GPSR for US Sellers: What Changes When You Ship to the EU (2026)

If you are a US-based seller and your listings started getting deactivated in EU markets, you have run into the General Product Safety Regulation (Regulation (EU) 2023/988, GPSR), which has applied since 13 December 2024.

The important thing to understand first: being outside the EU does not exempt you — it makes your obligations heavier than an EU seller's. This guide covers what is actually different for a US seller, in the order it costs you money.

The one requirement you cannot do yourself

Article 16 GPSR requires a responsible economic operator established in the EU for every product offered to EU consumers. An EU address is not optional paperwork; without one, marketplaces are required to stop showing your listing.

An EU seller usually fills this role themselves — they are the manufacturer or the importer, and they are already established in the EU. A US seller cannot. Your options:

Option	Works when	Rough cost
Your EU importer	You sell wholesale to an EU business who imports	Free — they already are the operator
Your own EU entity	You have a subsidiary or branch in an EU member state	Cost of maintaining the entity
A paid EU Responsible Person service	You ship direct to EU consumers (Etsy, Amazon, your own store)	Typically €150–400/year, varies by provider and product count
A fulfilment service provider in the EU	Only if they accept the Article 4 duties in writing	Varies; most do not accept them by default

That last row is where sellers lose the most time. Using Amazon FBA in Europe does not make Amazon your Responsible Person. Warehousing your goods is not the same as accepting the legal duties of the responsible operator. You appoint the operator yourself, and then you enter their details in Seller Central.

If you are comparing providers, we maintain a breakdown of what an EU Responsible Person costs with verified pricing.

What you must put on the listing

Once you have an EU operator, Article 19 GPSR requires that the offer itself shows, before purchase:

• Manufacturer — name, postal address, and electronic address. If you make the product, or sell it under your own brand, that is you.
• The EU responsible operator — name and contact details, including postal and electronic address.
• Product identification — a picture, type, batch or serial number.
• Safety warnings and information — in a language the consumer in that country easily understands.

That last point is the one US sellers underestimate. "In English" is not automatically sufficient. If you sell into Germany, the warning that matters is the German one. This is a per-market requirement, not a per-seller one.

Where you enter this depends on the platform — see Amazon's EU compliance fields, GPSR for Etsy sellers, eBay or Shopify.

What you must have but never upload

Article 9(2) GPSR requires manufacturers to run an internal risk analysis and keep technical documentation for ten years. No marketplace asks you to upload it. That is exactly why it gets skipped — and why it becomes a problem only when an authority asks, at which point you cannot produce it retroactively with any credibility.

If you sell under your own brand, you are the manufacturer under GPSR even when a factory in another country physically makes the product. Private label does not make you a distributor.

• How to build the risk assessment · free generator
• What goes in the technical file · free generator

What does not apply to you

This section saves US sellers the most money, because most of what gets sold to them here is unnecessary.

• There is no GPSR certificate, GPSR registration or GPSR seal. No body issues one. Anyone selling you certification "for GPSR compliance" is selling something that does not exist.
• CE marking is not a GPSR requirement. GPSR is the safety net for products that fall outside specific CE legislation. If your product is a toy or an electronic device, CE rules apply to it separately — but not because of GPSR.
• An EU Declaration of Conformity is usually not required. It belongs to CE-scope product legislation. For a candle, a tote bag or a piece of jewelry, there is normally nothing to declare. Check first: when you actually need a Declaration of Conformity.
• UK sales are a separate regime. Since Brexit, selling to Great Britain does not put you under GPSR, and an EU Responsible Person does not cover you there. Northern Ireland is treated differently again.
• You do not need an EU company. An EU Responsible Person is a service you appoint, not an entity you incorporate.

Does this apply to handmade and small volumes?

Yes. GPSR has no minimum turnover, no small-seller exemption and no handmade exemption. A single candle shipped from Ohio to a buyer in Belgium is a product placed on the EU market.

What does scale with size is effort, not obligation: the risk analysis for one simple product is a short document, and your own business details often cover the manufacturer fields. The unavoidable fixed cost for a US seller is the EU Responsible Person.

Order of operations if you start today

1. Decide whether you still want EU sales. For some low-margin sellers, the annual Responsible Person cost exceeds their EU revenue. That is a legitimate answer — and cheaper to reach now than after a suspension.
2. Appoint an EU Responsible Person and get their name, postal address and electronic address in writing.
3. Fill in the listing fields on every marketplace you sell on, including safety warnings in the destination language.
4. Build the risk assessment and technical file, starting with your best sellers.
5. Keep the file current when you change suppliers or materials. A file that does not track your product is worth nothing when it is needed.

Official sources: Regulation (EU) 2023/988 (GPSR) · Regulation (EU) 2019/1020 (market surveillance) · EU Safety Gate

General information, not legal advice. Which obligations apply to your product depends on its category and your role in the supply chain.

Check your product and generate the documents — €14