Under the EU General Product Safety Regulation, a listing you cannot back with documents is a listing waiting to be taken down.
GPSR — Regulation (EU) 2023/988 — has applied since 13 December 2024, reaching products sold online to EU consumers just as much as shelf products. Marketplaces hold due-diligence duties under Article 22, so any requested file must exist, be current and match the model you sell. We build those files per model — this page shows what we produce and what to demand of any supplier.
Scope and dates: where GPSR starts to bite
The old General Product Safety Directive is gone; since 13 December 2024 the regulation governs which consumer products may be placed on the EU market, online sales included, covering new, used, repaired and reconditioned units alike. Where sector-specific rules already govern a safety objective, GPSR is the safety net, not the primary rule; medicinal products, food and feed, and living plants and animals sit outside its scope. For smart pet electronics — feeders, fountains, self-cleaning litter boxes, grooming tools, connected toys — the question is not only whether a CE mark exists, but who answers for safety.
The responsible person, and the role you hold
Obligations attach by role — manufacturer, importer, distributor, authorised representative, fulfilment provider, online marketplace. Buy from a non-EU supplier, sell direct to EU consumers, and you usually stand in the importer's shoes, factory or not, document and traceability duties included; our OEM sourcing checklist for pet products from China covers the supplier side. Article 16 sets the hard gate: a covered product may be made available only if an economic operator established in the Union answers for its safety compliance, with name, postal address and electronic contact open to consumers and authorities. Before leaning on a supplier's arrangement, check five points: a named EU responsible person exists; their details reach the product or packaging; safety questions have a live route; a written mandate is on file; the person can reach the technical file and the incident process. Litter-box importers can go deeper in our GPSR countdown for smart litter box importers.
The technical file and the risk analysis behind it
Article 9(2) requires manufacturers to carry out an internal risk analysis and prepare technical documentation. Our per-model file holds: product identification (model, version, batch or serial format); intended use and plausible misuse; a risk assessment walking through electrical, battery, thermal, mechanical, chemical and software hazards; the test reports and signed declarations each framework requires; label artwork, warnings and instructions; a change-control log covering new components, suppliers and firmware; and post-market surveillance and incident notes.
For smart pet electronics, run seven lenses: what the battery and charger can do wrong (overcharge, thermal runaway, water getting in); what pumps, motors and moving parts can do (jam, run hot, pinch); how sensors misread (false triggers, drift); what happens when connectivity drops (pairing, firmware, lost link); how water and cleaning attack the build (ingress protection, detachable parts); what the animal does to the product (chewing, pawing, entrapment); and how software misbehaves — a feeder dispensing twice, a fountain running dry, a litter box cycle stopping halfway. A CE certificate alone is not a technical file — the test reports, signed DoC, model list and change-control history are what you ask to see. Battery paperwork for powered toys is unpacked in battery and material documentation for interactive pet toys.
Labels, batch traceability and the listing pack
A label review should confirm manufacturer name and postal address; importer details where applicable; a product identifier (model, batch or serial number); warnings and instructions in the destination market's languages; EU responsible person details where required; and voltage, power and battery markings. Traceability connects a finished unit to its components, suppliers, batch and test records.
Keep a listing pack ready for marketplace requests under Article 22: legal company name and contacts; EU responsible person details; product and batch identification; the DoC and its test reports; label artwork and instructions; listing safety warnings; an incident and recall contact; and a process for removing or correcting the listing. If a platform requests a paper the file lacks, source it or take the listing down — an improvised document is worse than a paused page. The wider timeline sits in our compliance countdown for connected pet device importers.
Recall readiness before you need it
A usable recall plan answers in writing: who decides to recall; who calls the authorities, and through which portal (the EU Safety Business Gateway); who reaches customers, and with which data; what a recalled customer is offered — two remedies at minimum, repair or replacement or refund among them; how the recall is logged and closed; how distributors and marketplaces hear. The notice must name the risk, the affected batch and the action required; a vague quality-issue note fails that test.
The frameworks GPSR does not replace
GPSR sits alongside the sector rules, never in place of them. Depending on the product you may also need RED coverage for the radio side (Wi-Fi, Bluetooth), EMC compliance, the Low Voltage Directive where it bites, RoHS clearance, WEEE registration, UN38.3 and MSDS papers for the battery's journey, and CE marking backed by its declaration of conformity. Market-by-market electrical differences: plugs, voltage and wattage across the US, EU, UK and Australia; the buying sequence: our EU sourcing guide covering CE, GPSR, DDP and MOQ.
Twenty supplier questions, answered in writing
Ask any supplier this list before a purchase order — our export desk answers every line in writing.
| # | Put this to any supplier | What our export desk sends back, in writing |
|---|---|---|
| 1 | Who answers for product safety in the EU? | Our responsible person's name, address, email and signed mandate. |
| 2 | How is each unit identified? | Model code plus our batch and serial format, sample label attached. |
| 3 | Where do those details appear? | On label artwork, carton and accompanying documents. |
| 4 | Can we see the risk analysis behind the design? | Internal risk assessment shared on request, NDA available. |
| 5 | Does a technical file exist at all? | Yes — the index comes first, documents follow against it. |
| 6 | Which EU rulebooks apply? | A per-product list: RED, EMC, RoHS, WEEE, battery rules. |
| 7 | Do reports match this model? | Reports naming the model and version you are quoting. |
| 8 | How current are they? | Date, standard edition and laboratory on every report. |
| 9 | Is there a signed declaration of conformity? | A model-specific DoC issued in our name as manufacturer. |
| 10 | What travels with the battery? | UN38.3 and MSDS with every shipment containing cells. |
| 11 | Which languages carry warnings? | Artwork localised to the destination market's requirements. |
| 12 | Who prints as importer on the label? | The line you agree with us, printed before the run starts. |
| 13 | What happens when a component changes? | A written change notice before the build, not after. |
| 14 | Who watches the product after sale? | A named post-market surveillance owner and their SOP. |
| 15 | How would an accident reach the authorities? | Our Safety Business Gateway route, documented up front. |
| 16 | Can we see the recall procedure? | The recall SOP as a document, not a phone promise. |
| 17 | What customer data could a recall reach? | The order records we can pass on, and their format. |
| 18 | What is a recalled customer offered? | At least two of repair, replacement or refund — policy text included. |
| 19 | Who fixes units after sale? | Our spare-parts and service flow, stocking list included. |
| 20 | Will you confirm all of this before a PO? | A completed, signed checklist returned with the quotation. |
Red flags that should end the conversation
- Nobody holds the EU responsible-person role.
- One CE certificate is offered, but test reports, a DoC and a model list never materialise — or the paper model is not the pallet model.
- The label carries neither an importer line nor batch or serial marking.
- Ask what happens after a component change and the answer trails off, the recall process lives only in someone's head, and every assurance arrives verbally — nothing in writing.
GPSR questions our export desk answers in writing
Who can stand as the responsible person under GPSR? Any economic operator settled in the EU can take the role — but it must be named on the product or packaging, carry the safety-compliance duty, and stay reachable by both customers and market surveillance authorities. A mailbox nobody minds does not qualify.
When a marketplace demands paperwork, what should be ready? Who the seller legally is, who the responsible person is, which product and batch the listing covers, the DoC with its reports behind it, the warnings shown on the page, and a live contact for incidents and recalls — Article 22 lets the platform ask for the whole pack at once.
What does a recall owe the consumer? The regulation asks for two remedies at minimum — repair, replacement, refund, any two of them — unless offering both is impossible or out of all proportion. Settle which two in the recall plan before launch day, not mid-recall.
Sources: Regulation (EU) 2023/988 (OJ L 135, 23.5.2023) on EUR-Lex; applies from 13 December 2024 (Article 51); Articles 16, 9(2) and 22 as cited above; EU Safety Gate and Safety Business Gateway. General procurement information, not legal advice.
Send your model numbers and target market via the inquiry form; our export desk answers all twenty in writing, per model.
