GPSR for Marketplace Sellers

Marketplaces sit inside the General Product Safety Regulation rather than alongside it. Amazon, eBay, Etsy and their peers carry obligations of their own, and they meet them by verifying seller data before listings reach European buyers. Through 2026 that verification has widened: where the first checks looked for responsible person details, later rounds have reached labelling, safety information in the listing and requests for underlying documentation.

The practical consequence for sellers is that platform compliance and legal compliance have converged. Details entered in Seller Central satisfy the platform; the same details on the physical packaging and a technical file behind them satisfy the regulation.

What the regulation asks

The GPSR has applied since 13 December 2024 and covers every consumer product reaching the European market, whether through a physical shop, a webshop or a marketplace. It reaches manufacturers, importers, distributors, fulfilment service providers and the marketplaces themselves.

At its centre sits one structural requirement: for each product placed on the EU market there is a party established in the Union who answers for it. That party is the manufacturer where the manufacturer sits inside the EU, the importer where goods enter through one, or an authorised representative appointed for the purpose. Their name and contact details appear on the product or its packaging and in the online listing.

Article 16 gives the role real content. The responsible person verifies that the technical documentation and risk assessment exist and remain current, holds that documentation available for ten years, serves as the point of contact for market surveillance authorities, and cooperates where corrective action becomes necessary. Recall remedies offer the consumer a choice of at least two options among repair, replacement and refund.

What marketplace sellers put in place

• A responsible person established in the EU, whose name and contact details appear in the listing and on the product or its packaging.
• A risk assessment and technical file per product or product family, held available for ten years.
• Traceability, with a precise batch or serial identifier on each unit.
• Safety information in the language of each Member State where the product is offered.

Physical labelling and listing data are examined separately, so a product that passes the platform check keeps its labelling reviewed on its own merits.

Where an own entity changes the picture

Appointing a third-party representative covers the requirement. Establishing a Dutch BV places it inside your own business, which matters once volume grows: the entity acts as importer of record, holds the technical files under your own control, carries the Article 23 licence that defers import VAT to the periodic VAT return, and takes on the EPR registrations that follow under the Packaging Regulation.

Sellers using fulfilment services inside the Union find the second route particularly natural, since goods already move through EU warehouses and an EU importer of record aligns the paperwork with the physical flow.

Two routes, one decision

Sellers established outside the Union reach compliance along one of two routes. Appointing an authorised representative established in the EU covers the requirement directly and quickly. Incorporating your own Dutch BV places the role inside your own group: the BV acts as importer, holds the technical files, carries the Article 23 import VAT deferment licence and serves as your base for the wider set of obligations that follow, from packaging under the PPWR to EPR registrations across Member States.

Our guide to choosing between a representative and your own entity sets out how sellers usually decide, and at what point the second route begins to pay for itself.

Frequently asked questions

Do Amazon sellers need an EU responsible person?

Where consumer products reach EU buyers, yes. Marketplaces verify the details before a listing reaches European customers, and the same name and contact details appear on the product or its packaging.

What happens when listing details and packaging differ?

Physical labelling and online listing data are examined separately. Keeping both consistent, and matching the technical file behind them, is what holds up under both platform checks and market surveillance requests.

Can a fulfilment provider act as responsible person?

Fulfilment service providers carry their own obligations under the GPSR. The responsible person role is held by an EU manufacturer, an EU importer, an appointed authorised representative or the seller's own EU entity, established by written mandate or by establishment.

Does one responsible person cover every marketplace?

Yes. The role attaches to the product and the party established in the Union, so a single arrangement serves listings across Amazon, eBay, Etsy and any other channel reaching EU buyers.