Do Pet Products Fall Under GPSR? Pet Toys, Leashes and Electric Pet Devices

Pets are not consumers, so why does the GPSR apply?

Article 3(1) of the GPSR defines a product as any item intended for consumers or likely, under reasonably foreseeable conditions, to be used by consumers, and a consumer is a natural person acting outside their trade or profession. Owners buy, fit, hold and clean leashes, litter trays and pet toys, so they are the consumers and these items are within scope. The manufacturer duties in Chapter III Section 1 (risk analysis, technical documentation, identifiers, contact details, local-language instructions) and the Article 16 EU responsible person rule all apply.

What differs is who is protected. Article 3(2) links a "safe product" to a high level of protection of the health and safety of consumers, and Article 20(2) requires notification of accidents that result in a person's death or serious harm to health. The GPSR text does not mention pets. Our reading is that a risk that harms only the animal, with no effect on people, is not what the GPSR directly measures. That is not a free pass: the CE laws for electric pet devices expressly protect domestic animals, member states have animal welfare laws, platforms have their own pet product policies, and many pet risks become human risks, such as a leash breaking and the owner falling.

Pet products the GPSR does not cover

Article 2(2) lists the exclusions. For pet sellers the common ones are:

"Edible chews" and dental sticks sit between feed and toys: check whether the recipe is meant to be eaten before choosing feed rules or the GPSR. Feed labelling, composition and animal by-product rules are beyond this site and need their own check.

Pet toys, leashes and cat trees: the GPSR in full

Non-electric pet products have no specific EU safety law, so the GPSR applies in full. As of our check date, the list of cited standards in Implementing Decision (EU) 2026/901 contains no pet product standards, so there is no shortcut to a legal presumption of safety. Assess risks using the Article 8 elements: other European and international standards, codes of practice and the state of the art. Typical risk points under Article 6:

• Retractable leashes: cord or tape wrapping round fingers or legs and causing cuts or burns; brake failure or a broken clip pulling the owner over; the clip snapping back towards a person.
• Collars, harnesses and buckles: load-bearing metal or plastic parts breaking; unclear size and weight ranges.
• Pet toys: children in the home pick them up. For plush or squeaky toys that look like children's toys, Article 6(1)(f)(ii) requires assessing use by children: removable squeakers and eyes, long cords, magnets.
• Cat trees, beds, crates and carriers: tall cat trees tipping, folding crates pinching fingers, sharp edges, failing door latches.
• Chemicals: REACH Annex XVII restrictions apply to pet products too, for example phthalates in plasticised PVC and PAHs in rubber or plastic parts with prolonged skin contact.

A pet toy is usually not a toy under Article 2(1) of the Toy Safety Directive 2009/48/EC, which covers products for play by children under 14. But if design, packaging or marketing suggest it is for children, it may be assessed as a toy. Labelling it "Pet product, not a toy for children" helps but does not replace reducing small-part risks. See the toys white paper for the boundary.

Electric pet devices: feeders, fountains, dryers and GPS trackers

Electric pet products fall under EU harmonisation legislation, so start with the CE laws:

Unlike the GPSR, these CE laws expressly protect domestic animals. Article 3 of the LVD requires that electrical equipment does not endanger the health and safety of persons and domestic animals, or property, and Article 3(1)(a) of the RED sets the essential requirement of protecting the health and safety of persons and domestic animals, with no voltage limit. The risk assessment for an electric pet device must therefore include shocks, burns and trapping risks to the pet.

CE products are outside GPSR Chapter III Section 1, but Article 19 (online information), Article 20 (accidents), the marketplace rules and the recall rules still apply, and the EU responsible person comes from Article 4 of Regulation (EU) 2019/1020. See the electronics white paper.

Shock training collars: check national animal welfare law

Electric or static training collars may carry CE and still be unlawful to use in some countries. Section 3 point 11 of the German Animal Welfare Act, for example, prohibits using a device that, through direct electric current, significantly restricts an animal's species-appropriate behaviour, in particular its movement, or forces it to move, and thereby causes it more than minor pain, suffering or harm, unless federal or state law permits it. Rules differ between member states, so check the official national text before listing and watch for platform restrictions.

Labels, instructions and listings for pet products

Labels and online information follow the general GPSR rules, plus pet-specific use information:

Instructions and warnings must be in a language easily understood by consumers, as determined by the member state; a QR code may only add to the printed information (Article 21). See GPSR label requirements, or draft the label with gpsrtools.com and check each field.

Risk analysis and after-sales: say who could get hurt

The most common gap in pet product files is writing only "safe for pets". A GPSR technical file must answer whether people can be hurt. Record each risk like this:

Keep the file for 10 years (Article 9(3)). After launch, keep a complaints register. Where a product causes a person's death or serious harm to health, the manufacturer notifies the authority of the member state where it happened through the Safety Business Gateway (Article 20), and recall notices follow Implementing Regulation (EU) 2024/1435. Try the compliance check, and see what is GPSR for the basics.