GPSR and French EPR obligations for online sellers, article by article
Summary for small sellers, checked on 11 October 2026 against the official texts. Every line links to the text: if in doubt, the text prevails.
General information, not legal advice. READ FRANCE SAS does not act as responsible person, authorised representative or importer.
Regulation (EU) 2023/988 in brief
Since 13 December 2024, Regulation (EU) 2023/988 on general product safety (GPSR) requires that only safe products are placed on the market, and organises identification, traceability and consumer information (Regulation (EU) 2023/988 (GPSR), Art. 5 and 52). It covers new, used, repaired or reconditioned products sold by traders, handmade included (Regulation (EU) 2023/988 (GPSR), Art. 2(3)); purely consumer-to-consumer sales are out of scope (Commission guidelines C/2025/6233, §1.1).
An online offer counts as making the product available in the EU as soon as it targets EU consumers (delivery, language, currency…) (Regulation (EU) 2023/988 (GPSR), Art. 4). There is no exemption for small businesses (Commission guidelines C/2025/6233, §1.1).
Your role under the regulation
- Manufacturer
- You make the product, or have it made and sell it under your name or trade mark. Most makers are in this case (Regulation (EU) 2023/988 (GPSR), Art. 3(8)). Substantially modifying a product (upcycling, customisation) can also make you a manufacturer (Regulation (EU) 2023/988 (GPSR), Art. 13).
- Importer
- Established in the EU, you place a product from a non-EU country on the EU market (Regulation (EU) 2023/988 (GPSR), Art. 3 and 11).
- Distributor
- You resell another manufacturer’s product (Regulation (EU) 2023/988 (GPSR), Art. 12).
- Responsible person
- Every product needs an EU-established operator: manufacturer, importer, authorised representative with a written mandate or, failing those, a fulfilment service provider (Regulation (EU) 2023/988 (GPSR), Art. 16; Regulation (EU) 2019/1020, Art. 4(2)). A maker established in the EU is that operator. Sellers based in the UK, US or elsewhere need one. We do not offer this role.
The obligations, line by line
| Obligation | Who | Source |
|---|---|---|
| Internal risk analysis + technical documentation, before placing on the market | Manufacturer | Regulation (EU) 2023/988 (GPSR), Art. 9(2) |
| Keep the documentation up to date for 10 years | Manufacturer (copy: importer) | Regulation (EU) 2023/988 (GPSR), Art. 9(3); Art. 11(6) |
| Type, batch or serial number on the product (packaging if size requires) | Manufacturer | Regulation (EU) 2023/988 (GPSR), Art. 9(5) |
| Name, trade name or trade mark, postal and electronic address on the product (otherwise packaging or accompanying document) | Manufacturer; importer for its own details | Regulation (EU) 2023/988 (GPSR), Art. 9(6); Art. 11(3) |
| Instructions and safety information in the language set by the Member State (French in France) | Manufacturer, importer | Regulation (EU) 2023/988 (GPSR), Art. 9(7); Law No 94-665 (Toubon law), Art. 2 |
| EU-established responsible economic operator; its details on the product, packaging, parcel or an accompanying document | Every product placed on the EU market | Regulation (EU) 2023/988 (GPSR), Art. 16; Regulation (EU) 2019/1020, Art. 4 |
| Online listing: manufacturer, EU responsible person, picture and identifier, warnings | Every distance seller | Regulation (EU) 2023/988 (GPSR), Art. 19 |
| Public complaint channel; internal register of complaints and recalls (personal data 5 years max.) | Manufacturer | Regulation (EU) 2023/988 (GPSR), Art. 9(11)–(13) |
| Dangerous product: corrective measures, informing consumers and authorities (Safety Business Gateway) | Manufacturer, importer, distributor | Regulation (EU) 2023/988 (GPSR), Art. 9(8); Art. 11; Art. 12 |
| Serious accident: notify without undue delay through the Safety Business Gateway | Manufacturer (informed by importers and distributors) | Regulation (EU) 2023/988 (GPSR), Art. 20 |
| Recall: recall notice with mandatory content, at least two remedies to choose from (repair, replacement, refund) | Operator responsible for the recall | Regulation (EU) 2023/988 (GPSR), Art. 35–37; Implementing Regulation (EU) 2024/1435 (recall notice template) |
| France: declare every recall on RappelConso | Economic operators | French Consumer Code, Art. L423-3; RappelConso (French Consumer Code Art. L423-3) |
Products with specific rules
Where sector legislation exists, the GPSR only covers the risks it does not address (Regulation (EU) 2023/988 (GPSR), Art. 2(1)). Article 19 (online listing) and Article 20 (accidents) still apply.
France: EPR (extended producer responsibility)
- The principle and the streams are set by French Environment Code, Art. L541-10 and L541-10-1: household packaging and paper, textiles-linen-footwear, furniture, toys, sport and leisure, DIY and garden, electrical equipment and batteries, among others.
- One unique identifier (UID) per stream, obtained through the producer responsibility organisation that registers you in SYDEREP: French Environment Code, Art. L541-10-13 (unique identifier); ADEME: unique identifier (UID).
- UID shown in your terms of sale (or contractual document) and on your website: French Environment Code, Art. R541-173 (displaying the UID).
- Marketplaces must check their sellers’ UIDs or take on EPR for them: French Environment Code, Art. L541-10-9 (marketplaces).
- A seller not established in France appoints in writing an agent established in France (Art. L541-10-9-1). For textiles sold online, the place of manufacture must be shown (Law No 2026-602 of 8 July 2026 (EPR agent, textiles)).
- Triman logo and sorting info: French Ministry of Ecological Transition: EPR framework (Triman, marketplaces). Approved organisations: ADEME: list of approved producer responsibility organisations. Check a UID: ADEME: search a producer or UID.
Coming up
- 9 December 2026: the new Product Liability Directive applies to products placed on the market after that date; if the manufacturer is outside the EU, the importer or authorised representative can be held liable (Directive (EU) 2024/2853 (liability for defective products), Art. 2 and 8). This is one reason we remain a plain kit.
- 1 August 2030: the new toy safety regulation applies (Regulation (EU) 2025/2509 (toys, applies from 1 August 2030), Art. 59).
Marketplaces
- Etsy: Etsy Help: GPSR; Etsy Help: add an economic operator; Etsy Help: EPR in France.
- Amazon: Amazon developer docs (SP-API): GPSR attributes; Seller Central help: GPSR (login required).
- Vinted Pro: Vinted Pro (interface fields observed on 2026-10-11). We saw the “Manufacturer information” and “Labelling and marking” fields and the EPR settings in the interface.
- Shopify store or own website: you are the distance seller; Article 19 applies directly to your product pages.
Another obligation for online shops: since 28 June 2025, e-commerce sites selling to consumers must be accessible (European Accessibility Act, Directive (EU) 2019/882; micro-enterprises providing services are exempt). Free accessibility statement generator.
Limits of this summary
The French DGCCRF pages could not be read automatically (anti-bot protection): rely on Légifrance and RappelConso cited above. Amazon Seller Central help requires a login. Standards (EN 15494, EN 14682, EN 12586) are paid documents: we cite their titles, not their content. Report an error to octave@vread.fr.