Does GPSR apply to products already on the market before December 2024?

The GPSR includes a transitional provision in Article 48. Products that were compliant with the previous General Product Safety Directive (2001/95/EC) and were placed on the EU market before 13 December 2024 may continue to be made available without being recalled, relabelled, or subjected to the full GPSR documentation requirements. This provision protects existing inventory from retroactive application of the new rules and avoids the commercial disruption of requiring businesses to withdraw millions of compliant products overnight.

However, the transitional protection is narrower than many sellers assume. The key legal concept is «placed on the market» — meaning the moment a specific unit was first supplied to a distributor or made available to a consumer. A batch of product manufactured in October 2024 but first sold to consumers in January 2025 was not placed on the market before the deadline: it is fully subject to the GPSR. Similarly, Amazon clarified that while FBA inventory physically in EU fulfilment centres before 13 December 2024 could continue to sell through, the product detail page — the online listing — had to meet the GPSR's information requirements (Responsible Person, manufacturer details, safety warnings) from that date regardless. The exemption applied to the physical units, not to the listing presentation.

Any new production of a product — even the same model with identical specifications — falls fully under the GPSR from the date of first placement, regardless of when previous versions were on the market. There is no continuing grandfather clause for ongoing production. This means that if you restocked a product from your supplier after 13 December 2024, those new units must have GPSR-compliant labelling, and you must have a technical file covering them. If the design, materials, or manufacturing process changed in any way, the updated product is treated as a new product and requires fresh documentation.

What the law says

Consequences of non-compliance