Paused EU sales because of the GPSR? How to restart without overpaying

Many small brands outside the EU stopped selling to EU customers in December 2024. Here is what the GPSR actually requires, where the cost comes from and how to restart in a way that fits a small business.

By Margus Roosipuu, Founder · Published 14 October 2026

In December 2024, many small brands in the UK, the US and elsewhere stopped shipping to the EU and Northern Ireland. The reason was usually the same: the EU's General Product Safety Regulation (GPSR) requires an economic operator based in the EU for each consumer product, and the quotes for that service were often priced per product type. For a maker with a varied catalogue, the yearly cost could exceed their EU sales.

Nearly two years later, those customers are still there. This guide explains what the GPSR actually asks of a non-EU seller, where the cost comes from, and how to restart in a way that fits a small business.

What the GPSR requires from a non-EU seller

• An economic operator established in the EU. A product covered by the GPSR cannot be placed on the EU market unless an economic operator established in the Union is responsible for it (Article 16(1)). For most sellers who ship directly from outside the EU, this is an authorised representative appointed by a written mandate, often called the EU Responsible Person.
• Their details with the product. The responsible person's name and contact details, including a postal and an email address, must appear on the product or on its packaging, the parcel or an accompanying document (Article 16(3)). For a small seller this matters: a printed insert or a label on the parcel can be enough, so you don't necessarily have to relabel every product.
• Your own details and a product identifier. As the manufacturer, you indicate your name and postal and electronic address, on the product or, where that is not possible, on its packaging or an accompanying document (Article 9(6)). Each product also needs a type, batch or serial number or another element that identifies it (Article 9(5)).
• A short risk analysis and technical documentation. Before selling, the manufacturer carries out an internal risk analysis and draws up technical documentation with at least a general description of the product and its essential safety characteristics. More detail is needed where the risks call for it (Article 9(2)). The documentation is kept for 10 years (Article 9(3)). For a simple, low-risk product, this can be a few pages.
• Instructions and safety information where needed, in a language consumers in the country of sale can easily understand. This does not apply if the product can be used safely without them (Article 9(7)).
• The right information in your online listings. Every online offer must show the manufacturer's details, the responsible person's details when the manufacturer is outside the EU, information that identifies the product including a picture, and any warnings or safety information (Article 19). Amazon, Etsy and eBay collect these details in their own compliance fields. Our marketplace listing checklist walks through them.
• Northern Ireland is included, because EU product safety rules apply there.

Some products are outside the GPSR, for example food, medicines, living plants and animals, and antiques (Article 2(2)). Products covered by specific EU laws, such as toys, electrical equipment or cosmetics, follow those laws as well.

Where the cost comes from, and how to keep it down

• Ask how the price is calculated. Responsible person services price their work per product type, per product family or for a whole catalogue. If you make many unique or similar items, a price per family or per catalogue usually makes more sense than a price per type.
• Group your products into families. Products made from the same materials, with the same use and the same risks, can often be documented and assessed together.
• Start with what sells. Restart with your best-selling, lowest-risk lines rather than the whole range. You can add more later.
• Know what is included. A low headline price may not include document review, label checks, listing details or answering market surveillance authorities. These are the parts that take time when something goes wrong.
• Prepare before you ask for quotes. A clear product list with materials, photos and a short note on how each product is used makes onboarding faster and cheaper.

A restart plan in five steps

1. Choose the products. List what you sell, mark what your EU customers bought before, and pick the lines to restart first.
2. Check the rules for those products. Confirm that the GPSR applies and whether any specific EU law covers them too.
3. Prepare a short technical file for each product family: description, materials, possible risks and how you have addressed them, and instructions or warnings where needed.
4. Appoint your EU responsible person by written mandate, and add their details to a parcel label or insert and to your packaging templates.
5. Update your listings in your own shop and in the compliance fields of Amazon, Etsy or eBay. Keep a dated copy of what you submitted.

Why it is worth doing now

New EU rules Product Liability Directive: products placed on the EU market after 9 December 2026

The EU's new Product Liability Directive applies to products placed on the market after 9 December 2026. For a manufacturer outside the EU, the importer and the authorised representative can both be held liable for damage caused by a defective product. Responsible persons are therefore looking more carefully at the documents they accept, and sellers who prepare well will find onboarding smoother. Read more: what the new EU Product Liability Directive means for non-EU sellers.

How Legatia can help

Legatia sets this up end to end. We check which rules apply to your products, review your documents and labels, prepare the details your listings need, and arrange your EU Responsible Person through a vetted EU partner. You deal with one contact.

Tell us what you sell and where you want to sell it, and we will reply with what you would need. Send us a short note or read more about our GPSR service.

Official sources

• Regulation (EU) 2023/988 on general product safety (GPSR), including Articles 2, 9, 16 and 19.
• Directive (EU) 2024/2853 on liability for defective products.

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