What Changed When the GPSD Was Replaced by the GPSR
The General Product Safety Directive had been in force since 2001. For many non-EU manufacturers, it had become background noise: a set of general safety obligations that their EU importers or distributors handled as part of the normal compliance routine. Enforcement varied by country, and the practical burden on the manufacturer was often minimal.
On December 13, 2024, Regulation (EU) 2023/988 replaced it. Unlike a directive, a regulation applies directly across all EU member states without national transposition. The obligations are the same in Germany, Poland, and Spain from day one, and they land on manufacturers, not just on whoever is handling the import.
If your process hasn’t changed since 2024, this post covers what’s different and what it means for you specifically.
What the GPSD actually covered
The GPSD established a general safety requirement for consumer products: any product placed on the EU market had to be safe. That sounds straightforward, but the directive left substantial room for national interpretation. Each member state transposed it into domestic law differently, enforcement priorities varied, and the practical obligations for non-EU manufacturers were often diffuse.
The directive predated e-commerce as we know it. Online marketplaces barely featured. Traceability requirements were light. The Safety Gate system (then called RAPEX) existed but operated with less structured reporting obligations than what the GPSR now requires.
Why the GPSR is a different instrument
The shift from directive to regulation removes the transposition layer entirely. The GPSR is the law, directly, in every EU member state simultaneously.
The practical effect for a non-EU manufacturer is that there is no longer a country-by-country variation to navigate or exploit. A product that fails to meet GPSR requirements fails everywhere in the EU at once, and market surveillance authorities across member states operate under the same framework.
The GPSR also explicitly addresses online sales. Marketplaces now carry defined obligations, and products sold through them are subject to the same rules as products sold through traditional distribution channels.
What the GPSR adds that the GPSD didn’t require
Several obligations in the GPSR are genuinely new, not just clarifications of what the GPSD already implied.
Responsible Person inside the EU. Non-EU manufacturers must appoint a Responsible Person established in the EU before placing products on the market. This person holds specific legal accountability for product safety documentation and acts as the point of contact for market surveillance authorities. The role carries more defined obligations than the old importer model under the GPSD.
Documented risk assessment. The GPSR requires manufacturers to prepare and maintain a formal risk assessment for each product. This is a specific document, not a general internal safety review. It must identify the risks the product presents, the measures taken to address them, and the standards or technical specifications applied.
Stronger traceability requirements. The GPSR tightens the chain of accountability from manufacturer to end consumer. Products must be traceable, and the obligations on each economic operator in the supply chain are more precisely defined than under the GPSD. For non-EU manufacturers selling through EU importers and distributors, understanding where your obligations end and theirs begin matters more than it used to. The full breakdown of what the GPSR requires from importers specifically is covered in our post on GPSR importer traceability obligations.
Safety Gate reporting. The GPSR strengthens the Safety Gate system and expands the reporting obligations around dangerous products and accidents. Recalls are more structured, and the requirements for notifying authorities are more specific than what the GPSD mandated.
How harmonised standards work under the GPSR
The GPSR uses harmonised standards to establish a presumption of conformity, the same mechanism that applies under CE marking directives. A product manufactured in accordance with a relevant harmonised standard is presumed to meet the general safety requirement of the GPSR.
This gives manufacturers a practical compliance path: identify the applicable harmonised standards for your product category, apply them, and document it. The standards don’t cover every product type, but where they exist, they provide the clearest route to demonstrating compliance. For a more detailed explanation of how this mechanism works and which standards currently apply, see our post on GPSR harmonised standards and the presumption of conformity.
CE marking and the GPSR: two separate frameworks
A common assumption among non-EU manufacturers is that CE marking covers their product safety obligations in the EU. For many product categories it does, but CE marking and the GPSR operate under different frameworks and cover different scopes.
The GPSR applies to consumer products not covered by specific sector legislation that already addresses safety. If your product carries CE marking under a directive like the Low Voltage Directive or the Machinery Regulation, that specific legislation governs your safety obligations, and the GPSR steps back. However, products that sit outside CE marking requirements, or that have aspects the applicable CE marking directive doesn’t fully address, may still fall under the General Product Safety Regulation.
The clearest cases are examples of products not subject to CE marking: furniture, clothing, sports equipment, personal care appliances. These carry no CE marking obligation, but the GPSR applies to them in full.
The full text of Regulation (EU) 2023/988 is available on EUR-Lex for manufacturers who want to review the legislative text directly.
What to do if you haven’t reviewed your process since 2023
The December 2024 application date has passed. If you sell consumer products in the EU and your compliance process still reflects GPSD-era obligations, the gap between what you have and what the GPSR requires is worth assessing now, before a market surveillance authority does it for you.
The most common gaps for non-EU manufacturers are the Responsible Person appointment, the risk assessment documentation, and the traceability chain.
Those three cover most of the practical exposure.
If you want to understand where your products stand under the GPSR, get a quote and we’ll walk through it with you.
