Amazon & marketplaces

GPSR for Shopify and Own Online Stores: What Your Website Must Show and Who the Importer Is

Last checked against the official texts: 8 November 2026 · Based on Regulation (EU) 2023/988

Short answer

With your own store there is no marketplace in between, so every GPSR obligation lands on you. If the site targets EU consumers (EU shipping, local languages, euro pricing and so on), each product page must clearly show the manufacturer, the EU responsible person, product identification and warnings in the local language (Article 19). When you ship directly from China to EU consumers there is normally no EU importer, so you need an EU authorised representative under a written mandate, and in a recall you must notify your own customers directly (Articles 35–36).

Key points

GPSR applies when your offer targets EU consumers (Article 4), wherever your company or servers are.
A website builder is usually not an online marketplace: nobody else builds compliance fields, handles notices or warns your buyers.
Every product page must show the four Article 19 items before checkout, in every language version.
In direct shipping the consumer is not an importer and couriers are not fulfilment service providers, so the responsible person has to be a mandated authorised representative.
Customs declarants and the future customs "importer for distance sales" are customs roles, not the GPSR responsible person.
In a recall, use your order data to notify affected customers directly, with a recall notice in the legal format.

When does GPSR apply to your own store?

Under Article 4, products sold online are made available on the EU market if the offer is targeted at EU consumers, meaning the seller directs its activities, by any means, to one or more member states. Recital 21 and the Commission's business guidelines (Notice C/2025/6233) list the factors weighed case by case:

Factor	What it looks like on an own store
Where you can ship	Shipping zones include Germany, France or other EU countries
Languages for the offer or ordering	German, French or Italian product pages or checkout
Payment methods	Payment options commonly used in EU countries
Currency and domain	Prices in euro, or a member-state domain such as .de or .fr

Recital 21 adds that a website merely being accessible from the EU is not enough. But if you actively ship to EU addresses and accept EU orders, treat your store as targeting the EU. A company registered in China and servers in the US change nothing.

Unlike Amazon or Etsy, a store builder such as Shopify is usually not an online marketplace under Article 22, because the consumer concludes the contract with you on your own site. There is no platform to provide compliance fields, receive authority orders or notify your buyers; market surveillance authorities deal with you directly. For what marketplaces must do, see online marketplace obligations.

Your role: brand owner or reseller

Own brand. If you have a factory make the product and sell it under your brand or store name, you are the manufacturer (Article 3(8), Article 13(1)) with all Article 9 duties: risk analysis, technical documentation, type and batch number, label details and instructions.
Someone else's brand, including dropshipping. You are not the manufacturer, but as the business selling to EU consumers you still need to check the manufacturer's details are on the product and that there is an EU responsible person. The Commission's 2021 guidelines on Article 4 of Regulation (EU) 2019/1020 advise such sellers to ask the manufacturer whether an authorised representative has been appointed and, if not, to arrange one together.

Either way, the Article 19 listing duty is yours as the store operator. See economic operator roles.

Shipping from China: who is the importer?

An importer is a person established in the EU who places a product from a third country on the EU market (Article 3(10)). Article 16 requires an EU-based responsible person, which under Article 4(2) of Regulation 2019/1020 can be an EU manufacturer, an importer, an authorised representative or, failing those, a fulfilment service provider. How that plays out:

Fulfilment model	Is there a GPSR importer?	Usual responsible person
Parcels shipped from China straight to EU consumers	No. The buyer is a consumer; postal and parcel services are not fulfilment service providers (Art. 3(12))	Only a mandated authorised representative; without one the product may not be offered (2021 Article 4 guidelines)
Your own EU company imports in its name and resells	Yes, your EU company	That company as importer, with its details on the product (Art. 11(3))
Stock in a third-party EU warehouse that ships orders	Usually no	An authorised representative; where no one else exists the warehouse may be the responsible person as fulfilment service provider, but it can decline
Wholesale to an EU retailer	Yes, the retailer	That importer, or your authorised representative

The responsible person's name and contact details must be on the product, packaging, parcel or an accompanying document (Article 16(3)), not just on the website. See EU responsible person.

Customs is a separate track. The customs declarant, IOSS for VAT and the "importer for distance sales" in the new Union Customs Code (Regulation (EU) 2026/2108, applying generally from 21 September 2027) are customs concepts and do not make anyone the GPSR responsible person. Since 1 July 2026 low-value consignments pay a temporary €3 duty per item, and since 1 November 2026 a €2 handling fee per item applies. Customs can already suspend release when the responsible person's details are missing (Article 26 of Regulation 2019/1020). Details: EU customs reform and low-value parcels.

What each product page must show

Article 19 requires every online offer to indicate "clearly and visibly" at least:

Manufacturer: name, registered trade name or trade mark, and postal and electronic address (point (a)).
EU responsible person: where the manufacturer is outside the EU, its name, postal and electronic address (point (b)).
Product identification: a picture, the type and any other identifier such as an EAN (point (c)).
Warnings and safety information that must appear on the product, packaging or accompanying document, in a language accepted in the country of sale (point (d)).

In practice: put this on the product page so it is visible before checkout, not only in order emails; use text rather than images alone; translate the warnings in every language version; keep it identical to the physical label. Manufacturers must also publish a channel for complaints and accident reports (Article 9(11)); a safety contact address or form on your site is the obvious place. Full page checklist: GPSR information for online listings; language rules: warning and instruction languages.

When an authority contacts you

With no platform in front of you, requests go straight to you or your authorised representative. The 2021 Article 4 guidelines note that in distance sales an authority that cannot see who the responsible person is can ask the business offering the product. Have these ready:

Technical documentation (Art. 9(2)–(3)): description, risk analysis, test reports and standards applied, kept 10 years. Give a copy to your representative, who must periodically check the product against the documentation and labels (Art. 16(2)).
Risk and complaint information (Art. 15(2)): a full description of the risk, related complaints and known accidents, and corrective measures taken.
Supply chain records (Art. 15(3) and (5)): who supplied you with the product or its parts, and which businesses you supplied, for six years. Consumers are not part of this record; your customer data serves recall notices instead.

Penalties are set by each member state (Article 44); we do not quote amounts. See technical documentation.

Recalls and safety warnings: no platform will warn your buyers

On a marketplace, Article 22(12) makes the platform notify consumers who bought through it. On your own store that layer does not exist:

Direct notification (Art. 35(1)): in a recall or safety warning, all affected consumers who can be identified must be notified directly and without undue delay. If you collect customer data, you must use it for this. Keep orders searchable by model and batch.
Separate safety contact (Art. 35(2)): if you run product registration or loyalty schemes, let customers give contact details used only for safety messages.
Wider channels (Art. 35(4)): where you cannot reach everyone, publish a clear recall notice on your website, social media and newsletters.
Recall notice format (Art. 36): the headline "Product safety recall"; picture, name, brand and batch; a clear hazard description without softening words such as "voluntary" or "precautionary"; an instruction to stop using the product; the remedies; and a free phone number or online service. The Commission template is in Implementing Regulation (EU) 2024/1435.
Remedies (Art. 37): a choice of at least two of repair, replacement or refund, a refund at least equal to the price paid, and no return shipping costs for the consumer.

The manufacturer must also inform the authorities through the Safety Business Gateway (Article 9(8)) and notify serious accidents (Article 20). See accidents, recalls and Safety Gate.

Own-store GPSR checklist

Check whether your store targets the EU: shipping zones, languages, currency, payment methods, domain
Decide your role for each product: own-brand manufacturer or reseller
Settle the EU responsible person for your fulfilment model; for direct shipping, appoint an authorised representative in writing
Put manufacturer and responsible person details, type and batch, and local-language warnings on the product, packaging or parcel
Show the four Article 19 items as text on every product page before checkout, in all languages
Publish a safety complaints and accident reporting channel on your site
Keep order data searchable by model and batch for recall notices
Prepare a recall notice that follows Article 36 and the 2024/1435 template
Declare true goods descriptions and values to customs; never split or undervalue shipments

Common mistakes

Thinking a non-EU company or server is out of reach
Article 4 looks at whether the offer targets EU consumers, not where you are registered or hosted. If you ship to the EU or sell in EU languages or euro, prepare for GPSR. If you don't want that, stop shipping to the EU rather than ignoring it.
Treating the courier, customs broker or IOSS as the responsible person
Postal and parcel services are excluded from the fulfilment service provider definition, and customs declarants and IOSS are customs and VAT arrangements. None of them is the Article 16 responsible person. Appoint an EU authorised representative in writing and put its details on the product, packaging or parcel.
Only taking the product page down in a recall
Unpublishing stops future sales; Article 35 also requires you to notify customers who already bought, with a notice in the Article 36 format and Article 37 remedies. Keep order data searchable by batch from day one.

Frequently asked questions

My store is in English and US dollars but ships to Germany. Does it target the EU?

It is a case-by-case test, but being able to ship to the EU is a key factor. If you actually accept and deliver EU orders, the safe course is to treat the store as targeting EU consumers and comply with GPSR, or close EU shipping zones if you do not want to.

Who is the responsible person for dropshipped products?

When a supplier ships straight to EU consumers there is usually no EU importer, so an authorised representative with a written mandate must take the role. If you sell under your own brand you are the manufacturer and appoint one yourself; if you resell another brand, first check whether the manufacturer already has one.

I have an IOSS number. Do I still need an EU representative?

Yes. IOSS only handles import VAT. It has nothing to do with product safety, does not replace the Article 16 responsible person and does not remove labelling or warning duties.

Is Shopify an online marketplace that checks my listings?

A store builder is usually not an online marketplace under Article 22, because consumers contract with you on your own website. Compliance information, complaint handling and recall notices are therefore your responsibility.

Which customers must I notify in a recall?

Article 35 requires direct notification of all affected consumers who can be identified, using the customer data you hold. If you cannot reach everyone, also publish the recall notice on your website, social media and newsletters.

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.