GPSR Compliance for Non-EU Brands: What You Need to Know Before Shipping to Europe in 2026

Publication Date: June 1, 2026

Read Time: 9 minutes

Target Audience: Non-EU e-commerce brands and B2B exporters shipping to Europe (US, UK, Vietnam, Canada, Australia…)

Introduction

If you ship non-food consumer products from outside the European Union to European customers, you need to understand the European Commission’s General Product Safety Regulation (GPSR).

This is not optional. GPSR has been fully applicable since December 13, 2024. By 2026, enforcement activity and marketplace compliance checks have become increasingly visible across the EU. Market surveillance authorities across member states have increased enforcement activity and online marketplace monitoring since the regulation took full effect.

Many non-EU brands are still unaware of their obligations. According to the first EU Product Safety Sweep coordinated through the Consumer Safety Network, approximately 32% of the audited listings showed non-compliance relating to economic operator and responsible person information requirements.

This guide explains what GPSR requires, who needs to comply, and the potential consequences of non-compliance. It also clarifies what Kontor of Bruges does and does not do to support your logistics workflow.

What Is GPSR?

The General Product Safety Regulation (GPSR) (EU) 2023/988 replaced the General Product Safety Directive (GPSD) and serves as a horizontal safety framework for non-food consumer products placed on the EU market. Where sector-specific legislation exists (e.g., toys, electronics, cosmetics, or personal protective equipment), GPSR complements rather than replaces those rules. Where no sectoral rules apply, GPSR sets the baseline safety requirements.

GPSR applies regardless of whether products are sold online or offline, and there are no general exemptions for e-commerce, dropshipping, or low-volume sellers.

Key dates to remember:

June 12, 2023: GPSR entered into force
December 13, 2024: GPSR became fully applicable
2026: Ongoing enforcement and marketplace compliance checks across the EU

Who Must Comply?

GPSR applies to any economic operator placing products on the EU market. That includes:

Manufacturers based outside the EU
Importers (EU-based entities bringing products into the EU)
Distributors
Authorised representatives (the “Responsible Person”)
Fulfilment service providers (under specific conditions)

If you are a non-EU brand selling directly to EU consumers (B2C), your products are subject to GPSR compliance requirements. There is no exemption for distance selling.

The Responsible Person: Your Biggest Challenge

This is the most critical requirement for non-EU brands. Under Article 16 of GPSR, products generally cannot be placed on the EU market unless there is an economic operator established in the European Union who is responsible for safety-related tasks.

This “Responsible Person” can be:

An importer established in the EU
An authorised representative appointed by the non-EU manufacturer
A fulfilment service provider based in the EU who may assume this role in certain circumstances where no other qualifying economic operator is established in the EU

For many non-EU brands, ensuring that an appropriate EU-based economic operator is designated under Article 16 is one of the most important steps toward GPSR compliance. Depending on the supply chain structure, this may be an importer, an authorised representative, or another qualifying economic operator established within the European Union. You cannot act as your own Responsible Person if you do not have a legal entity established within the EU.

What the EU Responsible Person is required to do:

Maintain the technical documentation and EU declaration of conformity (where applicable)
Cooperate with market surveillance authorities
Provide authorities with necessary information and documentation upon request
Notify authorities of identified product safety risks
Facilitate product withdrawal or recall actions when required

Importer of Record vs. GPSR Responsible Person: What's the Difference?

This is a major source of confusion for many non-EU brands. The party handling customs entry and the GPSR Responsible Person are distinct roles with different legal responsibilities and purposes.

Note: The term ‘Importer of Record’ (IOR) is commonly used in international trade to describe the party responsible for import formalities and customs obligations, though the formal legal definition within the EU Customs Code (UCC) refers to this party as the declarant or importing party.

The Importing Party / Importer of Record (IOR)

The declarant or importing party is responsible for customs compliance. This includes:

Ensuring correct commercial invoices and HS codes
Paying import VAT and customs duties
Clearing goods through EU customs
Complying with trade and customs regulations

This role can be fulfilled by:

Your customer (under DAP terms)
You, the seller (under DDP terms with IOSS or broker accounting)
A customs broker acting as a direct or indirect representative on your behalf

GPSR Responsible Person

The GPSR Responsible Person is responsible for product safety compliance. This includes:

Maintaining technical documentation and safety test reports
Cooperating with market surveillance authorities
Assisting with the mitigation of product safety risks
Ensuring safety warnings are available in required local languages

The Responsible Person must be an EU-based entity. It cannot be your retail customer, and it cannot be a non-EU entity. It is also separate from standard logistics providers unless they explicitly accept that compliance role in writing.

Why the confusion?

Many non-EU brands assume that if they have a customs declarant (for example, a customs broker handling their DDP shipments), that same entity automatically acts as their GPSR Responsible Person. That is typically not the case. Customs brokers handle trade compliance, not product safety. Unless they explicitly offer GPSR representation services, you require a separate arrangement.

Role	Required?	Who can fulfil it?
Customs Declarant (Importer of Record)	Required whenever goods are imported into the EU	Customer (DAP), seller (DDP), or customs broker
GPSR Responsible Person	Yes, for non-food consumer products within GPSR scope	EU-based manufacturer, importer, or authorised representative

What Kontor of Bruges does not do

We are neither an importer, a declarant, nor a Responsible Person. We do not clear customs, pay duties, assume trade compliance liability, or act as your GPSR representative. We do not provide storage, inventory management, picking, or order fulfilment services. As a relay hub, we do not act as your Responsible Person and do not assume GPSR compliance obligations on your behalf. We receive your DDP palletized cargo, process your cross-border shipping data, and relay individual parcels directly to your customers.

Labeling Requirements

GPSR imposes specific labeling requirements designed to ensure traceability. Products subject to GPSR requirements must display:

Manufacturer information
- Name, registered trade name or trademark
- Postal address
- Email address and/or other electronic contact details
Responsible Person information
- Name and contact details of the EU-based Responsible Person
- Email address and/or other electronic contact details
Product identification
- Type, batch, serial number, or other element allowing product identification
Safety information and warnings
- Any specific warnings or safety information required for the product type
- Provided in a language easily understood by consumers in the member state where the product is sold

If a product’s size or nature makes it impossible to display this information on the product itself, it can be displayed on the packaging or in an accompanying document.

Marketplace Enforcement: Major online marketplaces increasingly require GPSR-related information before allowing certain products to be listed or sold to EU consumers. Non-compliant listings face potential removal by the platforms.

Technical Documentation and Declaration of Conformity

Manufacturers selling into the EU must draw up technical documentation demonstrating that their products comply with applicable safety requirements.

This technical documentation typically includes:

A general description of the product
An analysis of potential safety risks
Safety testing results or laboratory reports
A list of applicable harmonised standards
The EU declaration of conformity, where required under applicable sector-specific legislation

This documentation must be retained for 10 years after the product has been placed on the market and made available to market surveillance authorities upon request.

Potential Consequences of Non-Compliance

Enforcement frameworks across the European product safety landscape have become increasingly stringent.

Marketplace Restrictions: Major platforms actively monitor listings. Non-compliant listings can be blocked, and persistent non-compliance may lead to merchant account suspensions.
Penalties: Penalties for non-compliance vary significantly by member state and may include product withdrawals, marketplace restrictions, administrative fines, and in some jurisdictions, additional sanctions for serious violations.
Border Controls: Non-compliant products may be detained, restricted, withdrawn from the market, or subject to corrective measures depending on the circumstances and the decisions of the competent authorities.

Common GPSR Mistakes Non-EU Brands Make

Mistake 1: Assuming GPSR only applies to large enterprises
GPSR applies to all economic operators placing consumer products on the EU market, regardless of business size.
Mistake 2: Listing a non-EU address as the Responsible Person
The Responsible Person must be established within the EU. A UK, US, or Asian address does not satisfy this requirement.
Mistake 3: Omitting batch or traceability numbers
Every product must be traceable. Without batch or serial numbers, targeted safety management becomes incredibly difficult.
Mistake 4: Disregarding language requirements
Safety information must be accessible in the official language of the member state where the product is commercialized.
Mistake 5: Confusing the customs declarant with the Responsible Person
Your customs broker handles border entry, not product safety. You typically need separate solutions for customs clearance and product safety representation.

What Kontor of Bruges Does and Does Not Do

We are frequently asked whether our hub can handle product safety compliance or act as an importer. To keep our operations fast and efficient, we maintain clear boundaries.

What we do not do:

Act as your EU Responsible Person or GPSR representative
Act as the importing party or declarant (we do not clear customs or assume import trade liability)
Verify product-level GPSR labeling or open retail packaging
Maintain or manage technical product compliance files
Provide legal advice regarding product safety directives

What we do:

Receive and cross-dock your pre-cleared, DDP shipments at our Belgian hub
Scan commercial invoice data for obvious omissions (not product safety compliance)
Apply last-mile shipping labels and inject parcels directly into European carrier networks
Provide end-to-end tracking visibility from our hub to the consumer’s door

Your product compliance and import responsibilities remain yours. We handle the efficient execution of your last-mile logistics.

How to Prepare for Compliance (Step by Step)

Assess and Appoint: Identify if your products require an EU-based Responsible Person and secure an authorized representative or economic operator service provider if needed.
Compile Documentation: Assemble product descriptions, risk assessments, and test reports. Ensure they are stored securely for the required 10-year period.
Review Packaging: Ensure manufacturer details, Responsible Person information, traceability codes, and translated safety warnings are correctly applied.
Update Digital Listings: Ensure your online store and marketplace portals are updated with the required digital compliance fields.
Verify Before Shipping: Implement checks at your manufacturing or dispatch facility to ensure compliance elements are in place before items travel. Your relay hub cannot perform these product-level audits for you.

Moving Forward with Your EU Expansion

GPSR represents a permanent shift in how products enter the European market. Brands that establish clear compliance workflows ensure uninterrupted access to EU consumers, while those that overlook these regulations face operational disruptions.

While we do not manage your product compliance, we specialize in making your European logistics seamless once your compliance framework is set up.

We support DDP pallet flows from markets including the US, UK, Vietnam, Canada, and Australia. Once your compliance is sorted, we stand ready to relay your parcels efficiently across all 27 EU member states, including Germany, France, Italy, Spain, the Netherlands, Belgium, Austria, Sweden, and Ireland.

Connect with our logistics team to learn how our relay services can streamline your cross-border supply chain.

Sources & Regulatory References:

European Commission – Consumer Safety Network: Summary Report on the First EU Product Safety Sweep
Official Journal of the European Union: Regulation (EU) 2023/988 (General Product Safety Regulation)