A third regulation alongside the AI Regulation and the product passport
If you have already looked into the AI Regulation and the digital product passport, you may also have come across the General Product Safety Regulation, also known as the GPSR (General Product Safety Regulation). This regulation applies in broad terms to any company that places products on or makes products available on the EU market, including electronics and ICT equipment, regardless of whether a digital passport already exists for that product group.
Whether the regulation concretely requires anything of you depends on your role. If you are a manufacturer, importer or distributor of electronics, there are obligations tailored specifically to your role. If you only sell as an intermediary via your own web shop or platform, different and lighter obligations apply. The regulation explicitly distinguishes these roles, and that distinction determines what is expected of you.
What the regulation specifically covers
The GPSR replaces the older European general product safety directive and has been in force since December 2024. The core is that a product must be safe before it is placed on the market, and that someone in the EU is identifiable as responsible if something goes wrong. For electronics, this means, among other things, that risks such as overheating, electrical shocks or hazardous substances have been assessed in advance, and that a contact person within the EU is known to supervisory authorities and consumers.
This is separate from CE marking, which has long been mandatory for many electronics products. The GPSR is broader: it also applies to products for which no specific EU directive with CE requirements exists. The difference between CE marking and other European obligations is often underestimated; the knowledge base sets the concepts side by side so you can see which rule applies to which product.
Who the regulation specifically applies to
Manufacturers and importers
If your company has electronics produced under your own brand name, or imports electronics from outside the EU to sell in the EU, you are generally the party on whom the regulation places the most obligations. This includes, among other things, maintaining technical documentation, being able to designate a responsible person within the EU, and responding to reports of unsafe products.
Distributors and online sellers
If you sell electronics that another brand or party has already placed on the market, lighter but not to be neglected obligations apply. For example, you must be able to verify that the product carries the required information and that a responsible party has been designated in the EU. If you sell via your own web shop, there are specific requirements for the information you must display online, such as contact details and product warnings.
Purely internal equipment
If your company uses electronics only for its own business operations, without you trading or importing them yourself, you are generally not a party under this regulation. You remain bound by more general rules on working conditions and product safety in the workplace, but that is a different regime than the GPSR.
How this relates to the digital product passport
The GPSR and the future digital product passport are separate from each other, but affect the same companies. Both regulations require comparable basic information: who the manufacturer or importer is, what technical documentation exists, and who within the EU is accountable. Companies that already keep this data in order for the GPSR are well positioned once the obligations for the passport become concrete per product group. With a short scan shows you in five questions where your company stands at this moment, both for the passport and for related obligations.
What you can practically do with it
The first step is to determine which role your company takes on: manufacturer, importer, distributor or end-user only. That role determines which part of the regulation applies to you, and that distinction is also reflected in the digital product passport. If you are unsure about your role or what is concretely required of you, then the text of the regulation itself on EUR-Lex is the place to find it, and the Dutch Food and Consumer Product Safety Authority is the supervisory authority that provides general information about product safety. For an assessment of your specific situation, a lawyer is the appropriate party.
If you first want an overview of how the different European rules for electronics relate to each other, you will find that overview in frequently asked questions about the digital product passport and related rules.
Check for yourself whether this applies to you
Whether the General Product Safety Regulation applies to your company therefore strongly depends on the role you take on in the supply chain. Feel free to do the free quick scan to see in a few minutes where your company stands, or continue reading in the knowledge bank to see the different European rules clearly side by side.