Does GPSR apply to all products sold on Amazon in the EU?

GPSR applies to all consumer products on the EU market, except those covered by sector-specific legislation (food, pharmaceuticals, medical devices, motor vehicles). General consumer goods including electronics, home products, clothing, and toys are covered.

Can I use one Responsible Person for all EU marketplaces?

Yes. A Polish company as Responsible Person is valid across the entire EU — the same name and address work on Amazon, eBay, Allegro, and any other EU sales channel.

Do I need to test every product under GPSR?

Not necessarily. The level of testing depends on the product category and applicable EU standards. Products under harmonised standards need formal testing. For general consumer goods, a documented risk assessment and supplier certifications may be sufficient.

Can a Polish company serve as GPSR Responsible Person?

Yes. A Polish sp. z o.o. can serve as Responsible Person either as importer of record or as the manufacturer's authorised representative, with a physical EU address meeting GPSR requirements.

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Q: What happens if I sell on Amazon EU without GPSR compliance?

Amazon may suppress or remove your listings. Market surveillance authorities can order product withdrawal, impose fines, or require recalls. Both commercial and legal consequences apply.

Since December 2024, every consumer product sold in the European Union must comply with the General Product Safety Regulation (GPSR). For non-EU sellers — particularly those selling through Amazon, eBay, Allegro, or their own e-commerce stores — the most immediate impact is the requirement to have a Responsible Person with a physical EU address displayed on the product, its packaging, or its accompanying documentation.

Without this, EU marketplaces can restrict or remove your listings. Amazon has already begun enforcing GPSR requirements across its European storefronts. This guide explains what GPSR requires, who it affects, what the Responsible Person role involves, and how a Polish company can serve as your GPSR-compliant EU presence.

What Is GPSR

GPSR stands for the General Product Safety Regulation — EU Regulation 2023/988. It replaced the older General Product Safety Directive (GPSD) and became applicable on 13 December 2024. The regulation applies to all consumer products placed on the EU market, with the exception of products already covered by sector-specific EU legislation (such as food, pharmaceuticals, and medical devices, which have their own safety frameworks).

The core principle of GPSR is simple: every consumer product available in the EU must be safe, and there must be an identifiable party in the EU who is responsible for ensuring that safety. This is where the concept of the Responsible Person becomes critical for non-EU businesses.

Who Is Affected

GPSR applies to every economic operator in the product supply chain. The regulation defines four roles:

Manufacturer: The entity that designs and produces the product (or has it produced) and places it on the EU market under their name or brand
Authorised Representative: An entity established in the EU, designated by the manufacturer to act on their behalf for specific GPSR tasks
Importer: The EU-established entity that brings a product from outside the EU into the EU market
Distributor: Any entity in the supply chain that makes the product available on the EU market without being the manufacturer or importer

For non-EU Amazon sellers, the most common scenario is: you manufacture (or source) products outside the EU and sell them to EU consumers through Amazon or another marketplace. Under GPSR, you need either an EU-based importer or an authorised representative — collectively referred to as the Responsible Person — with a physical EU address.

The Responsible Person Requirement

This is the GPSR requirement with the most immediate operational impact. Every product sold to EU consumers must have a Responsible Person who:

Has a physical address in the EU (not a PO box, not a virtual address without mail handling)
Is identified on the product, packaging, or accompanying document — with their name and postal address
Can be contacted by market surveillance authorities and consumers
Takes responsibility for verifying that the product has the required safety documentation (technical file, risk assessment, test reports where applicable)
Cooperates with authorities in case of product recalls or safety issues

The Responsible Person is not required to physically test every product or guarantee its safety — that obligation remains with the manufacturer. However, they must verify that the manufacturer has fulfilled their obligations (technical documentation, conformity assessment) and must be available as the EU point of contact.

What Must Appear on the Product

GPSR requires the following information to be displayed on the product, its packaging, or an accompanying document:

Name and address of the manufacturer (or the entity placing the product on the market)
Name and address of the Responsible Person in the EU (if the manufacturer is outside the EU)
Product identification: type, batch, serial number, or other identifier allowing traceability
Warnings and safety information in the language(s) required by the member state where the product is sold

For Amazon sellers, this information typically appears on the product label, packaging, or on a document inside the package. Amazon may also require this data in Seller Central as part of your product listing compliance.

How Amazon Enforces GPSR

Amazon has been progressively enforcing GPSR compliance across its European marketplaces since December 2024. The enforcement affects all Amazon storefronts in the EU — Amazon.de, Amazon.fr, Amazon.it, Amazon.es, Amazon.pl, Amazon.nl, Amazon.se, and Amazon.be.

What Amazon Requires

Amazon requires sellers to provide Responsible Person information in Seller Central for products sold on EU marketplaces. This includes:

Responsible Person company name
Physical EU address (street, city, postal code, country)
Contact email and/or phone number
The relationship to the product (manufacturer, importer, or authorised representative)

If this information is missing or incomplete, Amazon may:

Suppress your listings — products become invisible to buyers
Remove your listings entirely — products deleted from the catalogue
Restrict your selling privileges on EU marketplaces

Amazon has stated that it may begin automated enforcement — meaning listings without valid Responsible Person data could be flagged and removed without manual review.

Other Marketplaces

GPSR is not Amazon-specific — it applies to all products sold to EU consumers regardless of the sales channel. Other major marketplaces including eBay, Allegro, Etsy, and Kaufland have implemented or are implementing similar compliance requirements. If you sell on multiple platforms, the same Responsible Person data applies across all of them.

How a Polish Company Solves GPSR

A Polish sp. z o.o. (limited liability company) can serve as the Responsible Person under GPSR. Here is how this works in practice.

As Importer of Record

If your Polish company imports goods from outside the EU (e.g., from China, Turkey, or India) and places them on the EU market, it automatically qualifies as the importer under GPSR. The importer is one of the recognised categories of Responsible Person. Your company’s name and registered address in Poland appear on the product packaging as the EU Responsible Person.

This is the most common GPSR structure for Amazon FBA sellers and import/export companies: your Polish entity imports the goods using its EORI number, clears them through customs, and serves as both the importer of record and the GPSR Responsible Person.

As Authorised Representative

If you do not want your Polish company to act as the importer (e.g., goods are imported through another EU country or by a third-party logistics provider), the Polish company can be designated as the manufacturer’s authorised representative under GPSR. This requires a written mandate from the manufacturer, specifying the tasks the representative is authorised to perform.

What Your Polish Company Needs

To serve as GPSR Responsible Person, your Polish company needs:

Active KRS registration — the company must be a valid legal entity
Physical registered address in Poland — not a PO box. The address must be able to receive correspondence from market surveillance authorities. Both LEXCARTA formation packages include a registered address that meets this requirement.
EORI number — if acting as importer of record (included in LEXCARTA packages)
Product documentation on file — the manufacturer’s technical documentation, test reports, and conformity declarations must be accessible through the Responsible Person

GPSR Compliance Obligations

Being the Responsible Person under GPSR is not just about having an EU address on the label. The role carries specific obligations.

Documentation

The Responsible Person must ensure that the following documentation is available and can be provided to market surveillance authorities upon request:

Technical documentation — description of the product, materials, manufacturing process
Risk assessment — identification and evaluation of potential safety risks
Test reports — from accredited testing laboratories, where applicable to the product category
EU Declaration of Conformity — if the product falls under harmonised EU standards (e.g., CE marking for electronics, toys, machinery)
Traceability records — supply chain documentation showing where the product was manufactured and how it reached the EU market

The documentation must be kept for 10 years after the product was last placed on the market. For ongoing sellers with multiple product lines, this means maintaining an organised archive of safety documentation for every SKU.

Product Recalls and Safety Issues

If a product is found to be unsafe or non-compliant, the Responsible Person must:

Cooperate with market surveillance authorities (in Poland: UOKiK — the Office of Competition and Consumer Protection)
Notify the authorities about unsafe products through the Safety Gate (formerly RAPEX) system
Take corrective measures — which may include product recall, withdrawal from the market, or modification
Inform consumers about the safety issue and the corrective measures taken

In practice, product recalls for small and medium sellers are rare. But the obligation to cooperate with authorities is real and cannot be ignored. Having a properly structured EU entity — rather than a virtual address service — ensures your company can respond to regulatory inquiries credibly.

Marketplace Communication

Under GPSR, online marketplaces (Amazon, eBay, Allegro) have their own obligations — including the ability to contact the Responsible Person and to remove non-compliant products. Your company must be responsive to marketplace inquiries about product safety. An unresponsive Responsible Person risks having listings suspended not just on one marketplace, but across all EU platforms.

Common Mistakes

Using a Virtual Address Without Substance

Some sellers try to comply with GPSR by listing a cheap virtual address in the EU. This is risky. Market surveillance authorities can — and do — visit the Responsible Person’s address. If nobody is there and there is no evidence of a real business presence, the authorities can consider the GPSR obligation unfulfilled. A virtual office with mail handling is a starting point for labelling purposes, but depending on your product category and sales volume, you may need dedicated premises where product documentation is physically accessible and where authorities can conduct an inspection.

Using a Third-Party GPSR Service Without a Company

Several services now offer “GPSR Responsible Person” as a standalone product — you pay a monthly fee and they put their address on your label. This can work for some sellers, but it has limitations. You have no control over the entity, you depend on a third party’s continued operation, and if they discontinue the service or increase prices, you must relabel all your products. Having your own EU company as the Responsible Person gives you full control.

Ignoring Product Documentation

Putting an EU address on the label is necessary but not sufficient. GPSR requires the Responsible Person to have access to product safety documentation. Sellers who list a Responsible Person address but have no technical file, no risk assessment, and no test reports are technically non-compliant — even if Amazon accepts the listing. In a market surveillance check, the lack of documentation creates serious liability.

Not Updating Amazon Seller Central

Some sellers update their product packaging but forget to add Responsible Person data in Amazon Seller Central. Amazon’s enforcement checks the Seller Central data independently of what appears on the physical product. Both must be complete and consistent.

GPSR and Your LEXCARTA Company

LEXCARTA provides the legal infrastructure that enables GPSR compliance — the EU entity itself, not product safety services. Specifically:

Your Polish sp. z o.o. can serve as GPSR Responsible Person — either as importer of record or as authorised representative
EORI number already active on ready-made companies — required if your company acts as importer
Legal advisory on the corporate and regulatory aspects of GPSR compliance

Important Note About the Registered Address

The registered address included in LEXCARTA formation packages is a virtual office — it handles mail and official correspondence, and is fully sufficient for company registration, KRS, and tax purposes. However, GPSR may require the Responsible Person to be reachable at a physical location where market surveillance authorities can conduct inspections or retrieve product documentation.

A virtual office address may satisfy the GPSR labelling requirement (name + EU address on the product), but if your operations grow or authorities require physical access to documentation, you may need dedicated premises. LEXCARTA can assist in finding a suitable office or warehouse space in Poland if your business requires it.

What LEXCARTA Does Not Provide

Product safety documentation — technical files, risk assessments, test reports, CE marking — is your responsibility as the product manufacturer or seller. LEXCARTA does not provide product testing, safety certification, or product compliance consulting. For these services, you should work with a specialised product compliance consultant or accredited testing laboratory. We provide the EU legal entity, corporate compliance, and legal advisory — not product safety services.

If you are an Amazon seller or e-commerce operator who needs an EU entity for GPSR compliance, check your eligibility or schedule a consultation.

For more on setting up an e-commerce entity in Poland, visit our Amazon & E-Commerce service page or read our guide on Amazon FBA company setup in Poland.

Frequently Asked Questions

Does GPSR apply to all products?

GPSR applies to all consumer products placed on the EU market, with exceptions for products already covered by sector-specific EU legislation — such as food, pharmaceuticals, medical devices, and motor vehicles. If your product is a general consumer good (electronics accessories, home products, clothing, toys, cosmetics, etc.), GPSR applies.

Can I use the same Responsible Person for all EU marketplaces?

Yes. Your Polish company as Responsible Person is valid across the entire EU. The same name and address can be used on Amazon.de, Amazon.fr, eBay, Allegro, and any other marketplace or direct sales channel in the EU.

What if I already have an EU company?

If your existing EU company imports the products, it already qualifies as the Responsible Person (as importer). You only need to ensure the company’s name and EU address appear on the product/packaging and that you have the required documentation on file.

Do I need to test every product?

Not necessarily. GPSR requires a risk assessment and appropriate safety documentation — the level of testing depends on the product category and applicable EU standards. Products that fall under harmonised standards (e.g., electronics requiring CE marking) need formal testing. For general consumer goods, a documented risk assessment and supplier certifications may be sufficient. Consult with your product compliance advisor.

What happens if I do not comply with GPSR?

Marketplaces (Amazon, eBay, Allegro) may remove your listings. Market surveillance authorities can order product withdrawal, impose fines, or require a recall. The Responsible Person — your EU company — bears legal responsibility for cooperation with authorities and corrective measures. Non-compliance creates both commercial risk (lost sales) and legal liability.