What is GPSR and what must a China importer to the EU actually do?

What GPSR Actually Requires

GPSR covers nearly all consumer products sold in the EU and shifts safety accountability onto economic operators. Before placing a product on the EU market, the importer must verify the manufacturer's compliance, add its own contact details, keep documentation available, and cooperate on corrective action. From 1 October 2026 the importer can itself serve as the Article 16 responsible person — but only if it is established in the EU and actually places the product on the market. Selling direct from non-EU stock means you usually need a separate authorised representative with a written mandate.

The Responsible Person Is Not Optional

Every product in GPSR scope needs an economic operator established in the EU before it is placed on the market. That operator can be the EU manufacturer, the EU importer, a mandated authorised representative, or (as fallback) a fulfilment service provider. The responsible person's name, registered trade name/trademark, postal address, and email must appear on the product, packaging, parcel, or accompanying document — and, for distance sales, clearly on the online offer. No responsible person means no legal EU market access.

A Real-World Case

A Shenzhen electronics brand sold earbuds to Germany via its own Shopify store, shipping from a Shenzhen warehouse. In early 2025 a market-surveillance authority asked for the responsible person; the listing named only the Chinese company. Because no EU-established operator existed, the listing was suspended within days and a batch was held at the border. The brand then appointed an EU authorised representative, uploaded the technical file and risk assessment, and added the RP details to the pack and listing. Sales resumed — but only after the compliance gap cost three weeks of revenue.

The Paperwork You Must Hold

GPSR is documentation-heavy. The responsible person must be able to produce, on request, the technical file (specifications, risk assessment, test reports, Declaration of Conformity, labels, instructions) retained for 10 years, and provide evidence of periodic compliance checks.

How RND SOURCING Handles GPSR

RND SOURCING treats GPSR as a precondition, not a checkbox. For EU-bound shipments we confirm the product has a valid technical file and test reports, appoint or verify an EU responsible person, and make sure the RP details are printed on the physical product and the marketplace listing before goods leave China. We keep the files accessible so a market-surveillance request is answered in days, not weeks.

Step-by-Step: Get GPSR-Ready

1. Map every SKU to its EU responsible person (importer, authorised rep, or fulfilment provider).
2. Collect and store the technical file and Declaration of Conformity per product.
3. Register on the EU Safety Gate Online Marketplace Module.
4. Print RP name, address and email on pack and show them on every listing.
5. Run a documented compliance check before each production run.

Common Mistakes to Avoid

• Using a reseller as 'the responsible person' when they never actually import the goods.
• Thinking a CE mark alone satisfies GPSR — the RP and technical file are separate duties.
• Keeping the technical file only in China where authorities cannot access it quickly.
• Shipping direct-to-consumer from non-EU stock without a mandated authorised rep.

Key Takeaways

• GPSR has applied since 13 Dec 2024 — it is live law, not a proposal.
• An EU responsible person is mandatory for market access.
• Technical files must be kept 10 years and producible on request.
• From 1 Oct 2026 the EU importer can be the responsible person — if it is truly EU-established.

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