The EU General Product Safety Regulation (GPSR), Regulation (EU) 2023/988, became fully applicable on December 13, 2024. It explicitly covers non-EU brands selling through online marketplaces, including Amazon EU, eBay, Zalando and bol.com, classifying them as importers with full product safety accountability. If you are a US brand selling any consumer product into the EU through any online channel, the GPSR Responsible Person obligation applies to you today. It is not a future requirement. It is not limited to large brands. It is already active.

The GPSR replaces the previous EU General Product Safety Directive and significantly strengthens the accountability framework for products sold online. For non-EU brands, the critical change is the explicit inclusion of online marketplace sellers as economic operators, specifically as importers. Under the GPSR, an importer is a person who places a product from a third country on the EU market, and online marketplaces are explicitly named as entities that must cooperate with authorities and remove unsafe products. For US brands without EU physical presence, the importer designation means an EU-based Responsible Person must be appointed to accept legal accountability for product safety compliance. This is distinct from the cosmetics Responsible Person under the EU Cosmetics Regulation, and distinct from Responsible Person roles under other product-specific regulations.

The practical obligation is the same across product categories: a designated, EU-based entity that holds product safety documentation and can respond to authority requests or product recalls. The GPSR Responsible Person must hold and be able to produce the product's technical documentation, a declaration of conformity where applicable, instructions and safety information in the relevant EU languages, and a record of any complaints or accidents. For US supplement, beauty, electronics and home goods brands selling via Amazon EU, the GPSR Responsible Person appointment is a live, already-active requirement. Selling on EU marketplaces without it has been non-compliant since December 13, 2024.

• GPSR Regulation (EU) 2023/988 has been fully applicable since December 13, 2024, and non-EU online marketplace sellers are classified as importers with full product safety accountability from that date
• An EU-based Responsible Person appointment is required, holding technical documentation, responding to authority requests and managing product recalls for any covered product on the EU market
• The GPSR Responsible Person is separate from category-specific Responsible Persons, so a cosmetics RP does not satisfy GPSR, and both may be required for a beauty supplement brand
• EU marketplace operators (Amazon, eBay, Zalando, bol.com) must cooperate with authorities and remove non-compliant products, so non-compliance creates de-listing risk, not just regulatory risk
• Technical documentation, a declaration of conformity, and consumer-language safety information must be held by the Responsible Person for every covered product on the EU market

The GPSR Responsible Person requirement is the most commonly missed active compliance obligation for US brands already selling or planning to sell into the EU via online marketplaces. Its broad scope, applying to virtually all consumer product categories, means few US brands are out of scope. Expandly includes GPSR Responsible Person appointment and documentation support as part of EU market entry onboarding, so brands do not discover this obligation after their first authority request or marketplace de-listing.