EU Seller Kit

GPSR by Product Category: Toys, Textiles, Electronics and Cosmetics

GPSR by Product Category: Toys, Textiles, Electronics and Cosmetics helps you establish whether Regulation (EU) 2023/988 applies on its own or alongside sector-specific legislation. Toys, electronic equipment and cosmetics have dedicated legal frameworks; textiles commonly fall under GPSR plus fibre-labelling rules. In every case, the product must be safe, traceable and presented correctly before purchase.

Key takeaways

  • Regulation (EU) 2023/988, known as the GPSR, has applied to consumer products made available on the EU market since 13 December 2024.
  • Where EU sector-specific legislation covers a product category or risk, it takes priority within that scope; GPSR fills gaps that the sector-specific rules do not cover.
  • CE marking, where required, follows the manufacturer's conformity-assessment process. A statement in a listing or a generic certificate is not enough.
  • Before selling online, check documents, traceability, warnings, languages and the information displayed in the distance-sales offer.

Who must apply GPSR by Product Category: Toys, Textiles, Electronics and Cosmetics?

GPSR applies to economic operators making consumer products available in the EU, including manufacturers, importers, distributors and online sellers. Your precise duties depend on your place in the supply chain, but selling through a marketplace does not automatically transfer your obligations to that platform.

Regulation (EU) 2023/988 on general product safety covers products intended for consumers, or likely under reasonably foreseeable conditions to be used by them. This can include new, second-hand, repaired and refurbished products, subject to any specific rules that apply.

Roles to distinguish before publishing a product reference

The manufacturer designs the product or has it made under its name or trade mark. Where a conformity assessment is required, the manufacturer has primary responsibility for that process and its supporting documentation.

The importer is established in the EU and brings in a product from a third country. Before placing it on the market, the importer must check that the manufacturer has completed the relevant steps and that the product carries the required information.

A distributor, including a reseller, must act with due care. It must not supply a product that it knows, or should reasonably know, is non-compliant or dangerous. The duties of economic operators and their cooperation with authorities are explained in the GPSR Article 16 guide.

Example: if you ship from Shenzhen to an Amazon FBA warehouse in Germany, Amazon holding the stock does not make Amazon the manufacturer or importer in your place. You still need to identify the relevant economic operator, organise the conformity evidence and provide the information requested by the marketplace.

For a seller or manufacturer outside the EU, check product by product whether an EU-established economic operator is required. The EU GPSR Responsible Person service may suit certain consumer products. It becomes active only after acceptance, entity assignment, a signed mandate and active payment.

EU Seller Kit — Start with the EU Market Entry Compliance Assessment if you do not yet know which GPSR, CE, customs, VAT or environmental obligations apply to your products and trade flows.

Which rules apply to toys, textiles, electronic equipment and cosmetics?

A product's legal classification determines its substantive requirements, documents and, in some cases, the type of responsible operator needed. GPSR is not a universal certification; it complements sector-specific legislation rather than replacing it.

Toys: toy safety, CE marking and complementary GPSR duties

A product designed or intended for play by children under 14 will generally fall within Directive 2009/48/EC on the safety of toys. This framework requires, among other things, a safety assessment, technical documentation, an EU declaration of conformity and CE marking under the applicable procedure.

A soft toy marketed as decoration may still be a toy if its appearance, presentation or foreseeable use invites children to play with it. Review small parts, choking risks, flammability, substances, warnings and the intended age group. The guide to selling toys in the EU: CE marking, warnings and documents sets out the evidence to gather before sale.

Textiles: general safety and fibre composition

Clothing, household linen and textile accessories are not automatically subject to CE marking. They must nevertheless be safe under GPSR and comply with Regulation (EU) No 1007/2011 on textile fibre names and labelling.

A label stating “100% cotton” does not demonstrate that the product is safe. A children's dress with drawstrings, pyjamas treated with a particular substance, or a cover with detachable fasteners requires an assessment suited to foreseeable risks. See the guide to EU textile fibre labelling, GPSR safety and documents to separate labelling duties from product-safety checks.

Electronics: identify the applicable CE legislation

Electronic equipment can fall within several EU legal acts. A product incorporating Wi-Fi, Bluetooth or other radio technology will generally fall under Directive 2014/53/EU on radio equipment (RED). Depending on its characteristics, it may also fall under the Low Voltage Directive 2014/35/EU or Directive 2014/30/EU on electromagnetic compatibility.

Imagine a Bluetooth night light sold for a child's bedroom. Its radio function, power supply, marketed purpose and components must each be assessed. CE marking can be affixed only after the applicable conformity assessment; it does not replace testing, technical documentation or the EU declaration of conformity. The RED, LVD and EMC guide for electronics sellers can help you structure that classification.

Cosmetics: a separate regime and a specific responsible person

Cosmetics fall under Regulation (EC) No 1223/2009 on cosmetic products. Before they are placed on the market, this regime requires, among other things, a responsible person, a product information file, a safety assessment, notification through the Cosmetic Products Notification Portal (CPNP), and compliant labelling.

Do not confuse the responsible person under the Cosmetics Regulation with a GPSR responsible person. Their functions, documents and governing legislation differ. For a cream, serum or shampoo, begin with the guide to selling cosmetics in Europe: CPNP, responsible person and labelling, rather than applying GPSR alone.

What must you show on the product and in the online listing?

The information must enable product identification, contact with the relevant operators and safe use. For distance sales, the required information must be accessible to the consumer before purchase, not only inside the parcel.

GPSR establishes a traceability approach. Depending on the product and its size, information may appear on the product, its packaging or an accompanying document. Sector-specific rules may add category-specific information, such as toy warnings, cosmetic particulars or markings for electrical equipment.

Information to check in an online offer

For a consumer-product listing, check in particular:

  • product identification: type, model, batch, serial number or another relevant traceability element;
  • the manufacturer's name or trade mark, postal address and electronic address;
  • where the manufacturer is not established in the EU, the contact details of the EU-established economic operator where GPSR requires them;
  • relevant warnings and safety information in a language consumers in the target country can understand;
  • applicable sector-specific information, such as fibre composition or mandatory cosmetic particulars.

GPSR Article 19 addresses the information to be provided in distance-sales offers. Read the GPSR Article 19 explanation for online product listings before uploading product data to Amazon, eBay, Etsy, Shopify or your own shop.

A common mistake is to place warnings in an image that is too small, reserve them for a downloadable PDF, or show them only after the order. In practice, a marketplace may block the listing and an authority may consider that the pre-contractual information was not properly provided.

EU Seller Kit — Use the Marketplace Product Compliance Scanner before publication to flag safety, traceability and compliance information to verify in your listing. It does not replace an assessment of the product's regulatory status.

How do you check a product reference step by step?

Start by describing the actual product, then classify its functions and users before requesting supplier documents. This prevents you from treating a toy as decoration or connected equipment as a simple accessory.

Practical procedure before placing a product on the market

  1. Describe the reference without relying only on its commercial title. Record its function, materials, power supply, connectivity, intended age group, accessories, substances applied to the skin and country of manufacture.
  2. Identify users and foreseeable uses. A children's item, heated product or cosmetic needs different checks from a straightforward adult textile.
  3. Determine the applicable sector-specific legislation. Check whether the product is a toy, cosmetic, radio equipment, electrical equipment or textile subject to fibre-labelling rules.
  4. Request evidence suited to the actual product. Depending on the case, this may include a risk assessment, test reports, technical file, EU declaration of conformity, product information file, safety report or traceability records.
  5. Check the product, packaging and online listing. Names, models, warnings, languages and contact details must be consistent across every medium.
  6. Prepare for an incident. Retain supply-chain contacts and document versions, and organise a withdrawal or recall procedure.

Checklist for each product reference

  • I have described the actual function, components, intended user and reasonably foreseeable uses.
  • I have identified sector-specific legislation before relying on GPSR.
  • I have checked that reports and declarations cover the model, version and components actually sold.
  • I have checked warnings, safety information and languages for every target country.
  • I have checked consistency between the product, packaging, documents and sales listing.
  • I have identified the EU-established economic operator where that requirement applies.
  • I have retained evidence and organised a response to a marketplace or authority request.

If you import stock, do not confuse customs classification with regulatory classification. An HS code is needed for the customs declaration, but it does not by itself decide whether a product is a toy or radio equipment. The HS classification assistant generates candidate subheadings that you should then confirm in the CN or TARIC.

Which documents, effort and mistakes should you anticipate?

The effort depends on the product's complexity and risk, as well as your role in the supply chain. You need to demonstrate a coherent compliance process, not simply collect certificates supplied by a manufacturer.

For a straightforward textile, the file will often cover fibre composition, general safety, labelling and traceability. A toy or connected device will usually require more structured technical documentation. For cosmetics, the product information file and safety assessment are central preconditions before marketing.

Mistakes that cause the most blocks

  • Relying on the commercial category. Terms such as “gadget”, “accessory” or “decoration” do not exclude toy or electronics rules.
  • Accepting a document without checking its scope. A test report must match the product, version, components and relevant legislation.
  • Treating CE as a marketing label. CE marking is the manufacturer's regulatory declaration, not proof of general quality.
  • Mixing up representation roles. A CE authorised representative, GPSR responsible person and cosmetics responsible person are not interchangeable.
  • Forgetting the distance-sales listing. A correct label inside the parcel does not necessarily remedy an incomplete pre-purchase offer.

Authorities may request information and take measures where a product presents a risk or does not meet applicable requirements under Regulation (EU) 2019/1020 on market surveillance and product compliance. Depending on the circumstances, the consequence may be a blocked listing, a document request, withdrawal or corrective action.

A CE Authorised Representative may be appropriate where the applicable CE legislation permits that appointment. It acts under a written mandate and never replaces the manufacturer's conformity assessment, testing, technical documentation or EU declaration of conformity. To compare SaaS plans and add-on services without assuming a price, see EU Seller Kit pricing and plans.

Tools and services to take action

  • EU Market Entry Compliance Assessment — use this guided assessment before a first launch to map the obligations to check for your products, countries and trade flows.
  • GPSR Responsible Person (EU) — consider this service when a non-EU seller needs an EU-established responsible economic operator for consumer products, subject to review, mandate and activation.
  • Marketplace Product Compliance Scanner — analyse a listing before publication to identify safety, traceability and compliance information that needs checking.
  • HS classification assistant — use it when preparing an import to generate candidate subheadings, then confirm them in the CN or TARIC.
  • EU compliance tools — access classification, VAT, customs, supplier-check and country-compliance tools for the relevant stage of your project.

Frequently asked questions

Does GPSR replace CE marking?

No. GPSR does not replace EU harmonisation legislation that requires CE marking for certain categories, including many toys and electronic products. The manufacturer must follow the applicable conformity-assessment procedure before affixing CE marking; GPSR may supplement matters not covered by that legislation.

Does a textile need CE marking?

Not automatically. An ordinary textile is not generally subject to CE marking merely because it is textile, but it must comply with GPSR and applicable fibre-labelling rules. Added functions, such as electrical or radio functions, can bring the product within another regulatory framework.

Can a GPSR responsible person manage a cosmetic product?

The responsible person required under the Cosmetics Regulation belongs to a specific legal regime. It must not be confused with the responsible economic operator under GPSR. For a cosmetic, first check the requirements of Regulation (EC) No 1223/2009, including the responsible person, product information file and CPNP notification.

Can GPSR information be provided after the order?

No. Where GPSR requires relevant information for distance sales, it must be accessible in the offer before purchase. Providing it only in the parcel, in an order-confirmation email or in a difficult-to-access file may be insufficient. Sector-specific rules can require additional information.

Is a supplier certificate enough to sell in Europe?

No. You must check that every document matches the product actually sold, its version, its components and the applicable legislation. A generic certificate, a report without clear model identification or a document referring to a different standard does not by itself demonstrate compliance for your product reference.

Official sources

This content provides general information and is not legal advice.