GPSR for China Importers: Your 2026 Compliance Checklist

Is GPSR Live? Yes — and the Importer Is Now the Responsible Person

The EU's General Produkt Safety Regulation is not a proposal, a pilot or a consultation. It has been fully applicable since 13 December 2024, replacing the old General Produkt Safety Directive, and it changed who is legally answerable for a Produkt sold into Europe. Under the GPSR, a Produkt whose manufacturer sits outside the Union cannot be placed on the EU Markt at all unless there is an economic operator established inside the Union acting as the responsible person. For a China-made Produkt imported by you, that person is normally you.

This is the part most China importers miss. GPSR is not primarily about factories. It is about accountability, and the regulation deliberately places that accountability as close as possible to the consumer — which means on the importer's desk. The good news is that almost every obligation is procedural, documentable and preparable in advance. This checklist walks through the seven things that matter, in the order it pays to do them.

What GPSR Actually Changed, in One Paragraph

Regulation (EU) 2023/988 sets a single, directly applicable safety framework across all 27 member states. It replaced both the General Produkt Safety Directive (2001/95/EC) and the food-imitating products Directive, and it added the concepts that now drive enforcement: a mandatory responsible person in the Union, a mandatory technical file per Produkt, expanded traceability and labelling duties, an obligation to report accidents through the Safety Business Gateway, and — new for this regulation — binding obligations on online marketplaces to police listings. Because it is a regulation rather than a directive, it does not need national transposition: it applies in full, everywhere, in the same words.

The Responsible Person: The One Concept That Governs Everything

Article 16 of the GPSR creates the linchpin. Where the manufacturer is not established in the Union, the importer must ensure that a responsible person is established in the Union, that the Produkt carries their identity, and that the technical documentation can be produced on demand. In practice, importers take one of two paths: they act as the responsible person themselves (common when they already have an EU entity, warehouse or fiscal representative), or they appoint an authorised representative under a written mandate.

A responsible person is not a mailbox. Article 16 requires them to Ueberpruefen that the technical documentation exists, to hold it available for 10 years after the Produkt is placed on the Markt, to cooperate with Markt surveillance authorities, and to inform authorities without delay if they believe a Produkt is dangerous. If you appoint a representative service, confirm in writing that they will actually perform those tasks — a service that only provides an address is a compliance gap dressed as a solution.

Step 1 — Appoint an EU Authorised Representative and Name Them Everywhere

If you go the authorised-representative route, the appointment must be in writing and the name and contact details must appear on the Produkt itself — or, where that is genuinely impossible (very small items, certain packaging), on the packaging or in an accompanying document, and in the online listing. Markt surveillance authorities and consumers must be able to find the responsible person's postal address and electronic address without effort. The most common enforcement finding is not a dangerous Produkt; it is a Produkt with the wrong name on it.

A GPSR file is not proof that a Produkt is safe. It is proof that someone in the Union can be held to account for it — which is exactly what the regulation was designed to create.

Step 2 — Build a Technical File for Every SKU

The technical file is where compliance becomes real work rather than a form. For each SKU, assemble: the declaration of conformity and the applicable harmonised standards or test reports; a risk assessment of the Produkt and its foreseeable use; evidence of traceability (batch, lot or serial numbering and the link to the Fabrik); drawings or specifications where relevant; and the record of which warnings, instructions and language versions ship with the Produkt. When your SKUs are supplied from China, the test reports and standards evidence have to come from your Lieferant — so the file-building exercise doubles as a Lieferant-quality screen.

Two practical rules keep this manageable. First, build the file from the same test reports you already collect for CE and RoHS rather than commissioning new ones. Second, version the file and date every revision, because the question in an inspection is not "do you have documents?" but "does this document describe the unit that shipped in March?"

Step 3 — Label the Produkt Properly: EU Contact Details, Model, Batch Number

Article 9 of the GPSR sets out what must appear. The Produkt — or, where size or nature makes it impossible, its packaging or an accompanying document — must carry the manufacturer's name, registered trade name or registered trademark and postal address; where the manufacturer is outside the Union, the name and postal and electronic address of the responsible person; and information identifying the Produkt, including its type and any batch, serial or other identifier. Safety warnings and instructions must accompany the Produkt. None of this is optional decoration — each element is a separate line an inspector can tick or fail.

The batch or serial number deserves special attention because it is what makes traceability possible at all. Without it, a defect found in one production run forces you to treat every unit you have ever imported as suspect. With it, you can isolate the run, notify only the affected buyers, and keep the rest of your catalogue selling. Insist that your Fabrik prints or applies it before packing, not after the container arrives.

Step 4 — Get the Language Right for Each Markt, Not Just English

Warnings, instructions and safety information must be in a language consumers in the destination member state can easily understand, as determined by that member state. English satisfies this in Ireland and, in practice, in the Nordics and the Netherlands — but it does not satisfy France, Germany, Italy, Poland, Spain or Portugal. If you sell into several EU markets from one warehouse, you need per-Markt language versions prepared in advance, not a single English leaflet with a translated sticker added later. For a China-based Lieferant, this usually means commissioning the localised instruction sheets and label variants as part of the packaging specification, which is far cheaper than a post-launch correction.

Step 5 — Keep the Records: Ten Years and the Safety Business Gateway

The GPSR requires the technical documentation and the traceability records to be kept for 10 years from the date the Produkt is placed on the Markt, and to be made available to Markt surveillance authorities on request. Ten years is longer than most importers' document retention habits, and it is longer than most Lieferant relationships last — which is precisely why the file should live with the responsible person rather than in your inbox. Alongside the file, register with the Safety Business Gateway, the Commission's channel for economic operators, so you have the account, contact details and process in place before you ever need to use it.

Step 6 — Report Serious Risks Immediately, Not Eventually

When you know, or should presume, that a Produkt you placed on the Markt presents a serious risk, the GPSR requires you to inform the Markt surveillance authority immediately — without waiting for a formal investigation or a confirmed incident count. Accidents caused by a Produkt must be notified without undue delay once you learn of them, and where the manufacturer is outside the Union, the responsible person must ensure the notification is made. Reporting early is not an admission of liability; it is the behaviour the regulation is built around, and authorities weigh cooperation heavily when deciding how hard to push a corrective action.

The Marketplace Squeeze: Amazon, Temu and Shein Now Police This for You

Article 22 of the GPSR is the provision importers feel first. Online marketplaces must register with the Safety Gate Portal, designate a single point of contact for authorities and another for consumers, and — when a member state issues an order about a dangerous Produkt listing — act within two working days to remove the content, disable access or display a warning. The practical consequence is brutal in its simplicity: if your listing cannot show the manufacturer, the responsible person and the Produkt identifier, it is a candidate for suspension, and the marketplace has no incentive to argue on your behalf.

Amazon, TikTok Shop, Temu and Walmart each translate this into their own documentation demands — verified business identity, safety test documents, origin marking, traceable barcodes and a named accountable party. The failure mode is not a rejected application; it is on-demand documentation you cannot reproduce. If a platform asks for a test report and you cannot produce the same report you filed six months ago, the listing comes down while you rebuild it.

What Enforcement Looked Like in 2026

The Commission and national authorities publish the outcome of their sweeps, and the 2026 results are instructive. Across roughly 1,700 listings on 35 online marketplaces examined between May and July 2026, 91% of marketplaces had registered on the Safety Gate Portal and had named a contact point for authorities — up from 53% a year earlier — and 100% had designated a single point of contact for consumers, up from 64%. But only 58% of the listings reviewed simultaneously showed the manufacturer, the EU responsible person and the Produkt identification. Authorities issued 560 orders to marketplaces over non-compliant listings. Compliance by the platforms has improved sharply; compliance at the listing level has not.

The Safety Gate alert stream tells the same story from the Produkt side. Alerts published in 2026 include a Chinese-origin rechargeable drill rejected at the border for insufficient insulation, an electric bicycle rejected at Import and destroyed for a missing fuse in the plug, and an electric grinder ordered recalled and withdrawn from the Markt after being listed on Amazon — in each case the measure landed on the importer or the marketplace, not the distant Fabrik.

Your GPSR Obligation Map

A Ten-Point GPSR Readiness Checklist

• Confirm whether you are the responsible person — or appoint an authorised representative in writing.
• Put the EU operator's name, postal address and electronic address on the Produkt, packaging and listing.
• Build one technical file per SKU, reusing the CE and RoHS test reports you already hold.
• Add a declaration of conformity and a written risk assessment to every file.
• Require batch, lot or serial markings from the Fabrik before packing — never after arrival.
• Prepare per-Markt language versions of warnings and instructions for FR, DE, IT, PL, ES and PT.
• Hold documentation and traceability records for ten years, with the responsible person.
• Register on the Safety Business Gateway and name a contact before you need it.
• Define who reports a serious risk, and how fast — immediate means immediate.
• Ueberpruefen every marketplace listing shows manufacturer, responsible person and Produkt identifier.

How a Yiwu-Based Sourcing Partner Lifts This Burden

Most of these obligations are document problems before they are legal problems, and document problems are solved at the source. Working through a sourcing partner based in Yiwu with an established EU-facing process changes the sequence: batch numbering is specified in the purchase order, test reports and conformity declarations are collected as a condition of shipment, packaging is produced with the EU contact block and the correct local-language insert already printed, and every file is handed over in a structure your responsible person can retain for the decade the regulation requires. The alternative — discovering the gap when a listing is suspended or a container is stopped — costs both the sale and the rework.

References

• European Parliament and Council, Regulation (EU) 2023/988 on general Produkt safety (GPSR), applicable from 13 December 2024 — EUR-Lex consolidated text (Articles 9, 10, 16, 17, 20 and 22).
• European Commission, Produkt safety — obligations for businesses, Safety Gate and Safety Business Gateway information pages (ec.europa.eu).
• European Commission, Produkt safety sweep 2026 shows improved compliance with EU Produkt safety rules, although gaps remain, press release, 7 September 2026 — 1,700 listings across 35 online marketplaces; 560 removal orders.
• European Commission, Safety Gate rapid alert system, alert records for 2026 concerning Chinese-origin imports (border rejection, destruction and recall measures).