GPSR · By category
GPSR by product category: toys, electronics, cosmetics and textiles
GPSR is a safety net, not the whole law. Where a category has its own EU safety legislation, that legislation governs the risks it covers and GPSR fills what is left. So a toy seller answers to the toy rules first, a cosmetics seller to the Cosmetics Regulation, and a t-shirt seller to GPSR almost on its own. Getting this wrong usually means buying compliance you did not need, or missing the rulebook that actually applies to you.
How GPSR interacts with category rules
Article 2(1) of GPSR sets the boundary. The regulation applies to products insofar as there are no specific provisions with the same objective under other Union law. Where a product is subject to specific safety requirements, GPSR applies only to the aspects and risks those requirements do not cover.
The Commission published guidelines on 19 November 2025 confirming the intent: the economic-operator obligations in GPSR Chapter III, Section 1 are not meant to apply in addition to the obligations in sector legislation. If your product is a CE-marked toy, you follow the toy rules rather than doing both sets of paperwork.
The edges here are genuinely unsettled, and we would rather say so
Those guidelines do not fully resolve how Article 16 (the Responsible Person) and Article 19 (the information in your listing) interact with CE-marked goods, and practitioners still disagree. The practical answer is the same either way: CE-marked categories have needed an EU-established economic operator since 16 July 2021 under Article 4 of the Market Surveillance Regulation. Showing an EU contact in the listing is the safe position regardless of how that argument settles.
Where enforcement actually lands
EU Safety Gate alerts by product category, 2025
Share of all 4,671 validated alerts
Everything from childcare articles to motor vehicles
Source: European Commission, Safety Gate 2025 annual report.
| Category | Share of alerts |
|---|---|
| Cosmetics | 36% |
| Toys | 16% |
| Electrical appliances and equipment | 11% |
| All other categories | 37% |
Chemical risk drove 53% of 2025 alerts, ahead of injuries at 14% and choking at 9%. One banned fragrance ingredient, BMHCA, accounted for 1,278 alerts on its own. If you sell in a category where the risk is chemical rather than mechanical, your exposure is in your formulations and your suppliers' substance declarations, not in your instruction leaflet.
Toys
Toys are fully harmonised. Today that means the Toy Safety Directive 2009/48/EC, CE marking, an EU declaration of conformity, technical documentation, and the EN 71 standards for mechanical, flammability and chemical safety. GPSR does not replace any of it.
The regime is changing. Regulation (EU) 2025/2509 was adopted on 12 December 2025 and entered into force on 23 December 2025, replacing the directive. It applies from 1 August 2030 after a 54-month transition, and it makes a digital product passport mandatory for every toy placed on the EU market, accessible from a data carrier such as a QR code. It also tightens the chemical rules and addresses connected and digital toys.
2030 is not far away for a product line
Nothing changes for your current listings yet, and anyone selling you toy compliance work for 2026 on the basis of the new regulation is ahead of the law. What it does change is sourcing decisions for products you expect to still be selling at the end of the decade.
Electronics and electricals
Also harmonised, and usually under several directives at once. A mains-powered device falls under the Low Voltage Directive. Anything that can emit or be disturbed by electromagnetic interference falls under the EMC Directive. Anything with Wi-Fi, Bluetooth or any other radio falls under the Radio Equipment Directive. Substance limits come from RoHS. All of them mean CE marking and a declaration of conformity.
Then there is the waste side, which is where online sellers most often have a gap. Electricals need WEEE registration in each country you sell into, and anything containing a battery needs battery registration as well, with its own authorised representative requirement since 18 August 2025. We cover both in WEEE and battery registration for online sellers.
Cosmetics
Cosmetics have the most complete regime of the four and the one least like GPSR. Regulation (EC) No 1223/2009 requires a Responsible Person established in the EU, named on the label, who notifies every product through the CPNP portal before it is placed on the market and holds the product information file, including a cosmetic product safety report.
That is a different appointment from a GPSR Responsible Person, and one does not stand in for the other. Cosmetics were 36% of all Safety Gate alerts in 2025, the largest category, driven overwhelmingly by banned substances: BMHCA, restricted since 2022, still generated 1,278 alerts, and the TPO ban that took effect in September 2025 produced 60 more in its first months.
Old stock is the usual cause
Most cosmetics alerts are not new formulations that broke a rule. They are products made before a substance was restricted and still sitting in a warehouse or a dropshipping catalogue. If you resell cosmetics you did not formulate, the substance restriction dates matter more than any label check.
Textiles and apparel
Textiles are the interesting case, because there is no CE marking and no sector safety regulation. GPSR is the rulebook, which means the full Article 9 and Article 19 set applies to you directly: manufacturer identification on the product, a Responsible Person if the manufacturer is outside the EU, and all of it visible in the listing. Apparel sellers often assume they are the least regulated category and are in fact the most directly exposed to GPSR itself.
Separately, fibre composition labelling is required under Regulation (EU) No 1007/2011, and chemical restrictions reach textiles through REACH.
The bigger change is EPR. France has run textile EPR through Refashion for years and the Netherlands brought its decree into force on 1 July 2023. The revised Waste Framework Directive entered into force on 16 October 2025, making textile EPR mandatory in every member state. Countries must transpose it by June 2027 and have schemes operating by April 2028. Separate collection of textile waste has already been required across the EU since 1 January 2025.
Everything else
Furniture, homewares, stationery, kitchen items, sports goods, pet products and most general merchandise sit outside harmonised legislation. For all of them GPSR is the primary rulebook, in full, and the labelling requirements apply without any sector law to displace them.
| Category | Main rulebook | CE marked | EPR streams to check |
|---|---|---|---|
| Toys | Toy Safety Directive, then Regulation (EU) 2025/2509 from 2030 | Yes | Packaging, batteries if included |
| Electricals | LVD, EMC, RED, RoHS | Yes | Packaging, WEEE, batteries |
| Cosmetics | Regulation (EC) No 1223/2009 | No | Packaging |
| Textiles and apparel | GPSR, plus fibre labelling under 1007/2011 | No | Packaging, textiles from 2028 |
| General merchandise | GPSR | No | Packaging |
How Assuro helps
Assuro reads your Shopify catalogue and flags, per product, what is missing and which markets that affects, including the EPR streams your category pulls in. We organize and flag. We do not test products, issue CE marks, write declarations of conformity, or notify cosmetics through CPNP.
Frequently asked questions
Does GPSR apply to CE-marked products like toys and electronics?
Partly. GPSR applies to aspects and risks that sector legislation does not cover. For toys and electronics the safety requirements and most economic-operator duties come from the sector rules, and the Commission's November 2025 guidelines confirm GPSR Chapter III duties are not meant to stack on top. You still need an EU-established economic operator, which Article 4 of Regulation (EU) 2019/1020 has required since 16 July 2021.
Do I need a GPSR Responsible Person if I sell cosmetics?
You need a Responsible Person under the Cosmetics Regulation, which is a separate and older requirement. They must be EU-established, named on the label, and must notify each product through CPNP. Do not assume a general GPSR service covers it, and check which regulation any provider's mandate names.
Are clothes and textiles covered by GPSR?
Yes, and more directly than most categories. There is no sector safety regulation for textiles, so GPSR applies in full: manufacturer identification, a Responsible Person where the manufacturer is outside the EU, and the Article 19 information in every online offer. Fibre composition labelling is separate, under Regulation (EU) No 1007/2011.
When does the new Toy Safety Regulation actually apply?
Regulation (EU) 2025/2509 entered into force on 23 December 2025 but applies from 1 August 2030, after a 54-month transition. Until then the Toy Safety Directive 2009/48/EC governs. The headline change is a mandatory digital product passport for every toy.
Which category gets flagged most by EU authorities?
Cosmetics, by a wide margin. They were 36% of the 4,671 Safety Gate alerts in 2025, ahead of toys at 16% and electrical appliances at 11%. Chemical risk accounted for 53% of all alerts.
See where your store actually stands
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