GPSR · Asia-based sellers
GPSR for sellers in China, Hong Kong and India shipping to the EU
If you manufacture or ship from Asia and sell to EU consumers, GPSR applies to you directly, and you cannot fill the EU contact role yourself. Since 13 December 2024 a consumer product cannot be placed on the EU market unless an EU-established economic operator is responsible for it, and that operator's name and full contact details must appear in the offer the customer sees before buying. Products of Chinese origin drew 2,006 of the 4,671 EU Safety Gate alerts in 2025, so this is also the group under the most scrutiny.
Why your listings get checked first
Dangerous-product alerts in the EU Safety Gate, per year
Validated alerts
Source: European Commission, Safety Gate annual reports 2022 to 2025.
| Year | Alerts |
|---|---|
| 2022 | 2,117 |
| 2023 | 3,412 |
| 2024 | 4,137 |
| 2025 | 4,671 |
In 2025 EU authorities validated 4,671 alerts, close to 100 a week, and took a record 5,794 follow-up actions. Products of Chinese origin accounted for 2,006 of them, the largest single country of origin. The 2024 report put China at 40% of alerts, rising to 61% once cosmetics were excluded, and around 85% of dangerous toys and electrical appliances were manufactured there.
This is not a claim about your products
Volume explains a lot of it: most consumer goods sold into the EU are made in Asia, so most alerts will be too. What it does mean in practice is that origin is a signal authorities use when deciding what to look at, and the first thing they look at is your listing.
That last point is the operational one. The Commission's eSurveillance web crawler inspected more than 1.6 million URLs in 2025 and found over 20,800 offers of dangerous products. Enforcement increasingly begins with software reading product pages, which is precisely where GPSR Article 19 applies.
You cannot be your own Responsible Person
The role has to be filled by someone established in the Union. A company in Shenzhen, Hong Kong or Mumbai cannot appoint itself, and an employee of yours living in the EU is not sufficient on its own either. There are four ways to fill it:
- An EU-established manufacturer, which does not apply if you manufacture in Asia.
- An importer established in the EU, if a European business is buying from you and placing the goods on the market.
- An authorised representative holding a written mandate that expressly covers the Responsible Person tasks. This is the usual route for direct-to-consumer sellers.
- A fulfilment service provider, but only where none of the above exists. It is the fallback, not a first choice.
Shipping DDP removes your importer
If you sell direct to EU consumers and ship delivered-duty-paid, there is no EU importer in the chain to carry the role. That is the exact scenario the rule was written for, and it is the most common gap we see. You have to appoint someone.
You are probably the manufacturer in EU law
EU product law defines the manufacturer as whoever places a product on the market under their own name or trade mark, not whoever operated the machine. If you buy white-label goods from a factory and sell them under your brand, you are the manufacturer for GPSR purposes and you carry the manufacturer's duties: the technical documentation, the internal risk analysis, and your name and both addresses on the product.
This surprises trading companies and brand owners more than factories. If your supplier's name is nowhere on the item and yours is, the obligations are yours.
What has to appear in the listing
Article 19 requires four things clearly and visibly in the offer itself, not behind a link or on a separate compliance page:
- The manufacturer's name or trade mark, with a postal and an electronic address.
- The EU Responsible Person's name, postal address and electronic address.
- Product identification, including a picture, the type, and any other identifier.
- Warnings and safety information in a language the destination country's consumers easily understand.
Item four is the one that catches exporters selling across several EU markets. English-only safety text is weak for Germany, France, Italy or Spain, and since 19 February 2026 German law states explicitly that instructions and safety information must be in German. The full breakdown is in GPSR labelling requirements.
Does it matter which country you ship from?
For GPSR, no. The obligations are triggered by placing a product on the EU market, not by where you are based. Mainland China, Hong Kong, India, Vietnam and Bangladesh are in the same position: outside the Union, so an EU-established operator is required. Trade agreements, customs treatment and VAT differ by origin, but none of that changes the product-safety duties.
What does change with volume is the customs picture. The EU has agreed to remove the €150 customs duty relief for low-value consignments, with an interim handling charge on parcels from 1 July 2026. That is a landed-cost question rather than a compliance one, but it affects the same orders.
Then there is EPR, which is separate
Product safety is only half of it. If you ship goods in your own packaging directly to consumers in an EU country, you are usually the producer for packaging purposes in that country, because you are the first to place that packaging on its market. That means registering with the national scheme, paying fees by material and weight, and reporting volumes annually. There is no single EU registration, and no EU-wide small-seller exemption.
Start with do you need to register for EPR, then what it costs. From 12 August 2026 the PPWR additionally requires a packaging authorised representative, appointed by written mandate, in each member state where you are not established. The proposal to suspend that rule was discontinued by Council in June 2026, so plan on the date.
A starting checklist
- Confirm whether you or an EU buyer is placing the goods on the market
- Appoint an EU Responsible Person under written mandate if no EU importer exists
- Put their name, postal address and electronic address in every EU product listing
- Add manufacturer name, postal and electronic address, and a type or batch identifier to the product itself
- Translate warnings and safety information for each destination market
- Keep technical documentation and an internal risk analysis available for ten years
- Register for packaging EPR in each country you ship to
- Add WEEE and battery registration if the product is electrical or contains a cell
- Line up a packaging authorised representative per member state for 12 August 2026
How Assuro helps
Assuro connects to a Shopify store and flags, per product, which GPSR fields are missing, where no Responsible Person is on record, and which EU markets that exposes. It tracks the EPR registrations your catalogue pulls in and the deadlines attached to them. It organizes and flags. It does not act as your Responsible Person, test or certify products, or file with any scheme.
Frequently asked questions
Can a company in China or Hong Kong be its own EU Responsible Person?
No. The Responsible Person must be established in the European Union. A non-EU company cannot fill the role for itself, whether it is in mainland China, Hong Kong, India or anywhere else outside the Union. You need an EU importer, an authorised representative under written mandate, or, as a fallback, a fulfilment service provider.
Does GPSR apply if I sell only through a marketplace like Amazon?
Yes. Marketplaces have their own obligations, including collecting trader information and acting on takedown orders, but they do not absorb yours. If your products cannot show a valid EU Responsible Person, the practical outcome is that your listings get removed.
I only ship a few EU orders a month. Does it still apply?
Yes. GPSR has no volume threshold. The obligations attach to placing a product on the EU market, so the first order counts the same as the thousandth. EPR thresholds do exist in a few countries but most have none.
Is the Responsible Person the same as an EPR authorised representative?
No. One covers product safety and can usually serve the whole EU. The other handles waste registration, fees and reporting, and you generally need one per member state. We compare them in detail in the Responsible Person versus authorised representative guide.
We are a factory, and our EU client puts their brand on the goods. Who is responsible?
Whoever places the product on the market under their own name or trade mark is the manufacturer in EU law. If your client brands the goods and imports them, they carry the manufacturer and importer duties. If you ship branded goods direct to EU consumers yourself, you carry them.
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