Does GPSR apply if my product already has CE marking?
CE marking and GPSR compliance are not the same thing, and one does not automatically satisfy the other. CE marking is the result of conformity assessment under one or more sector-specific EU directives — the Low Voltage Directive, the EMC Directive, the Radio Equipment Directive, the Toy Safety Directive, and others. Each of these directives addresses specific categories of risk. The GPSR functions as a safety net for all risks and safety aspects not addressed by those sector-specific rules. Article 2.3 of Regulation (EU) 2023/988 is explicit: the GPSR applies to products subject to sector-specific legislation «only in respect of those aspects and risks or categories of risks not covered by those requirements».
In practice, this means that having CE marking partially exempts a product from GPSR obligations — but only for the specific safety aspects covered by the CE directive that generated the marking. A consumer electronics device that carries CE marking under the Low Voltage and EMC Directives has its electrical safety and electromagnetic compatibility addressed by those directives. But if that device also has ergonomic risks, chemical migration from its casing materials, or age-related hazards that the directives do not address, the GPSR fills those gaps. The manufacturer must assess whether their CE documentation leaves any safety aspects unaddressed and supplement it accordingly.
More significantly, the GPSR adds entirely new obligations that apply to CE-marked products regardless of their compliance with sector directives. The most important are: the requirement to display the EU Responsible Person's contact details on the product, packaging, or accompanying documents (Article 9.6 — new even for CE products if the manufacturer is outside the EU); and the obligation to show safety information, manufacturer identity, and Responsible Person details on online listings before purchase (Article 19 — applies to all products including CE-marked ones). Amazon now systematically requests Responsible Person information even for fully CE-compliant electronics, and deactivates listings that do not provide it.
What the law says
Article 2.3 of Regulation (EU) 2023/988: "For products which are subject to specific safety requirements imposed by Union law, this Regulation shall apply only to those aspects and risks or categories of risks which are not covered by those requirements." The Commission's Guidelines C(2025) 7699 recommend a gap analysis to identify which GPSR obligations remain applicable alongside CE requirements.
Consequences of non-compliance
CE marking does not protect against GPSR-specific sanctions. Amazon deactivates listings of CE-marked products that do not provide the EU Responsible Person information now required by the GPSR. EU market surveillance authorities can sanction manufacturers for GPSR gaps even where the CE documentation is complete. Fines up to €100,000 per Member State.
GPSRCheck generates a supplementary GPSR technical file for CE-marked products, covering the aspects and obligations not addressed by CE documentation — including the Responsible Person file and online listing requirements. €49.
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