EU GPSR for Australian Exporters: What You Need to Know
Australian manufacturers, exporters and brand owners selling consumer products in the European Union should determine whether the EU General Product Safety Regulation (GPSR) applies to their products and supply chain.
Regulation (EU) 2023/988 strengthens the European Union framework for consumer-product safety and has applied since 13 December 2024. It addresses product-safety assessment, traceability, economic-operator responsibilities, online and distance sales, accident reporting, corrective actions and recalls.
For Australian companies, selling directly from outside the European Union does not remove EU product-safety responsibilities. The product, its documentation, the EU economic-operator arrangement and the information displayed to consumers should all be reviewed before market entry.
Quick answer
What should Australian exporters check under the EU GPSR?
Before offering a consumer product in the European Union, an Australian business should determine whether GPSR applies, assess product safety, identify the manufacturer and relevant EU economic operator, establish product traceability, prepare required safety information and ensure online product offers contain the required information.
Confirm GPSR scope
Determine whether GPSR applies and identify any additional sector-specific EU legislation.
Assess product safety
Identify hazards, target users, foreseeable misuse and the evidence supporting product safety.
Establish EU representation
Confirm the EU economic operator or responsible person required before market entry.
Prepare market information
Check product identification, warnings, traceability information and online product offers.
GPSR checklist
EU GPSR checklist for Australian exporters
Select a topic to move directly to the corresponding section of the guide.
01Confirm whether GPSR appliesProduct scope and interaction with sector-specific legislation
02Assess product safetyHazards, users, foreseeable use and supporting evidence
03Map the economic operatorsManufacturer, importer and EU responsible person
04Prepare safety documentationRisk analysis, evidence and technical records
05Establish product traceabilityProduct identification and manufacturer information
06Review warnings and instructionsConsumer safety information and language requirements
07Check online and distance salesProduct-page information required under Article 19
08Prepare post-market proceduresComplaints, accidents, corrective actions and recalls
Step 1Confirm whether the GPSR applies to your product
Start by classifying the product and identifying every EU legal instrument that may regulate it. GPSR provides a general consumer-product-safety framework, but many product categories are also covered by sector-specific legislation.
GPSR can also remain relevant to risks or aspects that are not addressed by more specific EU product legislation.
Record at least the following
- Product category and intended use.
- Whether the product is intended for consumers.
- Whether consumers may reasonably use the product even if it was originally intended for professional use.
- Target users, including children or vulnerable consumers where relevant.
- Applicable sector-specific EU legislation.
- Relevant standards or other technical specifications.
- Sales channels and destination EU Member States.
Step 2Perform a product-safety assessment
A consumer product supplied in the EU should be safe under normal or reasonably foreseeable conditions of use.
The assessment should consider the product itself together with its presentation, instructions, foreseeable use, target users and the environment in which it will be used.
Consider relevant hazards and safety factors
- Mechanical and physical hazards.
- Electrical or thermal hazards where relevant.
- Chemical exposure.
- Fire and flammability.
- Choking, ingestion or suffocation.
- Product durability and deterioration.
- Interaction with other products.
- Cybersecurity or software-related safety effects where relevant.
- Risks to children, older people and other vulnerable users.
- Reasonably foreseeable misuse.
Step 3Map the manufacturer, importer and EU responsible person
Australian exporters should document the economic-operator structure before placing a product on the EU market.
Where the manufacturer is established outside the European Union, an appropriate responsible economic operator established in the EU may be required under the applicable product-safety framework.
Confirm the following
- Who is the legal manufacturer?
- Is the product sold under the Australian company’s own name or trademark?
- Who imports the product into the EU?
- Is there an EU authorised representative?
- Which EU economic operator fulfils the responsible-person role?
- Who holds or can provide the required compliance information?
- Whose contact details must appear on the product or packaging?
Step 4Prepare the product-safety documentation
Compliance should be supported by documentation that explains the product, identifies relevant hazards and demonstrates how safety has been evaluated.
A practical product-safety file may include
- Product description and identification.
- Product specifications and drawings.
- Intended use and target users.
- Risk analysis or safety assessment.
- Applicable standards and technical specifications.
- Test reports and certificates where relevant.
- Materials and component information.
- Supplier declarations.
- Warnings and instructions.
- Traceability information.
- Records of corrective actions and product changes.
Step 5Establish product identification and traceability
Products should be identifiable so that a particular model, batch, type or production run can be traced when a safety issue arises.
Review the following
- Product name and model.
- Type, batch, serial number or other suitable identifier.
- Manufacturer name, registered trade name or trademark.
- Manufacturer postal and electronic contact details.
- Relevant EU economic-operator information.
- Supplier and production records.
- The ability to identify affected products if corrective action becomes necessary.
Step 6Review warnings, instructions and consumer information
Safety information should follow from the product risk assessment rather than being added as a generic final step immediately before launch.
Check whether consumers need
- Safety warnings.
- Installation or assembly instructions.
- Operating instructions.
- Age restrictions or user limitations.
- Maintenance information.
- Storage information.
- Safe-disposal information where relevant.
- Information in the language or languages required in the destination market.
Step 7Check GPSR requirements for online and distance sales
GPSR specifically addresses products offered online or through other forms of distance selling.
Article 19 requires specified information to be presented clearly and visibly in a distance-sale product offer before purchase.
Review each online product offer for
- Manufacturer name, registered trade name or registered trademark.
- Manufacturer postal and electronic address.
- Where the manufacturer is outside the EU, the required details of the responsible person.
- Information allowing the product to be identified.
- A picture of the product and other identifying information.
- Relevant warnings or safety information.
Step 8Prepare complaints, incident and recall procedures
GPSR compliance continues after a product is placed on the market. Businesses should be able to identify safety issues and take corrective action without first having to design the process after an incident occurs.
Establish procedures for
- Receiving and reviewing consumer complaints.
- Recording product-safety incidents.
- Escalating serious safety concerns.
- Investigating affected products and batches.
- Cooperating with distributors and EU economic operators.
- Notifying authorities where required.
- Corrective actions, withdrawals and recalls.
- Communicating with affected consumers.
- Maintaining records of actions taken.
Australia-to-EU example
Example: Australian brand selling consumer products through an EU marketplace
Consider an Australian company selling a consumer accessory under its own brand. Products are manufactured in Asia, stored by a European fulfilment provider and offered to consumers through an online marketplace.
The compliance review should establish
- Which EU product-safety legislation applies.
- Whether additional sector-specific requirements apply.
- Who is legally considered the manufacturer.
- Which EU economic operator performs the required role.
- Whether the risk assessment and documentation are adequate.
- Which identification and contact details appear on the product or packaging.
- Whether the marketplace listing displays the required information.
- How complaints, incidents and recalls will be handled.
Common mistakes
GPSR mistakes Australian exporters should avoid
Assuming CE marking solves everything
CE marking and GPSR are different concepts. The full legal framework still needs to be identified.
No EU operator structure
Non-EU manufacturers should confirm the required EU economic operator before offering the product for sale.
Ignoring online-sale requirements
Distance-sale product offers have specific consumer-facing information requirements.
Weak safety documentation
The business should retain evidence explaining why the product is considered safe.
Frequently asked questions
EU GPSR FAQ for Australian exporters
Does the EU GPSR apply to Australian companies?
It can. GPSR regulates consumer products placed or made available on the EU market, so Australian manufacturers and brand owners can be affected when their products are supplied to EU consumers.
When did GPSR start applying?
Regulation (EU) 2023/988 has applied since 13 December 2024.
Does an Australian manufacturer need an EU Responsible Person?
Where required by the applicable EU framework, products from a manufacturer established outside the EU need an appropriate responsible economic operator established in the European Union. The correct arrangement depends on the product and supply-chain structure.
Does GPSR cover Amazon and other online marketplaces?
Yes. GPSR specifically addresses online and other distance sales, including information that must be shown in the product offer.
Is CE marking enough for GPSR compliance?
No. CE marking applies only where relevant EU harmonisation legislation requires it. Product safety, traceability, economic-operator and other applicable requirements still need to be assessed.
Official references
Official EU GPSR sources
Use official European Union sources when confirming current and product-specific requirements.
Need product-specific support?
Prepare your consumer product for the EU market
EKOTOX supports Australian manufacturers, exporters and brand owners with GPSR applicability reviews, product-safety assessments, economic-operator arrangements, documentation, labelling, traceability and wider EU market-entry preparation.