GPSR vs CE Marking: What Is the Difference and Which Products Need Both?

The short answer: CE is a sector conformity mark, GPSR is the safety net

Two common mistakes are treating the GPSR as "another certification" and assuming a CE mark means the GPSR can be ignored. Neither is right.

CE marking comes from EU harmonisation legislation for specific product groups: the Toy Safety Directive, Low Voltage Directive (LVD), EMC Directive, Radio Equipment Directive (RED), machinery rules and others. Under Article 30 of Regulation (EC) No 765/2008, CE is affixed only by the manufacturer or its authorised representative, only to products for which the relevant legislation provides for it, and signals that the manufacturer takes responsibility for conformity with all applicable requirements. It normally goes with a conformity assessment, an EU declaration of conformity (DoC) and a technical file.

The GPSR (Regulation (EU) 2023/988) is a horizontal law requiring every non-food consumer product to be safe. It has no mark, no declaration and no official certificate. Instead it sets duties: risk analysis, technical documentation, traceability and contact details, online information, accident reporting and recalls. Recital 6 describes its role as filling gaps and complementing sector legislation.

How the GPSR fills the gaps around CE products

Article 2(1) divides the work:

• where EU law has no specific safety provisions with the same objective, the GPSR applies in full;
• where EU law imposes specific safety requirements, the GPSR applies only to aspects, risks or categories of risks not covered by them;
• for products under harmonisation legislation, Chapter II (safety requirements) applies only to uncovered risks, and Chapter III Section 1 (Articles 9–18, including the main operator duties and the Article 16 responsible person), Chapters V and VII and Chapters IX to XI do not apply.

"Harmonisation legislation" is wider than CE. Article 3(27) defines it as the laws listed in Annex I to Regulation (EU) 2019/1020 plus other EU laws harmonising marketing conditions. That annex includes CE directives but also non-CE laws such as the Cosmetics Regulation and REACH. Whether a sector law applies and whether CE is required are two separate questions.

According to the Commission's GPSR guidelines for businesses (C/2025/6233, published 21 November 2025; an interpretation, not the law itself), the following still apply to products under harmonisation legislation: Chapter I (general provisions); Chapter II for risks not covered by that legislation; Chapter III Section 2 (distance sales, accident reporting, electronic information); Chapter IV (online marketplaces); Chapter VI (Safety Gate and the Safety Business Gateway); and Chapter VIII (right to information and remedies, including recall notices). The guidelines give the example of self-learning features in low-voltage devices: if the LVD does not cover that risk, the GPSR does.

The CE laws sellers meet most often

All the laws below are listed in Article 4(5) of Regulation (EU) 2019/1020, so these products have needed an EU-based responsible economic operator since 16 July 2021, before the GPSR applied.

Whether a product needs CE depends on whether it falls within one of these definitions, not on what competitors print on their boxes. See the electronics white paper and the toys white paper.

What the GPSR still requires for CE-marked products

• Online information (Article 19): listings must show the manufacturer's name and postal and electronic address, the EU responsible person for non-EU manufacturers, product pictures and identifiers, and warnings and safety information.
• Accidents (Article 20): accidents causing death or serious harm to health must be notified through the Safety Business Gateway to the authority of the member state where they occurred. The Commission's Safety Business Gateway guidelines confirm this applies to all products, including those under harmonisation legislation.
• Marketplaces (Chapter IV): takedown orders, third-party notices, listing information and suspension of repeat offenders all cover CE products.
• Recalls and remedies (Articles 35–37): direct notice to consumers, mandatory recall notice content and a choice of repair, replacement or refund apply where the sector law has no provisions with the same objective (recital 8).
• Uncovered risks: any risk the CE law does not address is assessed under the general safety requirement in Article 5.

For CE products the EU responsible person comes from Article 4 of Regulation (EU) 2019/1020 rather than GPSR Article 16: an EU manufacturer, importer, authorised representative or fulfilment service provider, whose name, trade name or mark and contact details (including postal address) appear on the product, packaging, parcel or an accompanying document. In practice the two regimes ask much the same of sellers. Some sector laws, such as the Cosmetics Regulation, have their own responsible-person rules that must be followed instead.

Products without CE are still fully covered by the GPSR

The Commission's guidelines name childcare articles, gym equipment and furniture as examples of products with no specific EU safety law, to which the GPSR applies in full. Many typical e-commerce goods, such as phone cases, fashion accessories, home décor, candles, stationery, outdoor gear and non-powered sports equipment, are in the same position, although some are also subject to other EU rules such as chemical restrictions or food-contact materials law.

• Do not add a CE mark. Article 30 of Regulation 765/2008 forbids CE on products whose legislation does not require it.
• Use European standards. Conformity with European standards whose references are published in the Official Journal gives a presumption of safety for the risks they cover (Article 7). The guidelines confirm that standards published under the old GPSD still count (see Commission Implementing Decision (EU) 2019/1698). Where none exist, Article 8 points to international standards, codes of practice and the state of the art.
• Meet all Chapter III Section 1 duties: risk analysis and technical documentation, identifiers, manufacturer and responsible-person details (Article 16), local-language instructions and warnings, complaint channels and registers.

For homeware, see the home, kitchen and furniture white paper.

CE vs GPSR at a glance

When you need both: one combined workflow

Take a Bluetooth speaker. It normally needs CE under RED and RoHS and is also subject to the GPSR rules on online information, accidents and recalls. You can combine the work:

1. One technical file: start from the CE file and add analysis of risks the CE laws do not cover.
2. One label set: CE mark, type/batch number, manufacturer and EU responsible person with postal and electronic address, local-language warnings. gpsrtools.com can generate the layout.
3. One EU responsible person: the same authorised representative can cover Article 4 of Regulation 2019/1020 and GPSR Article 16, with both named in the mandate.
4. One set of listing data following Article 19, plus the DoC or other documents a platform asks for.
5. One incident process through the Safety Business Gateway for every product.

If you are unsure which laws apply, start with the compliance check and confirm the product scope with a test lab or lawyer.