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EU product safety (GPSR)

Selling home and kitchen goods in the EU: the GPSR and PPWR checklist

Jake Jinyong Kim
Published 4 min read
Short answer

A home or kitchen product sold in the EU needs an economic operator established in the Union who is responsible for it, contact details and an identifier on the product, instructions in the buyer's language, and an online listing that shows the same details. GPSR has applied since December 13, 2024; the packaging regulation's PFAS limits for food-contact packaging apply from August 12, 2026.

  • Responsible person
    Art. 16(1)Art. 16(1): "A product covered by this Regulation shall not be placed on the market unless there is an economic operator established in the Union who is responsible for the tasks set out in Article 4(3) of Regulation (EU) 2019/1020 in respect to that product."
  • Online listing
    Art. 19Art. 19: "the offer of those products shall clearly and visibly indicate at least the following information:"
  • DistributorsArt. 12(1): distributors "shall verify that the manufacturer and, where applicable, the importer have complied with the requirements"
  • PackagingFrom August 12, 2026, food-contact packaging "shall not be placed on the market" at or above three PFAS limits (Art. 5(5) PPWR).

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Note: This is a reading of the two regulations, not legal advice. Every quotation below is copied word for word from the rule records ClaraDB keeps for Regulation (EU) 2023/988 (last updated October 9, 2026) and Regulation (EU) 2025/40 (last updated October 8, 2026). Each row says who the duty falls on; a duty for a role you do not hold is not yours.

Who has to be the EU responsible person?

An economic operator established in the Union; without one, the product "shall not be placed on the market" (Art. 16(1)).

A US company selling into the EU is not established in the Union, so someone who is has to take on the tasks of Article 4(3) of Regulation (EU) 2019/1020 for the product. That person's name and contact details then go on the product or with it.

From December 13, 2024

WhoWhat to doFromThe law
Manufacturer or importer placing the productHave an economic operator established in the Union responsible for the productDecember 13, 2024
Art. 16(1)Art. 16(1): "A product covered by this Regulation shall not be placed on the market unless there is an economic operator established in the Union who is responsible for the tasks set out in Article 4(3) of Regulation (EU) 2019/1020 in respect to that product."
EU responsible personPut their name and postal and electronic address on the product, packaging, parcel or an accompanying documentDecember 13, 2024
Art. 16(3)Art. 16(3): "The name, registered trade name or registered trade mark, and contact details, including the postal and electronic address, of the economic operator referred to in paragraph 1 shall be indicated on the product or on its packaging, the parcel or an accompanying document."

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What has to be on the product?

An identifier, the manufacturer's and the importer's contact details, and instructions and safety information in a language consumers understand.

Each line falls on the manufacturer or the importer. Where the details do not fit on the product, the regulation allows the packaging or an accompanying document.

From December 13, 2024

WhoWhat to doFromThe law
ManufacturerMark the product with a type, batch or serial number or another identifierDecember 13, 2024
Art. 9(5)Art. 9(5): "Manufacturers shall ensure that their products bear a type, batch or serial number or other element enabling the identification of the product"
ManufacturerShow your name or trade mark and postal and electronic address on the productDecember 13, 2024
Art. 9(6)Art. 9(6): "Manufacturers shall indicate their name, their registered trade name or registered trade mark, their postal and electronic address and, where different, the postal or electronic address of the single contact point at which they can be contacted. That information shall be placed on the product or, where that is not possible, on its packaging or in a document accompanying the product."
ManufacturerInclude clear instructions and safety information in the consumer's languageDecember 13, 2024
Art. 9(7)Art. 9(7): "Manufacturers shall ensure that their product is accompanied by clear instructions and safety information in a language which can be easily understood by consumers"
ImporterShow the importer's name or trade mark and postal and electronic address on the productDecember 13, 2024
Art. 11(3)Art. 11(3): "Importers shall indicate their name, their registered trade name or registered trade mark, their postal and electronic address and, where different, the postal or electronic address of the single contact point at which they can be contacted. That information shall be placed on the product or, where that is not possible, on its packaging or in a document accompanying the product."
ImporterMake sure the instructions and safety information travel with the productDecember 13, 2024
Art. 11(4)Art. 11(4): "Importers shall ensure that the product they imported is accompanied by clear instructions and safety information in a language which can be easily understood by consumers"

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What must the online listing show?

The offer must "clearly and visibly" show the manufacturer, the EU responsible person, the product identification with a picture, and any warning or safety information.

The listing is a separate duty from the label: a product correctly labelled in the box can still be listed without the details.

From December 13, 2024

WhoWhat to doFromThe law
Online sellerIn the listing: manufacturer name and postal and electronic address; the EU responsible person's name and addresses where the manufacturer is not in the Union; product identification including a picture and type; any warning or safety information in the consumer's languageDecember 13, 2024
Art. 19Art. 19: "Where economic operators make products available on the market online or through other means of distance sales, the offer of those products shall clearly and visibly indicate at least the following information: (a) name, registered trade name or registered trade mark of the manufacturer, as well as the postal and electronic address at which they can be contacted;"
Online marketplaceDesignate a single point of contact for market surveillance authoritiesDecember 13, 2024
Art. 22(1)Art. 22(1): "providers of online marketplaces shall designate a single point of contact allowing for direct communication, by electronic means, with Member States’ market surveillance authorities in relation to product safety issues, in particular for the purpose of notifying orders issued pursuant to paragraph 4 of this Article."

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What must a distributor check?

Before making the product available, that the manufacturer and importer did their marking and instruction duties; while holding it, that storage and transport keep it safe.

From December 13, 2024

WhoWhat to doFromThe law
DistributorBefore selling, verify the manufacturer's and importer's marking, contact details and instructionsDecember 13, 2024
Art. 12(1)Art. 12(1): "Before making a product available on the market, distributors shall verify that the manufacturer and, where applicable, the importer have complied with the requirements set out in Article 9(5), (6) and (7) and Article 11(3) and (4), as applicable."
DistributorStore and ship the product so it stays safeDecember 13, 2024
Art. 12(2)Art. 12(2): "Distributors shall ensure that, while a product is under their responsibility, storage or transport conditions do not jeopardise its conformity with the general safety requirement laid down in Article 5"

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What must the manufacturer and importer do before selling?

Sell only safe products, design them to the general safety requirement, keep a risk analysis and technical documentation, and, as importer, check the manufacturer's work.

From December 13, 2024

WhoWhat to doFromThe law
Every economic operatorPlace or make available only safe productsDecember 13, 2024
Art. 5Art. 5: "Economic operators shall place or make available on the market only safe products."
ManufacturerDesign and make the product to the general safety requirementDecember 13, 2024
Art. 9(1)Art. 9(1): "manufacturers shall ensure that those products have been designed and manufactured in accordance with the general safety requirement laid down in Article 5"
ManufacturerCarry out an internal risk analysis and draw up technical documentationDecember 13, 2024
Art. 9(2)Art. 9(2): "Before placing their products on the market, manufacturers shall carry out an internal risk analysis and draw up technical documentation"
ManufacturerKeep the technical documentation up to dateDecember 13, 2024
Art. 9(3)Art. 9(3): "Manufacturers shall ensure that the technical documentation referred to in paragraph 2 is up to date"
ImporterBefore selling, confirm the product is safe and the manufacturer did the risk analysis, identifier and contact detailsDecember 13, 2024
Art. 11(1)Art. 11(1): "Before placing a product on the market, importers shall ensure that the product complies with the general safety requirement laid down in Article 5 and that the manufacturer has complied with the requirements set out in Article 9(2), (5) and (6)."
ImporterStore and ship the product so it stays safeDecember 13, 2024
Art. 11(5)Art. 11(5): "Importers shall ensure that, while a product is under their responsibility, storage or transport conditions do not jeopardise its conformity with the general safety requirement laid down in Article 5"
ImporterKeep a copy of the technical documentation for 10 yearsDecember 13, 2024
Art. 11(6)Art. 11(6): "Importers shall keep the copy of technical documentation referred to in Article 9(2) at the disposal of the market surveillance authorities for a period of 10 years"

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How do customers report complaints and accidents?

Through a public channel the manufacturer runs, such as a telephone number, an electronic address or a section of its website; the importer checks that it exists.

From December 13, 2024

WhoWhat to doFromThe law
ManufacturerPublish a telephone number, electronic address or website section for complaints and safety reportsDecember 13, 2024
Art. 9(11)Art. 9(11): "Manufacturers shall make publicly available communication channels such as a telephone number, electronic address or dedicated section of their website"
ImporterVerify that channel is public, and provide one if notDecember 13, 2024
Art. 11(9)Art. 11(9): "Importers shall verify whether the communication channels referred to in Article 9(11) are publicly available to consumers"

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What does PPWR require of packaging, and from when?

From August 12, 2026, food-contact packaging cannot be placed on the market at or above three PFAS limits.

ClaraDB applies these limits to household kitchen disposables designed to be filled at the point of sale. Items sold empty are outside them: the regulation lists "Disposable plates and cups not intended to be filled at the point of sale" among items that are not packaging (Annex I Part C, point 2).

From August 12, 2026

WhoWhat to doFromThe law
Whoever places the packaging on the marketKeep any individual PFAS below 25 ppbAugust 12, 2026
Art. 5(5)(a)Art. 5(5)(a): "food-contact packaging shall not be placed on the market if it contains per- and polyfluorinated alkyl substances (PFAS) in a concentration equal to or above the following limit values to the extent that the placing on the market of packaging containing such a concentration of PFAS is not prohibited pursuant to another Union legal act: (a) 25 ppb for any PFAS"
Whoever places the packaging on the marketKeep the sum of targeted PFAS below 250 ppbAugust 12, 2026
Art. 5(5)(b)Art. 5(5)(b): "250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis, where applicable with prior degradation of precursors (polymeric PFAS excluded from quantification);"
Whoever places the packaging on the marketKeep total PFAS, polymeric included, below 50 ppmAugust 12, 2026
Art. 5(5)(c)Art. 5(5)(c): "50 ppm for PFASs (including polymeric PFAS); if total fluorine exceeds 50 mg/kg"

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What does this page not cover?

Accident notifications to authorities, the full list of the responsible person's tasks, and products already covered by specific EU safety laws.

Accident reporting to authorities. Accident notification through the Safety Business Gateway is not among the rules ClaraDB stores for GPSR, so it is not on this checklist.

The responsible person's tasks. Art. 16(1) points to Article 4(3) of Regulation (EU) 2019/1020 for the tasks; that regulation's text is not quoted here.

Specific EU safety laws. GPSR applies only to aspects not covered by specific Union safety requirements (Art. 2(1)).

Sources and last check

Quotations are from the regulation texts ClaraDB stores with its rules; the GPSR text is the consolidated version published as CELEX 02023R0988-20260529. The GPSR rules were last updated on October 9, 2026, the PPWR rules on October 8, 2026.

SourceWhat it supportsLast checked
Regulation (EU) 2023/988 (GPSR), consolidated textResponsible person, product marking, online listing, distributor and importer checks, complaint channelsOctober 9, 2026
Regulation (EU) 2025/40 (PPWR)PFAS limits for food-contact packaging, items sold emptyOctober 8, 2026

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Sources

  1. Regulation (EU) 2023/988 on general product safety, consolidated text (EUR-Lex, CELEX 02023R0988-20260529)publications.europa.eu
  2. Regulation (EU) 2025/40 on packaging and packaging waste (EUR-Lex, CELEX 32025R0040)publications.europa.eu