GPSR for Online Sellers: Obligations, Documentation and Fines | Seller2Go

GPSR for online sellers — without losing track

The EU General Product Safety Regulation (Regulation (EU) 2023/988, GPSR for short) has applied since 13 December 2024. It replaces the earlier product safety directive and affects everyone who offers consumer products, whether in their own shop or on marketplaces.

The problem in practice: the obligations are manageable, but the effort lies in the details. Many items, many suppliers, documents in many places. This guide shows what you need to know, what belongs in your listing and how to document your checks in a way you can prove.

Which role do you have?

The GPSR distinguishes several roles. Your role determines which obligations apply to you:

• Manufacturer: you make the product yourself or have it made under your name or brand.
• Importer: you bring products from non-EU countries into the EU market.
• Distributor (seller): you resell products made by other manufacturers.
• Online marketplace: the platform you sell on has obligations of its own.

Important: if you sell someone else's product under your own name or brand, or modify it substantially, you are treated as the manufacturer and carry the manufacturer's obligations.

The key obligations for sellers

The German Federal Environment Ministry summarises the seller obligations as follows:

1. Only offer safe products.
2. Preserve conformity: storage and transport must not impair safety. Markings and identification must be preserved.
3. Do not sell if in doubt: if you suspect that a product is not compliant, you must not make it available.
4. Inform: inform the manufacturer or importer without delay, notify market surveillance authorities via the Safety Business Gateway, report accidents to the manufacturer.
5. Ensure corrective measures: up to withdrawal or recall.

Before selling, also check that the manufacturer has provided the required details on the product: name or brand, postal address, email address and a type, batch or serial number.

What belongs in the online listing?

For distance sales (Article 19 GPSR), the following details must be clearly and visibly shown in the offer:

• Manufacturer: name or brand, postal address, email address
• Responsible person in the EU: name and address, if the manufacturer is based outside the EU
• Product identification: for example a photo plus type, batch or model
• Warnings and safety information: in the language of the country where you sell

Two practical notes:

• Visible in the listing: the details belong in the listing itself, not only in internal records.
• Third-party products: if the manufacturer details are missing on the product or from your supplier, request them before you sell.

Documentation: what should you keep?

Which documents are required depends on your role:

• Manufacturers: technical documentation including the risk analysis, to be kept available for market surveillance for 10 years after the product is placed on the market.
• Importers: a copy of the technical documentation, likewise for at least 10 years.
• Sellers: the German Federal Environment Ministry does not name a retention period for sellers. Your duty is to check before selling and to act if you suspect a problem.

Our advice: record your checks so that you can present them at any time:

• Manufacturer details and responsible person for each item
• Photos of the product, its labelling and packaging
• Date and result of your check
• Communication with the supplier
• Warnings and instructions in the required language

What are the consequences of violations?

Fines. The German Product Safety Act (ProdSG) has been aligned with the GPSR. The revised version has applied since 19 February 2026. Anyone who makes a product available without the information required by Article 19 commits an administrative offence (Section 28(2) no. 26 ProdSG). In this case the fine can be up to 10,000 euros. Fines of up to 100,000 euros are provided for other violations, for example if required corrective measures are not taken, not taken correctly or not taken in time.

Cease-and-desist letters and courts. Trade associations and competitors can also pursue violations under competition law. On 23 April 2026 the Regional Court of Hechingen (case no. 5 O 37/25 KfH) granted a trade association an injunction: a seller may not offer products by distance sale without showing the manufacturer details required by Article 19 in the listing. The argument that the seller had merely used an existing product record on the platform did not help. You are liable for your listings, even if the platform pre-fills parts of them.

Marketplace measures. Marketplaces require these details from their sellers and can exclude listings with incomplete data:

• Kaufland requires name, full address and email address or website for both the manufacturer and the EU responsible person. According to Kaufland, listings without this information are systematically excluded from sale.
• eBay requires manufacturer details, an EU responsible person for manufacturers outside the EU, product information and safety information in the local language. If details are missing, listings can become invisible or unavailable to buyers in the EU.

For every marketplace you sell on, check the current requirements in its seller area.

Common mistakes

• Details missing in the listing even though they exist internally
• Manufacturer details not requested from the supplier or missing on the product
• No responsible person in the EU for manufacturers from third countries
• Relying on the platform: liability for the listing stays with you
• No proof: the check was done but not recorded

Checklist for your implementation

• Clarify your role for each product (manufacturer, importer, seller)
• Record manufacturer details (name, address, email) for each item
• Appoint a responsible person in the EU where required
• Collect product photos, labelling and warnings
• Make the details visible in the listing, in your shop and on every marketplace
• Document your check and record the date
• Review your data regularly to keep it up to date

Seller2Go GPSR — coming soon

Documentation is the part that takes time. We are building Seller2Go GPSR, a module that is meant to keep your checks in one place. It is not available yet. Planned features:

• Compliance checklist: step by step through the mandatory details
• Photo and note documentation: capture the product, its labelling and special features on the spot
• One-click PDF report: your proof when someone asks
• Multilingual support and secure cloud storage
• Mobile-first design: document directly in the warehouse

Note: This article is for general information only and does not replace legal advice. As of October 2026.