GPSR glossary: the terms that decide who is responsible

GPSRStatutory term

The General Product Safety Regulation, Regulation (EU) 2023/988. It has applied across the EU since 13 December 2024 and replaced the earlier General Product Safety Directive 2001/95/EC. It sets safety duties for consumer products that are not already covered by more specific EU product legislation.Source: Regulation (EU) 2023/988

Responsible PersonStatutory term

The economic operator established in the EU that is responsible for the tasks in Article 16 for a covered product. It is a role, not a job title: depending on the supply chain it can be an EU manufacturer, an importer, an authorised representative appointed in writing, or a fulfilment service provider.Source: GPSR Article 16

Authorised RepresentativeStatutory term

A person established in the EU who has a written mandate from the manufacturer to act on the manufacturer's behalf for specified tasks. An authorised representative can occupy the Article 16 Responsible Person role, but the two terms are not interchangeable: Responsible Person names the duty, authorised representative names one way of filling it.Source: GPSR Article 3 and Article 16

Economic operatorStatutory term

The collective term for the manufacturer, authorised representative, importer, distributor, fulfilment service provider or any other natural or legal person subject to obligations for the manufacture or making available of products.Source: GPSR Article 3

ImporterStatutory term

The natural or legal person established in the EU who places a product from a third country on the EU market. Where the manufacturer is outside the EU and no authorised representative has been mandated, the importer is commonly the operator that carries the Article 16 duties.Source: GPSR Article 3

Fulfilment service providerStatutory term

A provider offering at least two of warehousing, packaging, addressing and dispatching of products it does not own. It becomes the Article 16 operator only as a fallback, when no manufacturer, importer or mandated authorised representative is established in the EU.Source: GPSR Article 3

Article 16Statutory term

The GPSR article requiring that a covered product may be placed on the EU market only if there is an economic operator established in the EU responsible for defined tasks. Article 16(3) requires that operator's name or registered trade name or trademark, postal address and electronic address to appear on the product, its packaging, the parcel or an accompanying document.Source: Regulation (EU) 2023/988

Article 19Statutory term

The GPSR article on distance selling. It requires a covered online offer to clearly and visibly show the manufacturer's identity and contact details, the Responsible Person details where the manufacturer is outside the EU, information identifying the product including a picture, and any applicable warnings or safety information.Source: Regulation (EU) 2023/988

Article 4 of Regulation (EU) 2019/1020Statutory term

The market surveillance rule that lists the four possible EU-established operator routes and the document, authority-cooperation and corrective-action tasks attached to them. It is the source usually read alongside GPSR Article 16 when deciding which operator carries the duty.Source: Regulation (EU) 2019/1020

Placing on the marketStatutory term

The first making available of a product on the Union market. The moment matters because the Article 16 operator must exist before this point, not after a problem appears.Source: GPSR Article 3

Written mandateStatutory term

The document by which a manufacturer appoints an authorised representative and defines the products and tasks covered. Without a written mandate naming the products, a provider's details on a label do not establish that provider as the responsible operator for those products.Source: GPSR Article 16

Technical documentationStatutory term

The records a manufacturer must draw up and keep, containing the internal risk analysis and a description of how the product meets the general safety requirement. The Article 16 operator must be able to make this documentation available to a market surveillance authority on request.Source: GPSR Article 9

Risk assessmentStatutory term

The internal analysis of a product's hazards, foreseeable use and misuse, users at risk, and the measures that control those hazards. It is the evidence behind a safety claim; a certificate or a test report alone is not a risk assessment.Source: GPSR Article 9

Safety GateStatutory term

The EU rapid alert system for dangerous non-food consumer products, formerly known as RAPEX. Authorities publish alerts on products found to present a risk; monitoring it is how an operator learns that a comparable product has been flagged.Source: GPSR Chapter VII

Safety Business GatewayStatutory term

The Commission portal through which economic operators notify authorities of a product presenting a risk, and through which accident notifications are made. It is the business-facing counterpart to the public Safety Gate.Source: GPSR Article 20 and Article 35

Market surveillance authorityStatutory term

The national authority in each member state empowered to check products, request documentation and order corrective measures. The Article 16 operator is the point of contact these authorities approach.Source: Regulation (EU) 2019/1020

Corrective actionStatutory term

The measures taken when a product is found to present a risk, ranging from correcting information to withdrawal from the market or recall from consumers. The Article 16 operator must cooperate in these measures for the products it covers.Source: GPSR Article 16 and Chapter VII

Declaration of ConformityStatutory term

A manufacturer's signed statement that a product meets the requirements of the specific EU legislation that applies to it. The GPSR itself does not create a declaration of conformity; the document arises from product-specific rules such as the toy, electrical or radio legislation.Source: Product-specific EU legislation

CE markingStatutory term

The manufacturer's declaration that a product complies with the specific EU legislation requiring the mark. The GPSR does not introduce a CE mark and there is no GPSR certificate; a product in GPSR scope only is not CE-marked because of the GPSR.Source: Product-specific EU legislation

GPSDStatutory term

The General Product Safety Directive 2001/95/EC, the predecessor framework. It was repealed and replaced by the GPSR, which has applied since 13 December 2024.Source: Directive 2001/95/EC

General Product Safety Regulations 2005Statutory term

United Kingdom legislation that implemented the earlier EU Directive 2001/95/EC and still applies in Great Britain. It shares the GPSR acronym but is a different instrument from Regulation (EU) 2023/988; only the EU Regulation creates the Article 16 duty. Northern Ireland follows separate arrangements.Source: SI 2005/1803, United Kingdom

Product familyGrüner Baum contract term

Not a GPSR category. It is the unit Grüner Baum prices by: products sharing the same intended use, material structure, basic design, manufacturing method and safety risks are assessed as one family, and variants that differ only in colour or size normally stay inside it. A different intended use, material, electrical property, age group or specific regulatory scope makes a separate family.Source: Grüner Baum GmbH published terms

SKUGrüner Baum contract term

A stock-keeping unit: one sellable variant such as a colour or size. It is a commercial identifier, not a legal one. Grüner Baum places no limit on SKUs inside an accepted product family, so variants of one model do not multiply the fee.Source: Grüner Baum GmbH published terms

Scope of the GPSRStatutory term

The GPSR applies to consumer products placed or made available on the EU market where no specific EU legislation governs the same safety aspect. Where product-specific rules exist, such as toy or electrical legislation, those apply first and the GPSR fills the gaps.Source: GPSR Article 2

ExclusionsStatutory term

Categories the Regulation does not cover, including medicinal products for human or veterinary use, food and feed, living plants and animals, animal by-products, plant protection products, aircraft, and antiques. Second-hand products supplied for repair or reconditioning before use are also outside scope where the supplier informs the recipient.Source: GPSR Article 2(2)

General safety requirementStatutory term

The core duty that economic operators place or make available only safe products on the market. It is the obligation the rest of the Regulation supports; a product can meet every document rule and still fail this requirement.Source: GPSR Article 5

Serious riskStatutory term

A risk requiring rapid intervention and follow-up, including effects that are not immediate. The classification matters because it triggers faster authority notification and, in practice, the difference between a routine correction and an urgent recall.Source: GPSR Article 3

WithdrawalStatutory term

Any measure preventing a product in the supply chain from being made available on the market. It stops further sale but does not ask consumers to return anything — that is a recall.Source: GPSR Article 3

RecallStatutory term

Any measure aimed at achieving the return of a product that has already been made available to the consumer. A recall reaches people who own the product; a withdrawal only reaches the supply chain. The two are routinely confused and carry different notification duties.Source: GPSR Article 3 and Article 35

TraceabilityStatutory term

The ability to identify a product and follow it through the supply chain, supported by a type, batch or serial number on the product or its packaging. For certain products the Commission may require an enhanced traceability system.Source: GPSR Article 18 and Article 9(5)

EPR — Extended Producer ResponsibilityAdjacent regime, not GPSR

Not GPSR. EPR schemes make producers pay for the end-of-life handling of packaging, electrical equipment and batteries, and often require a separate national authorised representative. An EPR representative is not a GPSR Article 16 Responsible Person, and registering for EPR does not satisfy Article 16.Source: National packaging, WEEE and battery legislation

PPWRAdjacent regime, not GPSR

Not GPSR. The EU packaging and packaging waste rules govern packaging design, recyclability and waste obligations. A packaging authorised representative covers those duties only and does not take the GPSR Article 16 role for the product inside.Source: EU packaging and packaging waste legislation

UKCAAdjacent regime, not GPSR

Not GPSR and not an EU mark. The UK conformity assessed marking applies to goods placed on the Great Britain market under UK rules. An EU Responsible Person appointment says nothing about UKCA, and vice versa.Source: United Kingdom conformity legislation

Notified bodyAdjacent regime, not GPSR

Not a GPSR concept. A notified body is a conformity assessment organisation designated under specific EU legislation such as the toy or machinery rules. The GPSR requires no notified body and issues no approval, so no organisation can certify a product as GPSR compliant.Source: Product-specific EU conformity legislation

DistributorStatutory term

Any operator in the supply chain, other than the manufacturer or importer, that makes a product available on the market. A distributor must verify before selling that the product carries the required manufacturer and Responsible Person details and the necessary warnings, and must not supply a product it knows or should presume is unsafe.Source: GPSR Article 3 and Article 12

Online marketplaceStatutory term

A provider of an intermediary service that allows consumers to conclude distance contracts with traders. Marketplaces carry their own duties — registering a single point of contact, acting on authority orders, and designing their interface so sellers can display the Article 19 information. The marketplace is not the Responsible Person for the products it lists.Source: GPSR Article 3 and Article 22

Making available on the marketStatutory term

Any supply of a product for distribution, consumption or use on the Union market in the course of a commercial activity. Distinct from placing on the market, which is only the first such supply; every later sale is a making available.Source: GPSR Article 3

Substantial modificationStatutory term

A change to a product already on the market that affects its safety. Whoever makes such a modification is treated as the manufacturer for that product and takes on the manufacturer's obligations — a rule that catches refurbishers, bundlers and anyone altering a product after purchase for resale.Source: GPSR Article 13

Accident notificationStatutory term

The manufacturer's duty to notify authorities through the Safety Business Gateway when a product it placed on the market caused an accident resulting in death or serious health effects. Separate from the risk notification duty, and it applies even where the product was believed compliant.Source: GPSR Article 20

Warnings and safety informationStatutory term

The instructions and safety information that must accompany a product in a language easily understood by consumers in the member state where it is sold, as determined by that state. Clear warnings do not make an unsafe product safe; they are required in addition to the general safety requirement, not instead of it.Source: GPSR Article 9(7)

Product identificationStatutory term

The type, batch or serial number or other element that allows a specific product to be identified, shown on the product or its packaging. Without it, a recall cannot be limited to the affected lot and has to cover everything.Source: GPSR Article 9(5)

PenaltiesStatutory term

The Regulation requires member states to lay down effective, proportionate and dissuasive penalties for infringements and to notify them to the Commission. Amounts are therefore set nationally and differ per member state; there is no single EU-wide GPSR fine.Source: GPSR Article 44

Digital Product PassportAdjacent regime, not GPSR

Not GPSR. The digital product passport is being introduced through EU ecodesign rules to carry sustainability and circularity data per product group. It has its own timetable and does not replace, satisfy or extend the Article 16 duty.Source: EU ecodesign legislation

WEEEAdjacent regime, not GPSR

Not GPSR. WEEE governs the collection and recycling of electrical and electronic equipment and usually requires its own national registration and, in many states, a separate authorised representative. A WEEE representative does not take the GPSR Article 16 role.Source: EU waste electrical and electronic equipment legislation

REACHAdjacent regime, not GPSR

Not GPSR. REACH regulates chemical substances, including restricted substances in articles and the duty to communicate substances of very high concern. A product can be REACH-compliant and still fail the GPSR general safety requirement, and the two have different responsible roles.Source: Regulation (EC) 1907/2006

RoHSAdjacent regime, not GPSR

Not GPSR. RoHS restricts specified hazardous substances in electrical and electronic equipment and is demonstrated through that legislation's own conformity route and CE marking. It says nothing about the Article 16 economic operator.Source: EU legislation on hazardous substances in electrical equipment

Market surveillance authority (Germany)Statutory term

In Germany market surveillance is executed by the federal states, not by one national body, so the authority that contacts you depends on the Land where the product surfaces. The Marktüberwachungsgesetz frames their tasks, which run from checking products to ordering corrective measures and imposing sanctions.Source: BAuA; Marktüberwachungsgesetz (MüG)

BAuAStatutory term

The German Federal Institute for Occupational Safety and Health. It carries product-safety tasks under the ProdSG and the MüG, acts as the interface between the market surveillance authorities of the Länder, the federal level and Europe, and is Germany's national Safety Gate contact point.Source: Bundesanstalt für Arbeitsschutz und Arbeitsmedizin

ProdSGStatutory term

The German Product Safety Act. The bill adapting it to Regulation (EU) 2023/988 was a departmental draft of 25 October 2023 that lapsed unfinished at the end of the 20th legislative period on 25 March 2025; the ministry states a new bill will be reintroduced. The GPSR is an EU Regulation and applies directly in Germany regardless of that national process.Source: German Produktsicherheitsgesetz; BMAS legislative page

MüG — MarktüberwachungsgesetzStatutory term

The German act that defines the scope of market surveillance: controlling and monitoring products made available on the market and sanctioning infringements. It is the national frame within which a German authority acts on a GPSR matter.Source: German Marktüberwachungsgesetz

GPSR EU Responsible Person | Grüner Baum (2026) →