GPSR Article 22: Online Marketplace Obligations
GPSR Article 22 sets the product-safety rules for online marketplaces. Marketplace providers must run controls for trader onboarding, listing data, unsafe-product notices, authority orders, recalls and accident reports. Two exact deadlines matter: at most two working days for an authority order and three working days for a product-safety notice.
Who is a provider of an online marketplace under GPSR?
The GPSR defines a provider of an online marketplace as a provider of an intermediary service whose online interface lets consumers conclude distance contracts with traders for the sale of products. The GPSR's marketplace rules then set the product-safety duties of that provider.
A business can hold more than one role for the same product. If a marketplace also sells its own branded product, imports it, distributes it or provides fulfilment services, the duties of that extra role apply separately. Hosting a third-party listing alone does not make the platform the manufacturer or the EU Responsible Person.
What do the GPSR marketplace rules require?
| Duty | What the marketplace provider must operate | Deadline or trigger | Rulebook |
|---|---|---|---|
| Authority contact point and Safety Gate registration | Designate an electronic contact point for market-surveillance authorities, register with the Safety Gate Portal and publish the contact details there | In place for operations | GPSR |
| Consumer contact point | Give consumers a direct and rapid product-safety communication channel | In place for operations | GPSR |
| Internal product-safety process | Maintain procedures that can receive, decide and act on product-safety matters | Without undue delay | GPSR |
| Authority orders | Remove the specified offer content, disable access or display an explicit warning and report the action to the authority | Without undue delay; maximum 2 working days after receipt | GPSR |
| Safety Gate monitoring | Take account of regular dangerous-product information and use at least the Safety Gate Portal for the relevant DSA checks | Regular operational control | GPSR and DSA |
| Product-safety notices | Process notices received through the DSA notice-and-action system | Without undue delay; maximum 3 working days after receipt | GPSR and DSA |
| Listing interface | Let traders provide the four required product-safety information blocks and display them or make them easily accessible to consumers | Before and during publication of the offer | GPSR |
| Trader mechanisms | Collect the four information blocks, trader self-certification and applicable DSA identification data | Trader onboarding and listing workflow | GPSR and DSA |
| Repeat offenders | Suspend, after warning, traders who frequently offer products that do not comply with GPSR | Reasonable suspension period | GPSR |
| Recalls, accidents and cooperation | Notify affected buyers, publish recalls, inform authorities through the Safety Business Gateway and support investigations and supply-chain tracing | When the platform has the stated knowledge or receives relevant information | GPSR |
These rules do not create a general duty to monitor every piece of stored information or to assess every listing on its own. They do require workable controls and fast action when a listed product is flagged as dangerous through Safety Gate information, an authority order, a notice or actual knowledge.
What information must the marketplace listing support?
The marketplace interface must let the trader provide four information blocks for each product offer. It must also display them or make them easy to reach:
- Manufacturer: name, registered trade name or trademark, postal address and electronic address.
- EU Responsible Person: for a manufacturer outside the EU, the name, postal address and electronic address of the responsible person in the EU.
- Product identification: a picture, the product type and another product identifier.
- Warnings and safety information: the information required for that product in a language consumers can easily understand, as set by the country of sale.
These four blocks are the same information every online offer must show under the GPSR. Our online-sales checklist explains what the economic operator must supply. The marketplace rules explain what the platform's interface must allow and display.
What is the difference between marketplace and seller duties?
| Question | Marketplace provider | Trader or economic operator |
|---|---|---|
| Who designs the product-safety fields? | The marketplace designs and operates the interface | The trader uses the fields for the offered product |
| Who is responsible for accurate product data? | The platform applies its interface, best-efforts and response duties | The manufacturer, importer or distributor remains responsible for information attached to its role and offer |
| Who prepares the risk analysis and technical file? | Not the marketplace merely because it hosts the offer | The manufacturer does this work under the GPSR |
| Who supplies the EU Responsible Person details? | The marketplace provides a field and makes the information accessible | The non-EU manufacturer's supply chain must identify the correct responsible economic operator in the EU |
| Who acts on a dangerous-product notice or recall? | The marketplace follows its own removal, notification and cooperation duties | The economic operator follows its corrective-action, authority-notification and recall duties |
The same company may sit in both columns for a particular product. For example, a marketplace that sells its own-brand product can also be the manufacturer. The manufacturer duties then apply on top of the marketplace duties.
How do GPSR and the Digital Services Act work together?
The Digital Services Act (DSA) and the GPSR cover different layers of the marketplace workflow:
- Trader traceability (DSA): identity, contact, payment-account, register and self-certification information.
- Compliance by design (DSA): fields for the required information, best efforts to check that it was provided, and reasonable random checks against official machine-readable databases.
- Product safety (GPSR): safety-specific listing fields, Safety Gate registration, the two- and three-working-day deadlines, repeat-offender measures, recall communication and accident cooperation.
Do not replace one layer with the other. KYC data does not prove that a product is safe. A complete GPSR listing does not replace trader identity checks.
Marketplace operational check
Before treating a marketplace workflow as ready, confirm that:
- the authority and consumer contact points are active;
- Safety Gate registration and monitoring are assigned;
- orders and notices have separate two- and three-working-day timers;
- where applicable, the listing workflow checks that required trader-identity and product-safety fields have been provided before publication;
- listing fields keep the manufacturer and the EU Responsible Person as separate entities;
- recall communication can identify and contact affected buyers;
- Safety Business Gateway reporting has an owner; and
- repeat non-compliance can trigger a documented trader suspension.
Grüner Baum GmbH supports manufacturers and sellers with product-scope review, risk assessment, technical documentation, listing data for online offers and a Germany-based Responsible Person service where that route fits. We do not run a marketplace provider's own GPSR compliance system. Request a product review.
Frequently asked questions
What does the GPSR require online marketplaces to do?
Marketplaces must register with the Safety Gate Portal, run contact points for authorities and consumers and keep internal product-safety processes. They must also offer listing fields for the required product information, handle orders and notices on time, suspend repeat offenders and cooperate on recalls, accidents and dangerous products.
Do the GPSR marketplace rules apply directly to sellers?
No. These rules are aimed at the marketplace provider. Sellers stay responsible for the duties of their own role as manufacturer, importer or distributor, including correct product information in their offer. The marketplace interface does not move those duties to the platform.
How quickly must a marketplace act on a dangerous-product order or notice?
A marketplace must act on an authority order without undue delay and within two working days of receipt at the latest. It must process a product-safety notice received through the Digital Services Act notice system without undue delay and within three working days at the latest.
Must an online marketplace verify every product for GPSR compliance?
No. There is no general duty to certify every product. The marketplace must build its interface for the required data, carry out the relevant Digital Services Act checks, use Safety Gate information and act when it receives an order, a notice or actual knowledge of a dangerous product.
Is an online marketplace automatically the EU Responsible Person?
No. Hosting a listing does not make the marketplace the responsible economic operator in the EU. A business can have extra duties if it also acts as manufacturer, importer, distributor or fulfilment service provider for a product.
Official sources
| Topic | Legal basis | Official text |
|---|---|---|
| Definition of a provider of an online marketplace | GPSR (Regulation (EU) 2023/988), Article 3(14) | GPSR (Regulation (EU) 2023/988) on EUR-Lex |
| Authority contact point and Safety Gate registration | GPSR, Article 22(1) | GPSR (Regulation (EU) 2023/988) on EUR-Lex |
| Consumer contact point | GPSR, Article 22(2) | GPSR (Regulation (EU) 2023/988) on EUR-Lex |
| Internal product-safety processes and trader mechanisms | GPSR, Article 22(3) and (10); Digital Services Act (Regulation (EU) 2022/2065), Article 30 | GPSR (Regulation (EU) 2023/988) on EUR-Lex; Digital Services Act on EUR-Lex |
| Authority orders: removal, disabling access or warning; at most two working days | GPSR, Article 22(4) and (5) | GPSR (Regulation (EU) 2023/988) on EUR-Lex |
| Safety Gate information and the related DSA checks | GPSR, Article 22(6) and (7); Regulation (EU) 2022/2065, Article 31(3) | GPSR (Regulation (EU) 2023/988) on EUR-Lex; Digital Services Act on EUR-Lex |
| No general duty to monitor all stored information | Regulation (EU) 2022/2065 (Digital Services Act), Article 8 | Digital Services Act on EUR-Lex |
| Product-safety notices through the DSA notice system: at most three working days | GPSR, Article 22(8); Regulation (EU) 2022/2065, Article 16 | GPSR (Regulation (EU) 2023/988) on EUR-Lex; Digital Services Act on EUR-Lex |
| Listing interface with the four information blocks; the same blocks every online offer must show | GPSR, Article 22(9) and Article 19 | GPSR (Regulation (EU) 2023/988) on EUR-Lex |
| Suspension of repeat offenders | GPSR, Article 22(11) | GPSR (Regulation (EU) 2023/988) on EUR-Lex |
| Recalls, accidents and cooperation | GPSR, Article 22(12) | GPSR (Regulation (EU) 2023/988) on EUR-Lex |
| Trader traceability; compliance by design, best efforts and random checks | Regulation (EU) 2022/2065 (Digital Services Act), Articles 30 and 31 | Digital Services Act on EUR-Lex |
| Seller duties that stay with the seller: manufacturer's risk analysis and technical file; responsible person in the EU | GPSR, Article 9 and Article 16 | GPSR (Regulation (EU) 2023/988) on EUR-Lex |
| How the Commission explains these duties for businesses | European Commission guidelines | European Commission GPSR business guidance, C/2025/6233 |
This article is general information, not legal advice; the duties that apply depend on your actual role for each product.
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