The GPSR itself is no longer new: the General Product Safety Regulation has been applicable for some time now. What is changing this year is not in the text of the regulation itself, but in the way supervisory authorities, marketplaces and manufacturers are handling it in practice. For companies putting electronics or ICT equipment on the market, this means in particular that loose agreements and good intentions from last year are now being tested concretely.
Important to distinguish: the obligations under the GPSR — a responsible person in the EU, a risk assessment, correct product information, a complaints point — already applied. What is shifting is the implementation: supervisory authorities have by now built up experience with inspections, marketplaces have further developed their own obligations, and more practical guidance is emerging on how the rules are applied to specific product groups such as chargers, batteries and household appliances.
From preparation to implementation
In the period following the GPSR coming into force, the emphasis was mainly on understanding: what does the regulation mean, who is a supplier, what must be in the documentation. This year the focus is shifting to implementation. National supervisory authorities for product safety are carrying out inspections on the basis of the rules as they have been developed in the meantime, and they are not only looking at the presence of documents, but also at whether the information is correct and up to date. This particularly affects companies that have drawn up the first version of their product information and have not updated it since, while the product itself has been modified.
For anyone importing electronics or assembling them from components of multiple suppliers, this means that GPSR documentation must remain a living file, not a one-off exercise. consult the knowledge bank by subject provides an overview of which obligations apply to which product group and where the text of the regulation itself can be found.
Marketplaces and online sales
A second shift is taking place in online sales channels. Platforms offering products from third parties are themselves also bound by obligations under the GPSR, and many of them have tightened their own submission requirements for sellers this year. You will notice this concretely if you sell through a marketplace: some platforms are now actively requesting documents that previously only had to be available on request, or are refusing a listing without a valid responsible person contact in the EU. This is not an amendment to the regulation, but a tightening of how buyers in the chain are handling it — and that tightening often feels just as binding to a seller as an amendment to the law.
What does this mean for your company
Whether these shifts are relevant for your company depends on a few things: do you sell directly to consumers in the EU, do you use marketplaces as a sales channel, and has your product information been modified since you drew it up. An installation company that only places equipment commercially is in a different position than an importer who sells directly to consumers via a webshop. The regulation itself also makes that distinction, among other things in the scope of who is considered a supplier.
What supervisory authorities will precisely inspect and how strictly it will be done cannot be predicted with certainty — that is up to the competent supervisory authority itself, and also differs per Member State. What is clear, however, is that documentation that is correct for the current product, and that is demonstrably kept up to date, is less vulnerable to questions than a file that has not been touched since start-up.
Practical: what you can do now
The most common action companies are taking this year is not redrafting their GPSR file, but checking whether the existing information is still up to date: is the responsible person still the same, have there been product changes that have not been incorporated into the documentation, and is the complaints contact point still reachable as stated. For companies uncertain whether their current approach still aligns with how supervisory authorities now view it, it is worthwhile to compare their own situation against the official text, or to discuss this with a lawyer.
The digital product passport and the GPSR partly overlap in the data you must keep, but are separate obligations with their own timeline. Those who want to see how the two relate to each other will find that in frequently asked questions about both obligations.
Do you want to quickly gain insight into what applies to your own product group and sales channel? Take the free quick-scan in a few questions see where your company stands, or see how elektropas.com compiles the information via an explanation of the working method. For the broader background on both the GPSR and the digital product passport, the knowledge bank remains the starting point.