GPSR Importer Obligations (Article 11): Paragraph-by-Paragraph Checklist and FAQ

Who is the importer, and when non-EU sellers meet one

GPSR (Regulation (EU) 2023/988) Article 3, point 10: an importer is any natural or legal person established in the EU who places a product from a third country on the EU market. “Placing on the market” means the first making available on the EU market (point 7). Section 3.1.3 of the Commission's business guidelines (C/2025/6233) stresses that the importer is always established in the EU.

Sellers outside the EU usually meet an importer in three situations:

• Your own EU subsidiary buys, imports and sells the goods in its own name: the subsidiary is the importer.
• You sell B2B to an EU wholesaler or retailer that imports and resells in its own name.
• An EU buyer asks you for documents, because as importer it must check your product first.

The declarant on a customs declaration, or the “IOR” your forwarder mentions, is a customs concept and not automatically the GPSR importer; see Amazon FBA vs FBM. An EU company selling a Chinese factory's product under its own trademark is the manufacturer, not the importer (see Article 13 below). The full role comparison is in economic operator roles and is not repeated here.

Article 11, paragraph by paragraph

Compared with a distributor (Article 12), the importer has three extra duties: checking that the technical documentation exists, putting its own details on the product, and keeping the technical file copy for 10 years. See GPSR distributor obligations.

Adding the importer's details without hiding anything

Article 11(3) sets an order: on the product first, then the packaging or an accompanying document. Section 3.1.3 of the Commission's guidelines adds that only the size of the product, not aesthetics, justifies moving the information off the product, and that the importer should be able to justify its choice. The electronic address can be an email address or a website section that allows direct contact; a website alone is not enough.

• Ideally the factory prints the manufacturer's and importer's details at production, so nothing has to be stuck on in an EU warehouse.
• If a sticker is unavoidable, place it where it does not cover the manufacturer's name and address, the identifier or warnings.
• Where several importers handle the same type of product, the Commission's Article 4 guidelines (2021/C 100/01, section 4.2) say each is responsible for the units it placed on the market, and a unit should in principle bear only the name of its own importer.

For label fields and examples, see GPSR label requirements.

When the importer is also the EU responsible person

GPSR Article 16(1) applies Article 4(2) of Regulation (EU) 2019/1020: where the manufacturer is not established in the EU, the importer can be the responsible person. Section 2.2 of the Commission's Article 4 guidelines gives the order: if the manufacturer has mandated an authorised representative in writing for the Article 4 tasks, that representative is the responsible person; otherwise it depends on the supply chain, and an EU importer comes next. The importer checklist in the GPSR guidelines makes the same point: ensure there is a responsible person, and “it can be you”.

As responsible person, the importer additionally has to:

• verify that the technical documentation has been drawn up and ensure it can be made available on request (Regulation 2019/1020, Article 4(3)(a));
• on a reasoned request, provide all information needed to demonstrate conformity in a language the authority easily understands (point (b));
• inform the authorities when it has reason to believe a product presents a risk (point (c)) and cooperate on corrective action (point (d));
• where appropriate to the risk, regularly check that the product matches the technical documentation and the Article 9(5)–(7) requirements, and keep documented evidence of those checks (GPSR Article 16(2));
• show its name and contact details on the product, packaging, parcel or a document (Article 16(3)), which as importer it already does under Article 11(3);
• ensure an accident it learns about is notified through the Safety Business Gateway to the member state where it happened (Article 20(4)).

If the manufacturer has also mandated an authorised representative, the label will show three parties: manufacturer, importer and representative. More in EU Responsible Person under GPSR.

When an importer becomes the manufacturer (Article 13)

• Own brand: under Article 13(1), anyone placing a product on the market under their own name or trademark is deemed the manufacturer, with all Article 9 duties. An EU buyer that asks for “its own label” becomes an EU-established manufacturer; footnote 15 of the Article 4 guidelines notes that there is then no “importer” within the meaning of the regulation, even if another company handles the actual importation.
• Substantial modification: under Article 13(2) and (3), a change that affects safety, was not foreseen in the original risk assessment, changes the hazard or increases the risk, and is not made by consumers for their own use, makes the modifier the manufacturer for the affected part, or the whole product.

If you are the factory, a rebranding buyer will need your test reports, material and process information to build its own technical file. Agree in the contract what you supply and how it is kept confidential.

Other provisions: information, online sales, accidents, recalls

• Article 14: internal processes for product safety, such as incoming inspection, complaint handling and staff training.
• Article 15: on request, describe the risk, related complaints, known accidents and corrective measures (available for 10 years), and identify suppliers, including suppliers of parts, components and embedded software, and customers (six years).
• Article 19: if the importer sells online itself, the offer must show the manufacturer, the responsible person, a picture and identifier, and local-language warnings.
• Article 20(3): inform the manufacturer of accidents without undue delay; the manufacturer may instruct the importer to notify.
• Article 35: use customer contact data held for recalls and safety warnings; loyalty and registration schemes must let customers register for safety purposes only.

For CE-marked products (toys, electrical and radio equipment and so on), GPSR Articles 9 to 18 do not apply (Article 2(1)(b)). Importer duties come from the importer provisions of the sector law, the responsible person comes directly from Regulation 2019/1020 Article 4, and GPSR Articles 19 and 20 still apply in principle. See GPSR vs CE marking.