GPSR and EPR Explained for EU Marketplaces

Selling into the European Union now comes with two sets of paperwork that marketplaces actively check. The first is product safety, governed by the General Product Safety Regulation (GPSR). The second is extended producer responsibility (EPR): national rules that make whoever puts packaging, electricals, batteries and other goods on a market pay for their collection and recycling.

Both apply to non-EU sellers shipping to EU consumers, and missing details can get listings blocked. This guide is general information, not legal advice; for your own products, check the official texts or speak to a qualified adviser.

GPSR at a glance

The GPSR is Regulation (EU) 2023/988. It has applied since 13 December 2024, replacing the older General Product Safety Directive. As a regulation, it applies directly in every member state.

It covers consumer products sold online and offline, whether new, used, repaired or refurbished. Products already covered by specific EU safety laws, such as toys or electrical equipment, still follow those laws; the GPSR fills the gaps.

The responsible economic operator in the EU

The most visible change for overseas brands is Article 16. A product covered by the regulation cannot be placed on the EU market unless an economic operator established in the EU is responsible for it. That operator can be:

• a manufacturer established in the EU;
• an importer, where the manufacturer is outside the EU;
• an authorised representative appointed in writing by the manufacturer; or
• a fulfilment service provider, but only where none of the above is established in the EU.

The operator needs a real EU presence, not just a mailing address. It checks that technical documentation and product information are in order, keeps documents available to authorities, cooperates with them and reports risks. Specialist representatives, and some marketplaces, offer this service.

Product information and labelling

Under the GPSR, a product must carry:

• a type, batch or serial number, or another element that identifies it;
• the manufacturer's name, registered trade name or trade mark, plus a postal and an electronic address;
• the responsible operator's details, where the manufacturer is outside the EU;
• instructions and safety information in a language consumers in the country of sale can easily understand.

This goes on the product where possible, otherwise on the packaging or in an accompanying document. Commission guidance confirms that the electronic address can be an email address or an easy-to-find contact form on a website.

What online listings must show

Article 19 extends these requirements to online offers. Every listing aimed at EU consumers must clearly show:

1. The manufacturer's name, registered trade name or trade mark, and postal and electronic address.
2. Where the manufacturer is outside the EU, the name and contact details of the responsible operator.
3. Information that identifies the product, including a picture and its type or other identifier.
4. Any warnings or safety information, in a language consumers can easily understand.

In practice, the larger marketplaces have added fields for manufacturer, responsible-person and safety details, and they may restrict listings where this information is missing.

What marketplaces must do

Online marketplaces have their own duties under Article 22. They must:

• appoint a single point of contact for authorities and another for consumers;
• register on the Commission's Safety Gate portal and act on notices received through it;
• design their interface so that sellers can provide the information Article 19 requires;
• act on orders from market surveillance authorities within two working days, and handle safety notices within three working days;
• cooperate with authorities and consumers during recalls.

Accidents, recalls and penalties

If a product causes an accident, the manufacturer must report it promptly to the authorities in the country where it happened, through the EU's Safety Business Gateway. Importers and distributors who hear of an accident must tell the manufacturer.

In a recall, consumers must be told directly and in writing where they can be identified, and through other wide-reaching channels where they cannot. For recalls the business starts itself, consumers must normally be offered a choice of at least two remedies:

• repair;
• replacement with a safe product of the same type, of at least the same value and quality; or
• a refund of at least the price paid.

Remedies must be free and timely. Penalties are set by each member state and must be effective, proportionate and dissuasive.

EPR: the other half of compliance

EPR works country by country. Wherever you are the first to make a product available to end users, you are usually its "producer" there, even if you are based outside the EU and ship direct. A producer generally has to:

• register with the national register or authority;
• join a scheme, often called a producer responsibility organisation (PRO) or compliance scheme, that organises collection and recycling;
• report volumes placed on the market;
• pay fees based on those volumes and materials.

The main streams for marketplace sellers are:

• Packaging, including the outer shipping box, fillers and tape, not just the retail pack.
• Electrical and electronic equipment (WEEE).
• Batteries, including those built into products. The EU Batteries Regulation's EPR rules have applied since 18 August 2025, and producers selling at a distance into a country where they are not established need an authorised representative there.
• Other national streams. France, for example, runs EPR schemes for many more categories, including textiles and furniture.

Germany and France: the registers to know

Germany and France are where most marketplace sellers first meet EPR.

Germany: packaging. Whoever first places packaged goods on the German market must register in LUCID before selling and license consumer packaging with a dual system. Marketplaces and fulfilment providers have had to check registration since July 2022. Since 12 August 2026, under Germany's new packaging law (VerpackDG) and the EU packaging regulation, foreign producers without a German branch that sell direct to German end users must also appoint an authorised representative; new LUCID registrations cannot be completed without one. Registration itself stays the producer's own task.

Germany: electricals. Producers of electrical and electronic equipment register with stiftung ear before first placing products on the market. Foreign sellers either register themselves or appoint an authorised representative. A marketplace may reject a registration number if the brand or equipment type does not match what you sell.

France: the unique identifier. You receive a unique identifier for each stream, normally by joining a PRO. Producers must show it in their terms of sale and on their website. A marketplace is treated as the producer for third-party sales unless it has proof that the seller holds a valid identifier.

How Amazon and other marketplaces enforce EPR

Marketplaces turned these legal duties into account requirements:

• Amazon asks sellers to enter their EPR registration numbers in Seller Central. In Germany, listings without a valid number for the relevant category are deactivated; this began with packaging in July 2022 and extended to electrical equipment from January 2023. In France, sellers without a valid unique identifier are enrolled automatically in Amazon's pay-on-behalf service, which reports and pays eco-contributions for Amazon sales and charges the seller.
• eBay asks sellers to add WEEE numbers and battery IDs to their accounts, and may hide listings until the numbers are added.
• Other marketplaces in Germany and France run similar checks, because the law holds them responsible otherwise.

Pay-on-behalf only covers sales on that one marketplace. If you also sell through your own website or other channels, you still need your own registration.

The EU Packaging and Packaging Waste Regulation

The Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, entered into force on 11 February 2025 and has applied since 12 August 2026. It replaces the old packaging directive, and its obligations arrive in stages:

• From 12 August 2026: harmonised producer registration in each member state, and an authorised representative for EPR where a producer sells directly into a country in which it is not established.
• From 2028: harmonised material-composition labels, from 12 August 2028 or later if the Commission's implementing rules are delayed.
• From 2030: packaging must meet recyclability grades, plastic packaging must contain minimum recycled content, limits on empty space apply, and reuse targets start for certain packaging types.
• 2035 to 2040: stricter recyclability grades and higher recycled-content targets.

EPR fees will increasingly reflect recyclability, so packaging choices made now affect future costs.

Northern Ireland and Great Britain

Under the Windsor Framework, the GPSR has applied directly in Northern Ireland since 13 December 2024. A product sold to Northern Ireland consumers needs a responsible operator established in Northern Ireland or the EU. For a business based only in Great Britain, that is usually an authorised representative or the importer.

Great Britain follows its own rules: the General Product Safety Regulations 2005 still apply, and the Product Regulation and Metrology Act 2025 (Royal Assent 21 July 2025) lets the government add new duties, including for online marketplaces, through secondary legislation. The UK also runs its own EPR schemes for packaging, electricals and batteries, separate from any EU registrations. For how the PPWR applies in Northern Ireland, check the latest guidance from DAERA and the European Commission.

Compliance checklist for sellers

1. Map your markets. List every EU country (and Northern Ireland) you sell to or store stock in, and every channel.
2. Appoint an EU responsible operator. Non-EU brands need an importer or authorised representative with a real EU address, confirmed in writing.
3. Check your labels. Each product needs an identifier, manufacturer and responsible-operator details, and safety information in the right languages.
4. Update every listing. Add the Article 19 details to every marketplace listing and to your own website.
5. Keep the documents ready. Have the risk analysis, technical documentation and test reports ready to send to an authority.
6. Set up a recall and accident process. Know who reports through the Safety Business Gateway, how you contact buyers, and which remedies you will offer.
7. Register for EPR. For each country and stream, register, join a scheme, and appoint an authorised representative where required.
8. Enter your numbers. Add LUCID, WEEE, battery and French unique-identifier numbers to each marketplace account and to your terms of sale.
9. Report and pay on time. Diary every reporting deadline and keep your volume data consistent across registers and schemes.
10. Review packaging for the PPWR. Plan for harmonised labels, recyclability grades and recycled-content targets before you reorder packaging.

How Ain One Group can help

Our product compliance team prepares GPSR labels, listing data and documentation, and helps you appoint an EU responsible person. We also handle EPR and packaging compliance registrations and reporting across Europe, and keep your marketplace accounts, such as Amazon Germany, compliant. Contact us to review your current set-up.