GPSR Compliance Documents for Online Sellers: What to Organize

The EU General Product Safety Regulation (GPSR), which applied from December 2024, requires online marketplace sellers to have specific product safety documentation in place — and to be able to present it to market surveillance authorities or platforms on request. This guide covers the key document categories every GPSR-affected seller should have organized per product.

What GPSR requires you to have

GPSR applies to most consumer products sold in the EU, whether you manufacture, import, or sell as a third-party marketplace seller. The core requirement is that you hold a technical documentation file for each product line, and that you can produce it quickly if asked by a national market surveillance authority or an online marketplace.

Product identification documents

• Product name, model, and SKU — a consistent identifier used across all documents for that product.
• Manufacturer name and contact details — or your own details as importer or distributor.
• Country of manufacture and details of your supply chain if you are not the manufacturer.
• Product photos — clear images of the product, packaging, and any markings (CE mark, batch number, serial number ranges if applicable).
• Listing screenshots from each marketplace where the product is sold, showing what consumers see at point of purchase.

Safety and conformity documents

• Declaration of Conformity (DoC) — the manufacturer's written declaration that the product meets applicable EU directives or regulations. For products with a CE mark, this is mandatory. Keep a copy for each product.
• Test reports from accredited third-party laboratories showing the product meets the relevant safety standards (e.g., EN 71 for toys, EN 62115 for electrical toys, IEC 62368 for electronics). The test report should reference the specific product model and batch tested.
• Safety data sheets where applicable — particularly for products containing chemicals or materials subject to REACH or RoHS.
• Product instructions and warnings — the user manual, safety instructions, and any warnings printed on packaging, in the language(s) required for the markets where you sell.

Responsible Person designation

GPSR requires that a "Responsible Person" be established in the EU for products sold there — this is the entity that holds the technical documentation and is the point of contact for authorities. If you are not yourself based in the EU, you must appoint a Responsible Person.

• Written designation agreement between you and the Responsible Person, confirming their role and the products covered.
• The Responsible Person's EU business name, address, and contact details — these must appear on your product listing and packaging.
• Confirmation that the Responsible Person holds or has access to the technical documentation for the products they cover.

Incident and complaint records

GPSR requires sellers to track safety-related complaints and incidents and, in serious cases, to notify authorities and take corrective action.

• A log of any customer safety complaints, with the date, nature of the complaint, and your response.
• Records of any product recalls, voluntary withdrawals, or corrective actions taken.
• Any correspondence with market surveillance authorities or online platforms about safety concerns.
• If a platform removed a listing for safety reasons, keep the notification and your response.

How to organize your GPSR file per product

Maintain one document folder per product (or per product family if variants share documentation). A well-organized GPSR file contains, in order:

1. Product identification sheet (name, model, photos, marketplace listing screenshots).
2. Declaration of Conformity.
3. Test reports (most recent, referencing the relevant standards).
4. Responsible Person designation agreement and contact details.
5. User instructions and packaging warnings.
6. Incident and complaint log.