.

Adding CE marking without an applicable procedure

CE marking applies only to product categories covered by EU legislation that requires it. It does not apply to every consumer product. Conversely, failing to apply CE marking to a product that requires it is a separate issue from GPSR.

Treating languages as a graphic detail

Warnings must be understandable to consumers in the country of sale. Translating after stock arrives may require costly relabelling and delay the launch. Plan language versions when packaging is approved.

Overlooking environmental and national obligations

GPSR does not exhaust all market-placement duties. Packaging, electrical equipment, cells and batteries can trigger extended producer responsibility or registration obligations depending on the country. For electrical products, consult the WEEE Directive and organise country-by-country checks before selling.

Tools and services to take action

• EU Market Entry Compliance Assessment — use this guided assessment when planning a first shipment or mapping GPSR, CE, customs, VAT, packaging and product-data obligations.
• GPSR Responsible Person (EU) — consider this where a non-EU seller or manufacturer needs an EU-established economic operator; it becomes active only after product review, entity assignment, a signed mandate and active payment.
• Marketplace Product Compliance Scanner — analyse a listing before publication to identify traceability, safety and compliance information to review.
• EU Representative overview — compare the GPSR responsible person and CE authorised representative roles before selecting the appropriate arrangement for your product.
• Pricing and plans — review SaaS plans and add-on services without assuming that a subscription automatically appoints a representative.

Frequently asked questions

Does a Chinese seller need a GPSR responsible person in the EU?

Often, yes, where the manufacturer is established outside the EU and no other EU-established economic operator takes the required role for the product. Review your supply chain carefully because an EU importer may have a decisive role. A marketplace, warehouse or SaaS subscription is not automatically a valid appointment.

Does GPSR apply to Amazon FBA sales?

Yes. Storing goods in an Amazon FBA warehouse does not remove the product-safety, traceability and information duties that apply to the product. You must also deal separately with import, EORI, VAT and obligations linked to the storage country; Amazon may request information or documents before or after a listing is published.

Can I sell from China without holding stock in the European Union?

Yes, but having no EU stock does not exempt you from GPSR when you target EU consumers. The Regulation expressly addresses distance sales. Prepare listing information and the details of the relevant economic operator before accepting orders.

Is CE marking enough to comply with GPSR?

No. CE marking responds to sector-specific rules for certain product categories; it does not automatically replace GPSR duties, including distance-sale information and general product-safety requirements. Review the legislation that applies to your product and its risks.

Can an Amazon warehouse address be shown as the responsible person’s address?

No, not by default. The displayed address must belong to the economic operator that actually carries out the regulatory tasks and can cooperate with authorities. A warehouse provides logistics and does not necessarily accept a regulatory role.

Which documents might Amazon or an authority request?

The request depends on the product, platform and risk identified. It may cover manufacturer and EU-operator details, warnings, test reports, risk assessment, labelling photographs, technical documentation or an EU declaration of conformity for relevant products. Keep an accessible, consistent file for every product reference you sell.

Official sources

• Regulation (EU) 2023/988 — General Product Safety Regulation — GPSR rules on safety, traceability, economic operators and distance sales.
• Regulation (EU) 2019/1020 — market surveillance and compliance of products — market-surveillance and authority-cooperation framework for products on the EU market.
• Commission Notice — The Blue Guide on the implementation of EU product rules (2022) — roles of manufacturers, importers, distributors and authorised representatives for harmonised products.
• Your Europe — CE marking — CE marking principles and manufacturer responsibilities.
• European Commission — Economic Operators Registration and Identification (EORI) — EORI identification for customs formalities.
• European Commission — TARIC consultation — tariff and customs measures applicable to goods.
• European Commission — VAT One Stop Shop (OSS / IOSS) — VAT one-stop-shop schemes for relevant EU sales models.
• Directive 2012/19/EU — waste electrical and electronic equipment (WEEE) — WEEE obligations and related responsibilities for electrical and electronic equipment.

This content provides general information and is not legal advice.