If you sell electronics or ICT equipment in several EU countries, the core of the General Product Safety Regulation (GPSR) is the same everywhere: it is a regulation, and a regulation applies directly in every Member State without a country having to first enact its own law. The obligations concerning safe products, traceability and a point of contact within the EU therefore apply in Germany just as much as in the Netherlands or Spain.
What does differ is in the implementation: the language in which you provide safety information and warnings, which market surveillance authority in a country is responsible, and whether a Member State imposes an additional national requirement. For a company that supplies via an online shop or distributor in several countries, this is often the part that involves the most work in practice.
What is the same throughout the EU
The GPSR stipulates that a product must be safe, that risks must be recognisable to the user, and that a market operator within the EU can be identified and held responsible. These principles are set out in the regulation itself and are not country-specific. An importer who meets these basic requirements complies with it in principle in every Member State. This makes the regulation simpler in design for companies that trade internationally than a directive, where each country is allowed to make its own translation into national legislation.
Where it does differ per country
The first and most common difference is language. Instructions for use, safety warnings and contact details must be understandable to the consumer in the country of sale, and in practice this means: in the official language or languages of that country. A Dutch package insert is not sufficient if the same equipment also comes onto the market in France or Poland.
The second difference is in market surveillance. Each Member State appoints one or more market surveillance authorities to enforce the GPSR. In the Netherlands, this is usually with the Dutch Food and Consumer Product Safety Authority for many consumer electronics, but in another country a different authority may be responsible, with its own working methods and its own reporting point for consumers. For a company that sells products in several countries, this means that a complaint or inspection can come through different authorities.
The third difference is that some Member States, in addition to EU-wide rules, have their own additional requirement: for example a specific national register, a mandatory notification to a local authority, or their own form for designating the responsible person. These kinds of requirements are not in the GPSR itself but in national implementing rules, and therefore differ per country where you are active.
What this means for the interaction with the digital product passport
For electronics that will fall under the digital product passport in future, there will be a second layer on top: the passport itself is the same EU-wide system, but the underlying product safety information must still comply with the language and market surveillance requirements of each country where the product is sold. GPSR documentation and passport data thus run alongside each other and supplement each other, they do not replace each other. In the knowledge base per situation it is set out how these two regulations relate to each other for your product category.
How to keep this manageable for your company
If you sell in several EU countries, it is practical to maintain a brief overview per country: which language is required for the package insert, which market surveillance authority is responsible, and is there an additional national reporting obligation. This overview does not need to be complicated, but it prevents you from discovering when you expand to a new country that the safety information needs to be retranslated or adjusted. With a brief scan that provides an indication in just a few questions you will quickly gain insight into which components are relevant for your products, even if you don't yet know exactly which countries you will be supplying to.
Whether a specific national requirement applies to your product and how you comply with it varies per country and per product group. For an explanation of the regulation itself, you can consult the official text; for translating it into your own situation, a lawyer or the competent supervisory authority in the country concerned is the appropriate point of contact. In frequently asked questions you will also find a number of practical examples of how other companies approach this issue.
Would you like to get a general overview before you investigate in detail what changes per country? Take the free quick-scan or read through the topics in the knowledge base; both will give you an initial direction for your own products and markets without obligation.