Does GPSR apply to sellers based outside the EU?
Yes. Regulation (EU) 2023/988 applies based on where the product is sold — not where the seller is based. Any business or individual selling non-food consumer products to customers located in the EU is within scope, regardless of whether they are in the United States, United Kingdom, China, Australia, Canada, or any other country. This extraterritorial reach is deliberate: the EU's approach is to protect its consumers, and it achieves this by requiring compliance from anyone who wants access to the EU market, wherever in the world they operate from.
For non-EU sellers, the most significant practical consequence of the GPSR is the mandatory EU Responsible Person requirement. Article 16 of the GPSR states clearly that no non-food consumer product can be placed on the EU market without an identified economic operator physically established in the EU. For a non-EU manufacturer selling directly to EU consumers online — whether through Amazon, Etsy, their own website, or any other channel — this means designating an EU-based entity as the Responsible Person before the first sale. The Responsible Person can be an EU importer who buys stock and resells it, an authorised representative formally appointed by the manufacturer in writing, or a specialist compliance service provider with an EU address.
UK-based sellers are in a particular position after Brexit: since the UK is no longer a Member State of the EU or EEA, a UK company no longer qualifies as an EU Responsible Person. UK sellers who previously relied on their own UK address must now designate a separate EU-based entity. This applies even for Northern Ireland — while Northern Ireland has its own product safety rules with EU alignment, a Northern Ireland address does not automatically satisfy the GPSR's EU establishment requirement for all product categories. Beyond the Responsible Person, non-EU sellers must also ensure each product has a complete GPSR technical file, correct labelling with the Responsible Person's EU contact details, and compliant listings on any EU-facing marketplaces.
What the law says
Article 16.1 of Regulation (EU) 2023/988: Before placing a product on the EU market, manufacturers must ensure there is an economic operator established in the EU responsible for GPSR compliance. This obligation applies universally to all manufacturers, wherever they are based, including the US, UK, China, and Australia.
Consequences of non-compliance
Products without an EU Responsible Person can be blocked at EU customs before reaching any consumer. Amazon, eBay, and Etsy deactivate listings that do not provide EU Responsible Person details. Fines of up to €100,000 per Member State, enforced against whoever can be found within EU jurisdiction — which is typically the importer or the platform account holder.
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