EU Representative GPSR

Earlier this year, Amazon Europe issued a new announcement stating that the European Union's newly enacted General Product Safety Regulation (gpsr) will officially come into effect on December 13, 2024. This means that by the end of 2024, all sellers on Amazon Europe will need to have an EU Responsible Person.

What should sellers be aware of regarding the new legislation? Today, we will explain this.

What is GPSR?

The General Product Safety Regulation (GPSR) is a regulation by the EU to ensure that products sold in the market are safe. It replaces the General Product Safety Directive and will officially take effect on December 13, 2024. Non-food products (including both CE and non-CE items) sold in the EU and Northern Ireland must comply with the GPSR.

Which products are affected by the GPSR?

The majority of non-food consumer goods are subject to the General Product Safety Regulation (GPSR), with the following types of products being exempt:

- Human or veterinary medicines

- Food

- Animal feed

- Living plants and animals (including genetically modified organisms and genetically modified microorganisms used in closed systems, as well as animal and plant products directly related to the future breeding of animals and plants)

- Animal by-products and derivatives

- Plant protection products (e.g., pesticides)

- Consumer transportation or mobility equipment, provided it is directly operated by service providers within the scope of transportation services and not by the consumer themselves

- Aircraft

- Antiques

Key aspects of the GPSR:

1. Manufacturer's Obligation

 Producers or importers must ensure that products meet safety compliance requirements before being launched on the market. They must establish appropriate inspection procedures and conduct risk assessments.

2. Product Conformity Mark

 Products must carry the European conformity mark (CE mark), which indicates the product meets applicable EU safety and health requirements.

3. CE Marking Conformity Assessment

 The CE marking conformity assessment includes self-declaration, declaration of conformity, third-party certification agency testing, and type examination.

4. Market Surveillance

 EU member states are responsible for market surveillance, including product imports, wholesale, and retail, to ensure products meet GPSR requirements.

5. Enforcement of Penalties

 Violations of the GPSR will be punished with fines, product confiscation, product recalls, and potential market entry or criminal liability.

What is an EU Responsible Person? What is an EU Representative?

An EU Responsible Person refers to a natural or legal person, designated by a manufacturer located outside the European Economic Area (EEA), to act on behalf of the manufacturer within the EU. This could be a local manufacturer or importer, or an authorized representative (EU Representative) designated by the manufacturer or brand within the EU. When the seller is located outside the EU, the EU Representative will carry out specific responsibilities on behalf of the seller according to EU regulations and laws.

Can we wait until the end of the year to take action regarding the new law?

No. The GPSR regulation has various requirements, including uploading and labeling. Sellers generally need 4-6 months to complete these steps and ensure that products meet the gpsr labeling requirements before being stored in Amazon FBA warehouses. If products do not meet labeling requirements after December 13, any non-compliant products in the FBA warehouse may be removed and delisted by Amazon.

What should my product labeling include to meet GPSR requirements?

The GPSR regulation requires labels to include the following information:

1. Contact details of the responsible person and manufacturer (name, postal address, email/URL)

2. Product safety and warning information, including:

 - CE mark

 - Energy label

 - Toy safety warnings and chemical hazard warnings (in the language(s) of the selling country)

3. At least one of the following: product type, batch, serial number, or other identifiable information.

Where should my labels be placed?

Labels can be placed on:

- The product itself

- Product packaging

- Product parcel or accompanying documents

Additionally, a QR code or barcode may be added to the label to display the responsible person/manufacturer's information, but the seller must also provide this information in written form on the product, packaging, or accompanying documents.

How should sellers ensure GPSR compliance?

- Ensure that all products sold in the EU and Northern Ireland meet the existing labeling and traceability requirements.

- Provide an EU Responsible Person for the products you sell.

How to appoint an “effective” EU Representative?

An EU Representative is not just someone who provides an address. To ensure the representative can genuinely assist the seller in fulfilling product safety responsibilities, communicate with overseas buyers, and offer professional solutions and regulatory lawyer support, the representative must be capable of communicating with EU and UK regulatory bodies.

The Meou Cross-Border Overseas Product Compliance Team has the expertise and qualifications to liaise with EU and UK regulatory bodies, help sellers resolve overseas product issues, and guide them on printing correct labels to avoid risks of goods being seized.

If I change my EU Responsible Person information, do I need to update the product labels and safety images?

If you change your EU Responsible Person, you need to:

1. Update the responsible person information on your seller platform.

2. Display the latest responsible person information on the labels.

3. If your uploaded product safety images/documents contain the responsible person's information, you need to update and re-upload it.

JJR's Advantages:

- Over 20 years of experience in international regulatory certifications.

- Our laboratory is ISO 17025 accredited and meets platform certification requirements.

- We assist clients from product testing, warning label creation, certification registration, to product labeling, ensuring a successful review!