GPSR Article 22: Online Marketplace Obligations
As of 1 September 2026, GPSR Article 22 requires providers of online marketplaces to operate product-safety controls around trader onboarding, listing data, unsafe-product notices, authority orders, recalls and accident reporting. Two exact deadlines matter: a maximum of two working days for an authority order and three working days for a product-safety notice.
What changed in this Article 22 guide?
- September 2026: The online marketplace definition was corrected to GPSR Article 3(14); Article 22 sets the platform's product-safety duties.
- September 2026: The two- and three-working-day deadlines, Safety Gate registration, listing fields and recall duties were mapped to their exact paragraphs.
- September 2026: Marketplace-provider duties were separated from seller, manufacturer, importer and EU Responsible Person duties.
Who is a provider of an online marketplace under GPSR?
GPSR Article 3(14) defines a provider of an online marketplace as an intermediary-service provider using an online interface that allows consumers to conclude distance contracts with traders for product sales. Article 22 then sets the product-safety obligations for 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 attached to that additional role apply separately. Hosting a third-party listing alone does not make the platform the manufacturer or the EU Responsible Person.
What does GPSR Article 22 require?
| Article 22 duty | What the marketplace provider must operate | Deadline or trigger | Legal basis |
|---|---|---|---|
| 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 | Article 22(1) |
| Consumer contact point | Give consumers a direct and rapid product-safety communication channel | In place for operations | Article 22(2) |
| Internal product-safety process | Maintain procedures that can receive, decide and act on product-safety matters | Without undue delay | Article 22(3) and (10) |
| 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 | Article 22(4) and (5) |
| 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 | Article 22(6) and (7) |
| Product-safety notices | Process notices received through the DSA Article 16 mechanism | Without undue delay; maximum 3 working days after receipt | Article 22(8) |
| 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 | Article 22(9) |
| Trader mechanisms | Collect the Article 22(9) information, trader self-certification and applicable DSA identification data | Trader onboarding and listing workflow | Article 22(10); DSA Article 30 |
| Repeat offenders | Suspend, after warning, traders who frequently offer products that do not comply with GPSR | Reasonable suspension period | Article 22(11) |
| 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 | Article 22(12) |
Article 22 does not impose a general obligation to monitor every piece of stored information or independently assess every listing. It does require workable controls and timely action when a listed product is identified through Safety Gate information, an authority order, a notice or actual knowledge.
What information must the marketplace listing support?
GPSR Article 22(9) requires the marketplace interface to let the trader provide four information blocks for each product offer and to display them or make them easily accessible:
- 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 Article 16 responsible person.
- 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 determined by the Member State of sale.
These four blocks mirror the information required for an online offer under GPSR Article 19. Our Article 19 online-sales checklist explains what the economic operator must supply; Article 22 explains what the marketplace interface must enable 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 performs the GPSR Article 9 work |
| 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 Article 16 economic operator |
| Who acts on a dangerous-product notice or recall? | The marketplace follows Article 22 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 selling its own-brand product can also be the manufacturer; the manufacturer duties then apply in addition to Article 22.
How do GPSR and the Digital Services Act work together?
The Digital Services Act (DSA) and GPSR address different layers of the marketplace workflow:
- DSA Article 30 covers trader traceability, including identity, contact, payment-account, register and self-certification information.
- DSA Article 31 requires compliance-by-design fields, best efforts to check that required information was provided and reasonable random checks against official machine-readable databases.
- GPSR Article 22 adds product-safety-specific listing fields, Safety Gate registration, two- and three-working-day response 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, and a complete GPSR listing does not replace trader identity checks.
Article 22 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 preserve manufacturer and 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, Article 19 listing data and a Germany-based Responsible Person service where the Article 16 route is suitable. We do not operate a marketplace provider's Article 22 governance system. Request a product review.
Frequently asked questions
What does GPSR Article 22 require online marketplaces to do?
Article 22 requires Safety Gate registration, contact points, internal processes, listing-data fields, prompt handling of orders and notices, repeat-offender controls and cooperation on recalls, accidents and dangerous products.
Does GPSR Article 22 apply directly to marketplace sellers?
Article 22 addresses the marketplace provider. Sellers remain responsible for the GPSR duties attached to their role and for the accuracy of their product offer.
How quickly must a marketplace act?
The maximum is two working days for an authority order and three working days for a product-safety notice. Both duties also say action must occur without undue delay.
Must a marketplace verify every product?
No general certification duty applies to every listing. The platform must operate the Article 22 and relevant DSA controls, use official databases such as Safety Gate and act on reliable safety information.
Is the marketplace the EU Responsible Person?
Not merely because it hosts the offer. The Article 16 responsible economic operator is identified from the product's actual supply chain and written mandates.
Official sources
- Regulation (EU) 2023/988, Articles 3(14), 19 and 22
- European Commission GPSR business guidance, C/2025/6233
- Digital Services Act, Articles 16, 30 and 31
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