Product Safety Regulation (GPSR): what manufacturers, retailers and craft businesses must do to sell in Germany

The essentials at a glance

• Since 13 December 2024 the Regulation has applied to consumer products of every kind: new, used, repaired or refurbished, in shops as well as online.
• As a manufacturer, you assess the risks of your product before you sell it, record this in technical documentation and keep that documentation for ten years.
• Every product carries a type, batch or serial number and the manufacturer’s contact details, including a postal and an email address. If there is no room, the details go on the packaging or in a document supplied with the product.
• If the manufacturer is based outside the EU, every product needs a responsible business established in the EU, for example the importer or an authorised representative.
• In your online shop and on marketplaces you show the manufacturer, the responsible person where needed, a product photo, the product identifier and the warnings, in German for customers in Germany.
• You report dangerous products and serious accidents through the Safety Business Gateway, an online portal run by the European Commission.
• In Germany, the authorities of the federal states carry out the checks. A breach can cost up to €10,000, and up to €100,000 if corrective action on a dangerous product is not taken.

Which products and businesses does the Regulation cover?

The Regulation covers every product intended for consumers. It also covers products made for professionals if it is foreseeable that private users will use them anyway. Whether you sell the product, give it away or supply it as part of a job makes no difference. All that matters is that you place it on the EU market in the course of business.

If you sell something privately now and then, you are not affected. When sales become commercial depends on the circumstances. The Regulation also does not apply to, among other things:

• medicines for humans and animals, food and animal feed,
• live plants and animals and animal by-products,
• plant protection products,
• means of transport that a service provider operates itself while providing a transport service,
• certain aircraft and
• antiques.

A device that has to be repaired or refurbished before it can be used is not covered either, provided you sell it in that state and clearly label it as needing repair.

When your product has its own EU rules

Many product groups have their own EU rules, for example toys or electrical appliances. In that case the Product Safety Regulation only covers the risks that those specific rules do not address. Its duties for manufacturers, importers and distributors do not apply to such products. The rules on online offers, accident reports and recalls, however, apply to them as well.

Since when has the Regulation applied, and what about stock?

The Regulation has applied directly in every EU country since 13 December 2024. On the same day it replaced the old Product Safety Directive from 2001.

There is a transition rule for stock. Products that were placed on the market before 13 December 2024 and met the old rules may still be sold. Placed on the market means offered on the EU market for the first time. According to the European Commission’s guidelines, this is decided for each individual unit, not for the model. If your supplier first supplied a candle in the EU in January 2025, the new rules apply to that unit, even if the model has been around for years.

According to the Commission, the new labelling duties on the product and packaging do not apply retroactively to such older units. Online offers are different: the Commission applies the required information to every offer made from 13 December 2024. So plan the information for older stock in your shop as well.

The German accompanying rules came later. The amended Product Safety Act of 3 February 2026 has been in force since 19 February 2026. Among other things, it sets the language for safety information, what the authorities may require of online marketplaces and which breaches lead to a fine or a criminal penalty.

Duties as a manufacturer

A manufacturer is anyone who makes a product, or has it designed or made, and sells it under their own name or brand. That includes retailers with an own brand: if you have phone cases made in Asia and sell them under your brand, you are the manufacturer. You also become a manufacturer if you change someone else’s product so much that its safety is affected.

Before you sell a product for the first time, you must:

• assess the product’s risks and draw up technical documentation that describes at least the product and its safety-relevant features,
• keep that documentation current and have it ready for ten years from the sale in case an authority asks to see it,
• in series production, use fixed procedures to make sure every unit is as safe as intended,
• add a type, batch or serial number or another easily readable identifier, or, if that is not possible, put it on the packaging or a document supplied with the product,
• give your name or registered trademark, your postal address and your email address, again on the product or otherwise on the packaging or an insert,
• include clear instructions and safety information in German, unless the product can be used safely without them.

Your work does not end with the sale. You set up a publicly accessible way for customers to report complaints and accidents, such as a phone number, an email address or a form on your website. If someone reports a product as dangerous, you look into it. You record complaints, recalls and corrective measures in an internal register and keep any personal data in it for no more than five years. If you identify a safety problem, you inform the other businesses in your supply chain in good time.

If a product is dangerous, you act at once: you fix the defect, take the product off the market or recall it, inform your customers and report the case through the Safety Business Gateway to the authorities of the EU countries concerned. Our guide to technical documentation explains exactly what belongs in the file.

Duties as an importer

An importer is a business established in the EU that places a product from a country outside the EU on the EU market for the first time. If you buy from a manufacturer in China, Turkey or the US and bring the goods to Germany yourself, you are as a rule the importer. If your own name or brand appears on the product, you even count as the manufacturer.

As an importer, you must:

• before selling, make sure the product is safe and that the manufacturer has carried out the risk assessment, drawn up the technical documentation and added the identifier and contact details,
• hold back a product as long as any of this is missing and, for a dangerous product, inform the manufacturer and, through the Safety Business Gateway, the authorities,
• add your own name or brand, postal address and email address without covering the manufacturer’s details,
• include instructions and safety information in German,
• keep a copy of the technical documentation for ten years,
• check whether the manufacturer’s complaint channels work, set up your own if they do not, and review and record complaints yourself.

If the goods come from a manufacturer outside the EU, you as the importer can also be the responsible person for that product. Our page Responsible person and authorised representative sets out the four possible routes and when an external authorised representative is needed.

Manufacturers outside the EU: the responsible person

Manufacturers outside the EU must also follow the Regulation as soon as they offer their products to consumers in the EU. One extra condition applies to them: their products may only go on the market if a business established in the EU is responsible for them. That can be the importer. If there is none, the manufacturer appoints an authorised representative in writing. A fulfilment service provider is only a last resort.

The name, postal address and email address of this responsible person appear on the product, the packaging, the parcel or an accompanying document, and also in every online offer. The responsible person regularly checks that product, documentation and labelling match, answers questions from the authorities and makes sure accidents are reported.

Grüner Baum GmbH takes on this role as authorised representative for manufacturers outside the EU. Before that, we review the product category, the applicable rules, the technical documentation and the labelling. The role only begins with a written mandate for specific products. Our page Responsible person and authorised representative explains how this works and whether you need an authorised representative at all. Service packages and prices are listed on eugpsr.de.

Duties as a distributor

A distributor is anyone who resells a product without being its manufacturer or importer: the high-street shop, the online shop, the wholesaler. You do not have to draw up technical documentation. You do have to look carefully, though:

• Before selling, check that the product identifier, the contact details of the manufacturer and, where relevant, the importer, and the instructions and safety information in German are present.
• Make sure that storage and transport do not affect safety or labelling.
• If something is missing or you doubt the product’s safety, do not sell it until the problem has been fixed.
• If a product you have already sold turns out to be dangerous, inform the manufacturer or importer at once, make sure the problem is remedied and see that the authorities are told through the Safety Business Gateway.

In day-to-day practice, a short check of incoming goods against these points helps; file the result with the delivery note. If you hear of an accident involving a product you sell, tell the manufacturer. The manufacturer either reports the accident or asks you to make the report.

Online offers: the four required details

If you sell online, whether in your own shop, on a marketplace or through any other channel without face-to-face contact, every offer must show these details clearly and visibly:

• the manufacturer’s name or registered trademark and its postal and email address,
• if the manufacturer is not established in the EU: the name, postal address and email address of the responsible person in the EU,
• information that identifies the product: a photo, the type of product and other identifiers such as the model or batch number,
• the warnings and safety information that also appear on the product or packaging or come with it.

For customers in Germany, warnings and safety information must be in German. Missing details in an offer are an administrative offence that can lead to a fine.

An example: for a scented candle, the offer shows the manufacturer with address and email, a photo, the item number and warnings such as “Never leave a burning candle unattended”. The duty applies as soon as you direct your offers at customers in one or more EU countries. Our guide Labelling online offers correctly shows how to set up the details for each sales channel.

Online marketplaces: what the platforms must do

Operators of online marketplaces have duties of their own. They name one contact point for the authorities and one for consumers, and they register in the EU’s Safety Gate portal. If an authority orders an offer to be removed, blocked or given a warning, the platform must act at once and within two working days at the latest. It deals with product safety notices within three working days. In Germany, the market surveillance authorities are expressly empowered to issue such orders.

For you as a seller, this means: the platform must provide fields for the manufacturer details, the responsible person, the product identifier and warnings, and display them to customers. What goes into those fields, however, is your responsibility. Sellers who repeatedly offer products that breach the Regulation are suspended for a reasonable period after a warning. In a recall, the marketplace also informs the customers who bought the product there directly.

Reporting accidents: the Safety Business Gateway

If a person dies because of a product or suffers serious health effects, whether permanent or temporary, the manufacturer makes sure the accident is reported without delay. The report goes to the authorities of the EU country where the accident happened and is made through the Safety Business Gateway, a web portal of the European Commission for businesses. It states the type and identification number of the product and the known circumstances.

Importers and distributors who learn of such an accident inform the manufacturer at once. The manufacturer reports it or asks them to make the report. If the manufacturer is outside the EU, the responsible person takes care of it. In Germany, failing to report can lead to a fine.

So decide in advance who in your business operates the portal and who makes the call in an emergency. You use the same portal to report products that turn out to be dangerous.

Recalls: informing customers and offering a remedy

When a recall is due, write to every affected customer you know of, straight away and personally. You often already have their addresses, for example from orders or customer accounts. If some buyers are unknown, make the recall public as well: on your website, on social media, in your newsletter and in your shop, including in an accessible format.

The written recall notice follows a fixed structure. Its heading is “Product safety recall”; it describes the product with a photo, identification numbers and sales details, states the hazard clearly and tells people to stop using the product immediately. Reassuring words such as “voluntary”, “precautionary” or “in rare situations” do not belong in it. You will find an outline ready to use further down under Templates.

The remedy has to work, cost the customer nothing and come quickly. The choices are a repair, a safe replacement of the same type or money back, at least the purchase price, and customers can normally pick from at least two of these three. Offering only one is allowed only if the other two are not feasible or would cost far too much in relation. If the repair or replacement takes too long, customers are always entitled to a refund. They pay no postage, and you collect bulky products.

Craft businesses, one-offs and made-to-measure products

There is no exemption for small businesses, handmade goods, small batches or one-offs. A joinery, goldsmith, pottery, tailor or workshop that makes a product and supplies it to consumers under its own name is a manufacturer. This also applies to commissioned work: the service itself is not covered by the Regulation, but the product delivered is.

How much effort is needed, however, depends on the risk:

• The technical documentation describes at least the product and its safety-relevant features. You only need a detailed risk analysis with test reports and a list of standards to the extent the possible risks justify it. For a dining table, the documentation is therefore usually shorter than for a cot.
• You only need fixed procedures for series production if you actually produce in series.
• For one-offs, another easily readable identifier is enough, such as an order or piece number. If there is no room on the product, it may go on the packaging or an accompanying document.
• Your name, postal address and email address belong on the product. Only if that is not possible may they go on the packaging or a product sheet supplied with it.

If you repair or alter a customer’s product on their behalf and for their own use, that does not make you the manufacturer. It can be different if you rebuild used products on your own account, then sell them, and the type or level of risk changes in the process.

Works of art fall under the exemption for antiques if buyers cannot reasonably expect them to meet today’s safety standards. This means objects created solely for artistic purposes. A handmade mug, bowl or candle is therefore not exempt just because of its design.

B2B: when professional products end up with consumers

The Regulation protects consumers, but it does not stop at the boundary of B2B business. It also applies to products intended for professionals if consumers will foreseeably use them anyway. This expressly includes products that were originally designed only for professional use and later reached the consumer market. The European Commission gives the example of renovation and building products that DIY stores sell to private customers.

So ask yourself honestly who ends up buying your goods. An online shop with no proof of trade status, a marketplace offer open to anyone or sales to end customers in a shop all suggest that consumers will use the product. Even as a wholesaler who only supplies resellers, you are a distributor under the Regulation as soon as a consumer product is involved.

Purely professional products that only go to businesses and that consumers will foreseeably not use are outside the Regulation. In Germany, the general requirements of the Product Safety Act can apply to them. In a recall, the Commission recommends informing business customers too, especially micro and small enterprises that act like consumers.

Used, repaired and refurbished goods

The Regulation expressly applies to used, repaired and refurbished products as well. Second-hand shops, refurbishers, trade-in platforms and retailers reselling returns therefore have the same duties as when selling new goods, to the extent those duties fit their role. Exempt are products that must be repaired or refurbished before use and are clearly sold as such, as well as collectors’ items of historical importance.

For goods that first reached the EU market before 13 December 2024, the new labelling duties on the product do not apply retroactively, according to the Commission. Your online offers still need the required details. So find out who the manufacturer is when you buy the goods in. Anyone who substantially changes a used product before selling it can become its manufacturer.

Who enforces the rules in Germany, and what does a breach cost?

The market surveillance authorities of the federal states are responsible. In Rhineland-Palatinate this is the trade supervisory authority (Gewerbeaufsicht); at the Struktur- und Genehmigungsdirektion Süd it includes the regional offices in Mainz and Neustadt. The states take samples every year and work to a benchmark of 0.5 samples per 1,000 inhabitants. The authorities can ban or restrict the sale of a product and order a withdrawal or a recall.

You risk a fine if you breach the Regulation intentionally or negligently, for example if:

• the risk assessment or technical documentation is missing or incomplete,
• the product identifier or contact details are missing,
• instructions and safety information are not available in German,
• there is no complaint channel or complaint register,
• required details are missing from an online offer or
• a serious accident is not reported.

The fine is at most €10,000; if a manufacturer or importer fails to make sure the necessary corrective action is taken on a dangerous product, it can reach €100,000. In these cases the administrative offence becomes a crime if someone does it deliberately again and again or puts people or valuable property of others at risk. A fine or up to one year in prison is then possible.

It is worth going through your processes calmly once; the checklist below helps. You can also ask the authorities, free of charge, for specific information on how the Regulation is applied in Germany.

Warning letters from competitors and associations (Abmahnung)

If labels or required details are missing, competitors and associations can send you a formal warning letter (Abmahnung), which can cost money; whether a warning letter is justified in a particular case is for the courts to decide.

If you receive one, do not sign the enclosed cease-and-desist declaration without checking it. Have a lawyer review its content and deadline, and quickly fix any genuine defect in your offer.

Step by step: a checklist for your business

1. Go through your range: which products do consumers buy, or which will consumers foreseeably use? Do specific EU rules or an exemption apply to any of them?
2. Clarify your role for each product: manufacturer (including own brand), importer or distributor.
3. For imported goods, decide who the responsible person in the EU is, and put it in writing.
4. As a manufacturer, draw up the risk assessment and technical documentation; as an importer, request a copy; keep everything for ten years.
5. Check the labelling: type, batch or serial number and the name, postal address and email address of the manufacturer and, where relevant, the importer.
6. Provide instructions and safety information in German.
7. Add the four required details to every online offer, including on marketplaces.
8. Set up a complaint channel and keep a register of complaints, recalls and corrective measures.
9. Note for every product who supplies it to you and which businesses you supply it to, so you can show this for six years.
10. Decide who handles reports in the Safety Business Gateway.
11. Prepare a recall plan: customer data, recall notice, remedy offer.
12. Write down your internal product safety procedures and review them for new products or changes.

Templates you can use

Outline of the technical documentation

1. A general description of the product and its safety-relevant features (always needed).
2. Which risks the product may present and how you have removed or reduced them, with the results of your own or commissioned tests (as far as the risks require).
3. A list of the European standards and other assessment criteria applied; if applied only in part, which parts (where appropriate).
4. Recommended: a dated change log showing that you keep the documentation up to date.

Outline of a recall notice

The notice must be easy to understand and available in the languages of the EU countries where the product was sold. It contains:

1. Heading: “Product safety recall”.
2. Product: photo, name and brand; batch or serial number and, where helpful, a graphic showing where to find it; when, where and by whom the product was sold, if known.
3. Hazard: a clear description, without words such as “voluntary”, “precautionary”, “discretionary”, “in rare situations” or “in specific situations”, and without saying that no accidents have been reported.
4. What customers should do: “Stop using the product immediately.” and the next steps.
5. Remedy: the options offered (repair, replacement or refund), free of charge and without shipping costs for customers.
6. Contact: a free phone number or an interactive online service.
7. A request to pass the information on to others who might use the product.

The European Commission can lay down a standard template for recall notices. Before a recall, check whether one exists, and if so, use it.

Frequently asked questions about the Product Safety Regulation

Questions about your products?

Grüner Baum GmbH of Oppenheim, Germany, helps businesses with questions about the Product Safety Regulation. If you are unsure which role your business has or what applies to a particular product, write to us at info@gruner-baum.de or use the contact details on our home page.

Do you manufacture outside the EU and need a responsible person in the EU? Grüner Baum GmbH takes on this role after reviewing your products. Describe your plans in the form below, or first read how the mandate works. Detailed service descriptions are available on eugpsr.de.

Legal basis and sources

For every topic in this guide, this table gives the exact legal reference with a link to the official text. References as of 5 October 2026.

GPSR knowledge from Grüner Baum GmbH

Three deeper guides: on the responsible person, the technical documentation and the details every online listing must show.