GPSR basics

The Commission's GPSR Guidelines for Businesses (C/2025/6233): What Sellers Need to Know

Last checked against the official texts: 7 November 2026 · Based on Regulation (EU) 2023/988

Short answer

Commission Notice C/2025/6233, published in the Official Journal on 21 November 2025 under Article 17(2) GPSR, explains role by role what manufacturers, authorised representatives, importers, distributors, fulfilment service providers, responsible persons and online marketplaces must do, with a checklist for each. It clarifies points such as software and second-hand goods, per-model technical files, when label details may move to the packaging and what an "electronic address" is. The Notice itself says it is guidance only: the legislation has legal force, and binding interpretation belongs to the EU Court of Justice.

Key points

Full title: Commission Notice – Guidelines on the application of the EU general product safety legislative framework by businesses (C/2025/6233), OJ C series, 21.11.2025.
Adopted under GPSR Article 17(2) with SMEs in mind; a separate Notice on the Safety Business Gateway (C/2025/6238) was published the same day.
The Commission reads "product" broadly: apps and software (even chatbots), second-hand and refurbished goods are covered, and mental-health risks count.
Technical documentation is per model, with separate files for variants whose differences may affect safety; in principle only size, not aesthetics, justifies moving label details off the product.
An electronic address is an email or a website section allowing direct contact; a bare website is not enough.
The guidelines add no obligations and set no fines; cite them next to the article of the regulation, never instead of it.

What this document is

On 21 November 2025 the European Commission published Commission Notice C/2025/6233, "Guidelines on the application of the EU general product safety legislative framework by businesses", in the C series of the Official Journal (CELEX 52025XC06233). It is the document most people mean by "the Commission's GPSR guidelines".

The Notice says it was prepared as required by Article 17(2) of the GPSR, which tells the Commission to adopt specific guidelines for economic operators, with particular regard to SMEs and micro-enterprises. It also reflects questions raised in the first year of application.

Chapters 1 and 2 cover who has obligations, what a safe product is and scope. Chapter 3 goes role by role (3.1.1 manufacturer, 3.1.2 authorised representative, 3.1.3 importer, 3.1.4 distributor, 3.1.5 fulfilment service provider, 3.2 responsible person, 3.3 online marketplaces), each with a checklist, and 3.4 covers recalls, remedies and the Safety Business Gateway. Paragraphs are not numbered, so this article cites the Notice's points, e.g. "point 3.1.1".

Legal status. The introduction is explicit: the Notice is "intended purely as a guidance document – only the text of the EU legislation itself has legal force". Binding interpretation of EU law is the exclusive competence of the EU Court of Justice, and the Commission's position before the Court is not prejudged. The Notice also says it reflects the situation at the time of drafting and may be modified later.

The same day, the Commission published a companion Notice, C/2025/6238, on the practical implementation of the Safety Business Gateway under Article 27(2) GPSR. It carries the same disclaimer.

Scope: which products and sales are covered

Points 2.1 and 2.3 add useful readings of Articles 2, 3(1) and 4 GPSR:

"Any item", including software. The Commission reads the product definition as covering tangible, non-tangible and mixed items, naming apps and software, "including for example chatbots". For hardware with an app or firmware, software risks belong in your risk analysis.
Professional products that migrate to consumers, such as renovation products sold in DIY shops, are covered.
Second-hand, refurbished and repaired goods sold by an economic operator are fully covered; consumers' own repairs are not. The only carve-out is goods that must be repaired or reconditioned before use and are clearly marked as such (Article 2(3)).
The transition is unit by unit. Placing on the market is assessed for each unit. Units placed on the market under the old directive before 13 December 2024 need not carry the new GPSR information (Article 51), but any offer made from that date must comply.
When an online offer targets the EU is decided case by case under Article 4, looking at shipping destinations, languages, payment methods, currency and domain name.
Purely consumer-to-consumer sales are outside the GPSR; products supplied in a service, such as rented bikes, are inside.

Point 1.2 adds that safety includes mental health (for example anxiety or poor sleep quality) and that all businesses must take account of the precautionary principle (Article 2(5)). The exclusions mirror Article 2(2); see What is GPSR.

CE-marked products and Article 4 of Regulation 2019/1020

Point 2.2 turns Article 2(1) GPSR into a clear list. For products subject to Union harmonisation legislation (toys, electrical and radio equipment, cosmetics and so on):

GPSR part	Applies to harmonised products?
Chapter I – general provisions (incl. Article 4 on distance sales)	Yes
Chapter II – safety requirements	Only for risks not covered by the sector law
Chapter III Section 1 (Articles 9–18: operator duties, technical documentation, labelling, Article 16)	No
Chapter III Section 2 (Article 19 online offers, Article 20 accidents, Article 21 electronic information)	Yes
Chapter IV – online marketplaces; Chapter VI – Safety Gate and Safety Business Gateway; Chapter VIII – recall information and remedies	Yes
Chapters V, VII and IX–XI	No

The Commission's examples: childcare articles, gym equipment and furniture have no specific EU safety law, so the GPSR applies in full; for low-voltage devices it can still cover self-learning functions the Low Voltage Directive does not address. Footnote 17 confirms that the GPSR technical documentation duty does not apply to harmonised products, which follow their own sector rules.

On the responsible person, point 3.2 refers to Article 4(3) of Regulation (EU) 2019/1020 and Article 16 GPSR, and to the Commission's 2021 Article 4 guidelines (OJ C 100, 23.3.2021). For CE-marked products listed in Article 4(5) of 2019/1020, the requirement comes from that regulation directly, with much the same result. See GPSR vs CE marking and Who is the EU Responsible Person.

What the guidelines clarify for economic operators

Chapter 3 asks you to decide your role product by product: one company can be a distributor for one product and a manufacturer for another. Key clarifications for cross-border sellers:

Topic	What the guidelines say (point)	What sellers should do	GPSR article
Rebranding	A company that buys mugs from a producer and sells them under its own logo becomes the manufacturer (3.1.1, 3.4.4)	Private-label sellers take on the full manufacturer role	Art. 3(8), 13
Risk analysis	Design, composition, packaging, instructions, interaction with other products or software, vulnerable users, food-imitating or child-appealing looks, cybersecurity (3.1.1)	Address each item in writing; a test report alone is not a risk analysis	Art. 6, 9(2)
Technical documentation	Per model; variants whose colour, composition or functions may affect safety need their own file; list every identified risk regardless of level; a non-compulsory template is provided (3.1.1)	One folder per model and variant, kept up to date for 10 years	Art. 9(2)–(3)
Where label details go	Your choice within the rules, but be ready to justify it; in principle only product size, "not, for example, aesthetic" reasons, justifies moving details to packaging or a document (3.1.1, 3.1.3)	Print on the product where it fits; record why small items use packaging	Art. 9(5)–(6), 11(3)
Electronic address	An email or a website section that allows direct contact; "A website is not in itself sufficient" without direct communication (3.1.1, 3.2)	Use a monitored mailbox or contact-form URL, not a homepage	Art. 9(6), 16(3)
Instructions and language	Language set by the member state of sale; not needed where the product is safe to use without them, e.g. knives (3.1.1)	Prepare versions per country; see GPSR label requirements	Art. 9(7)
Importer stickers	An added label must not obscure required information; bringing a product into conformity may mean adding missing information (3.1.3)	Place EU rep or importer stickers so the original label stays readable	Art. 11(2)–(3)
Responsible person	Required for non-EU manufacturers; regularly checks the product against the technical documentation and labels, with documented evidence on request (3.1.1, 3.2)	Give your representative the file and labels; agree how checks are done	Art. 16
Fulfilment service providers	Can become the responsible person "automatically" if there is no EU manufacturer, importer or authorised representative; a marketplace that also warehouses and packs is a fulfilment service provider for those products (3.1.5)	Do not rely on this fallback as your compliance plan	2019/1020 Art. 4(2)(d)
Loyalty and registration schemes	If they identify products bought, customers must be able to join for safety purposes only, with no marketing use (3.1.1, 3.4.1)	Add a "safety notices only" option to your shop's membership scheme	Art. 35(2)
Complaints and records	Accessible complaint channel, which may be the single contact point; personal data in the register deleted after five years at the latest (3.1.1)	Keep a register of complaints, recalls and corrective measures	Art. 9(11)–(13)
Cooperation	Risk, complaint, accident and corrective-measure information for 10 years; supply-chain data for 6 years (3.4.5)	Keep purchase and sales records	Art. 15

More on roles in economic operator roles, and on files in GPSR technical documentation.

Online offers, marketplaces, accidents and recalls

Distance sales (Article 19). The same list appears under the manufacturer, importer and distributor: an online offer must clearly and visibly show the manufacturer's name and postal and electronic address; the responsible person's details where the manufacturer is outside the EU; product identification including a picture and type; and warnings or safety information in the language of the country of sale. It applies to every economic operator selling at a distance, not just brand owners. Platform details: GPSR information for online listings.

Online marketplaces (point 3.3). Platforms must register on the Safety Gate Portal, act on authority orders within 2 working days, handle third-party safety notices within 3 working days and notify buyers directly of recalls. The Notice flags three duties, interface design for Article 19 information, suspending repeat offenders and random checks, as applying only to medium and large platforms and to micro or small ones designated as very large online platforms. A small platform without dedicated fields does not remove your own Article 19 duty.

Accidents. Events linked to a product's use that caused death or serious adverse effects on health must be notified through the Safety Business Gateway to the authority where they happened, with product type, identification number and known circumstances, such as the victim's age and how the product was used (3.1.1, 3.2).

Safety Business Gateway (3.4.3). You need an EU Login account. Submissions reach all relevant market surveillance authorities immediately; any risk assessment you submit is only indicative. Consumer-facing recall information can be submitted too, but that does not replace contacting consumers directly.

Recalls (3.4.1–3.4.2). Identifiable consumers must be contacted directly, generally by whoever holds their data; the Commission says this is compatible with EU data protection law. Written notices are headed "Product safety recall" and must not use words such as "voluntary" or "precautionary"; the template is in Implementing Regulation (EU) 2024/1435 and available on the Safety Gate Portal. Offer at least two of repair, replacement or a refund of at least the price paid. The Notice adds that GPSR recall remedies have no time limit and consumers need not prove the product is dangerous. See accidents, recalls and Safety Gate.

What the guidelines do not change

They are not law and add no obligations. Authoritative readings come from the legislation, and the Court of Justice has the final word. If the guidance and the regulation seem to differ, the regulation prevails.
They set no fines. The conclusion only notes that member states can fine businesses; penalties are national under Article 44, with no EU-wide amount.
They do not deal with liability, which the GPSR does not regulate.
They do not replace sector law for toys, electronics or cosmetics.
They do not harmonise languages. Each member state still decides; the Notice gives no country list.
They do not bind platforms' own rules. Marketplace fields and review standards are set by each platform, may be stricter and can change.

How to use the guidelines

Keep a copy. Download C/2025/6233 from EUR-Lex and note the date (21.11.2025); EU language versions such as German and French exist.
Read the point for your role. Brand owners: 3.1.1 and 3.4. EU representatives and importers: 3.1.2, 3.1.3 and 3.2. Sellers using EU or marketplace warehouses: 3.1.5. The checklists at the end of each point make a ready-made self-audit.
Map your files against it. Check files, labels, listings and complaint records against it.
Use it as interpretation support. To explain why a small item carries details on its packaging, cite "GPSR Article 9(6)" with "Commission guidelines C/2025/6233, point 3.1.1", presenting the latter as guidance, not law. Whether a platform accepts it is up to the platform; see Amazon GPSR appeals.
Check for updates. The Notice may be revised; note the version you rely on.

Other official material (mostly listed in chapter 4 of the Notice):

the Safety Gate Portal: alerts, weekly reports and national authority contacts;
the Safety Business Gateway, for notifying dangerous products and accidents;
C/2025/6238, the Safety Business Gateway guidelines;
Implementing Regulation (EU) 2024/1435, the recall notice template under Article 36(3) GPSR;
Delegated Regulation (EU) 2024/3173 on the Safety Gate Rapid Alert System and risk assessment criteria;
the 2022 Blue Guide (OJ C 247) and the 2021 Article 4 guidelines (OJ C 100).

Not sure which duties apply to you? Try the 3-step compliance check.

Using the Commission's GPSR guidelines

Download C/2025/6233 from EUR-Lex and note its publication date
Decide your role for each product (manufacturer, distributor, fulfilment service provider and so on)
Work through the checklist at the end of your role's point in chapter 3
For CE-marked products, confirm which GPSR chapters apply and keep the sector-law technical file
Keep technical documentation per model, with separate files for safety-relevant variants
Check that the electronic address on labels is a monitored email or contact page
Confirm every EU listing shows the four Article 19 items
Set up an EU Login account and get familiar with the Safety Business Gateway
When citing the guidelines, quote the GPSR article alongside the point number

Common mistakes

Citing the guidelines as if they were law
The Notice says only the legislation has legal force and binding interpretation belongs to the Court of Justice. In an appeal or a reply to an authority, cite the GPSR article first and then "as interpreted in Commission guidelines C/2025/6233, point x", rather than "the guidelines require".
Assuming CE marking takes a product out of the GPSR
Point 2.2 lists what still applies to harmonised products: Article 19 online information, Article 20 accident reporting, marketplace duties, Safety Gate and the recall and remedy rules. Only parts such as Chapter III Section 1 fall away, with technical files and labels following the sector law.
Moving label details to the leaflet for looks
Point 3.1.1 says that, in principle, only the size of the product can justify moving required information from the product to its packaging or an accompanying document, and you should be able to justify the choice. If it fits on the product, put it on the product.

Frequently asked questions

Are the Commission's GPSR guidelines legally binding?

No. Chapter 1 of the Notice says it is purely guidance, only the legislation has legal force, and binding interpretation is for the EU Court of Justice. It does show how the Commission reads the regulation, which makes it useful for understanding the rules and explaining your approach.

Where can I download C/2025/6233?

On EUR-Lex: search for C/2025/6233 or CELEX 52025XC06233 to get the HTML and PDF of the version published on 21 November 2025. Language versions such as German and French are available there too.

Do the guidelines apply to CE-marked products?

Partly. Point 2.2 explains that the GPSR rules on online offers, accident reporting, marketplaces, Safety Gate and recall remedies apply to harmonised products, while manufacturer duties, technical documentation and labelling follow the sector law.

What if a marketplace asks for more than the guidelines say?

They are different things: the guidelines interpret the law, while marketplace rules are part of your contract with the platform. To keep a listing live you generally need to meet the platform's requirements; if you think the platform has misread the law, you can cite the GPSR article and the relevant point in an appeal, but the decision stays with the platform.

Will the guidelines be updated?

Possibly. The Notice says it reflects the situation at the time of drafting and may be modified. Check EUR-Lex and the Safety Gate Portal from time to time and record which version your compliance files rely on.

Official sources

This guide explains Regulation (EU) 2023/988 in plain language. It is general information, not legal advice. Requirements can depend on your product, other EU laws and the member state — check the official text and, for your own case, a qualified adviser.