Does GPSR Apply in Norway, Iceland, Liechtenstein and Switzerland? EEA and Swiss Product Safety Rules

EU, EEA, EFTA and Switzerland are not the same thing

“Europe” is at least three legal markets for product safety:

The Commission's Blue Guide 2022 (section 2.9.2) explains that the EEA Agreement extends the internal market to Iceland, Liechtenstein and Norway and is updated continuously through Joint Committee decisions. Once an act is incorporated, operators in the EEA EFTA States carry the same rights and obligations as their EU counterparts. The incorporation step is what matters.

Norway, Iceland, Liechtenstein: when will the GPSR apply?

The words “Text with EEA relevance” under the GPSR's title mean the act is meant to be incorporated into the EEA Agreement, not that it already applies there. When we checked EFTA's EEA-Lex entry for 32023R0988 on 8 November 2026, its status was a draft Joint Committee Decision under consideration by the EU (European Commission) and the EFTA States, with no decision number and no EEA entry-into-force date. In practice:

• the GPSR is not yet in force in these three countries as EEA law (to be re-checked against the latest EEA-Lex status);
• after the decision is adopted it still has to enter into force, and it may contain EEA-specific adaptations, for example on how “established in the Union” is read;
• until then, each country's existing product safety rules apply. The old Directive 2001/95/EC (GPSD) was part of the EEA Agreement, so those national rules are generally based on it; confirm with the national authority (to be re-checked).

Sector rules for CE products (toys, electrical equipment, radio equipment and so on) are a separate question: many are already in the EEA Agreement and apply in these countries as in the EU. Check each act's status on EEA-Lex; the GPSR still being pending says nothing about your CE rules.

Liechtenstein is a special case: it is in the EEA and also in a customs union with Switzerland, so two sets of rules can overlap. Confirm with the Liechtenstein authorities.

Does an EU responsible person cover Norway? What to do now

GPSR Article 16 requires a responsible person established in the Union. While the GPSR is not part of the EEA Agreement, that rule has no legal force in Norway, Iceland or Liechtenstein, so printing your EU responsible person on the pack does not satisfy a Norwegian legal requirement. Equally, a company based in Norway is not currently an EU-established responsible person for the EU-27. What changes after incorporation depends on the text of the Joint Committee Decision.

For sellers who sell into both the EU and the Nordic EEA countries, a sensible approach is:

1. Build to the GPSR standard: risk analysis, technical documentation, type or batch number, manufacturer details, safety information. You will need these once the GPSR is incorporated, and they help meet the general safety duty under national law today.
2. Keep the EU responsible person on the label: it is lawful and prepares you for incorporation, but do not present it as a Norwegian legal representative.
3. Check languages separately: confirm Norwegian and Icelandic requirements for instructions and warnings with local rules; see the approach in language rules for warnings and instructions.
4. Re-check EEA-Lex regularly: once the status shows the act as incorporated and in force, close any gaps the decision creates.

Switzerland: the Product Safety Act (PrSG), not the GPSR

According to the Swiss State Secretariat for Economic Affairs (SECO), the Federal Act on Product Safety (Produktesicherheitsgesetz, PrSG, SR 930.11) has been in force since 1 July 2010 and governs the safety of products placed on the market commercially or professionally. It transposed the old EU Directive 2001/95/EC into Swiss law, and Switzerland aims for an equivalent level of safety and equivalent principles to the EU, adopting key elements of EU rules where sensible. Like the GPSR, the PrSG applies only where no product-specific law pursues the same aim, and it has an implementing ordinance (PrSV).

Three points matter for sellers:

• The GPSR does not apply in Switzerland. GPSR mechanisms such as the EU responsible person and Safety Business Gateway notifications are not Swiss legal duties.
• Switzerland is catching up. On 5 June 2026 the Federal Council opened a consultation on a partial revision of the PrSG, in parallel with a revision of the Federal Act on Technical Barriers to Trade (THG); it closed on 28 September 2026. The draft proposes that operators selling online provide product identification, warnings and safety information, name a contact point and cooperate with authorities; new surveillance tools such as an information and warning system, test purchases under a covert identity and blocking of non-compliant online offers; and a possible supervision levy on products ordered online and shipped directly from abroad to users in Switzerland. As of 8 November 2026 this is still a draft (to be re-checked).
• The MRA is not the GPSR. The EU–Switzerland Mutual Recognition Agreement covers conformity assessment in some CE sectors, such as machinery, lifts, pressure equipment, gas appliances and personal protective equipment. It does not deal with general consumer product safety, and its coverage of individual sectors can change; check SECO.

Selling into Switzerland in practice

We did not find a general rule in SECO's public information requiring a Swiss representative for ordinary consumer products under the PrSG (to be re-checked). Some sector laws may require a person in Switzerland, so check the rules for your category. Practical steps:

• Give at least the manufacturer's name and contact details, a type or batch number, and the warnings and instructions needed for safe use. This largely matches GPSR Article 9, so one label design can serve both.
• Switzerland has several official languages, including German, French and Italian; check which languages your instructions and warnings need for the regions you sell to.
• If a platform asks for extra fields for its Swiss store or for shipping to Switzerland, follow what the platform currently shows; filling in EU GPSR fields does not by itself prove Swiss compliance.
• Follow the PrSG revision: once adopted, Swiss online information duties are likely to look more like GPSR Article 19.

For the full EU picture see what is GPSR and EU Responsible Person; for the UK and Northern Ireland see UK GPSR rules.