Selling in the European Union?

Distributor verification of manufacturer and importer marking before making a product available

Test required

Before making a product available, verify that the manufacturer and importer complied with Art. 9(5), (6) and (7) and Art. 11(3) and (4)

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Distributor

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products distributed on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)).

Distributor verification of manufacturer and importer marking before making a product available

Must meet the conditions of Regulation (EU) 2023/988 Art. 5 general safety requirement (storage and transport conditions)

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Distributor

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products distributed on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)).

Responsible person name and contact details on the product, packaging, parcel or document

Label required

name, registered trade name or registered trade mark and contact details, including postal and electronic address, of the Union economic operator responsible; on the product or on its packaging, the parcel or an accompanying document

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))

In force since 13 Dec 2024

Applies to products placed on the market on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52: "It shall apply from 13 December 2024"; entry into force the twentieth day after publication). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)). Duty of the economic operator responsible in the Union (Art. 16(3)); the schema has no operator-role condition, so the rule is category-wide and a seller who is not the economic operator responsible in the Union does not owe it.

An economic operator established in the EU, responsible for the product

Must meet the conditions of Regulation (EU) 2023/988 Art. 16(1): an economic operator established in the Union responsible for the tasks in Article 4(3) of Regulation (EU) 2019/1020

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))

In force since 13 Dec 2024

Applies to products placed on the market on or after 13 Dec 2024

Regulation applies from 13 December 2024 (Art. 52). Obligations are on the economic operator named in the quoted article; the schema has no operator-role condition, so the rule is encoded category-wide. GPSR applies in so far as no Union harmonisation legislation covers the same safety aspects. Duty of the manufacturer or importer who places the product on the market (Art. 16(1)); the schema has no operator-role condition, so the rule is category-wide and a seller who is not the manufacturer or importer who places the product on the market does not owe it.

Placing or making available products that are not safe (general safety requirement)

Must meet the conditions of Regulation (EU) 2023/988 Art. 5 general safety requirement

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))

In force since 13 Dec 2024

Applies to products placed on the market on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)).

Importer name and contact details on the product

Disclosure to consumer

verify that the complaint and accident communication channels of Article 9(11) are publicly available to consumers, and provide them if not

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Importer

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products imported on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52: "It shall apply from 13 December 2024"; entry into force the twentieth day after publication). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)). Duty of the importer (Art. 11(3)); the schema has no operator-role condition, so the rule is category-wide and a seller who is not the importer does not owe it.

Importer verification of product safety and manufacturer compliance before placing on the market

Test required

Before placing a product on the market, ensure it complies with the general safety requirement (Art. 5) and that the manufacturer has complied with Art. 9(2), (5) and (6)

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Importer

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products imported on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)).

Importer name and contact details on the product

Label required

importer name, registered trade name or registered trade mark; postal and electronic address and, where different, address of the single contact point; placed on the product or, where not possible, on its packaging or an accompanying document

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Importer

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products imported on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52: "It shall apply from 13 December 2024"; entry into force the twentieth day after publication). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)). Duty of the importer (Art. 11(3)); the schema has no operator-role condition, so the rule is category-wide and a seller who is not the importer does not owe it.

Importer name and contact details on the product

Label required

clear instructions and safety information in a language easily understood by consumers

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Importer

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products imported on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52: "It shall apply from 13 December 2024"; entry into force the twentieth day after publication). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)). Duty of the importer (Art. 11(3)); the schema has no operator-role condition, so the rule is category-wide and a seller who is not the importer does not owe it.

Importer name and contact details on the product

Must meet the conditions of Regulation (EU) 2023/988 Art. 5 general safety requirement (storage and transport conditions)

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Importer

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products imported on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52: "It shall apply from 13 December 2024"; entry into force the twentieth day after publication). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)). Duty of the importer (Art. 11(3)); the schema has no operator-role condition, so the rule is category-wide and a seller who is not the importer does not owe it.

Importer name and contact details on the product

Declaration required

copy of the technical documentation kept at the disposal of market surveillance authorities for 10 years

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Importer

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products imported on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52: "It shall apply from 13 December 2024"; entry into force the twentieth day after publication). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)). Duty of the importer (Art. 11(3)); the schema has no operator-role condition, so the rule is category-wide and a seller who is not the importer does not owe it.

Public communication channels for consumer complaints and accident reports

Disclosure to consumer

Publicly available communication channel (telephone number, electronic address or website section) to submit complaints and report accidents or safety issues

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Manufacturer

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products placed on the market on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52: "It shall apply from 13 December 2024"; entry into force the twentieth day after publication). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)). Duty of the manufacturer (Art. 9(11)); the schema has no operator-role condition, so the rule is category-wide and a seller who is not the manufacturer does not owe it.

Manufacturer name and contact details on the product

Label required

manufacturer name, registered trade name or registered trade mark; postal and electronic address and, where different, address of the single contact point; placed on the product or, where not possible, on its packaging or an accompanying document

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Manufacturer

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products placed on the market on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52: "It shall apply from 13 December 2024"; entry into force the twentieth day after publication). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)). Duty of the manufacturer (Art. 9(6)); the schema has no operator-role condition, so the rule is category-wide and a seller who is not the manufacturer does not owe it.

Instructions and safety information in a language easily understood by consumers

Label required

clear instructions and safety information in a language easily understood by consumers, as determined by the Member State where made available (not required where the product can be used safely without them)

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Manufacturer

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products placed on the market on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)).

Manufacturer product identification (type, batch or serial number)

Label required

type, batch or serial number or other element enabling identification of the product, easily visible and legible for consumers (on the packaging or an accompanying document if size or nature does not allow)

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Manufacturer

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products placed on the market on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52: "It shall apply from 13 December 2024"; entry into force the twentieth day after publication). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)). Duty of the manufacturer (Art. 9(5)); the schema has no operator-role condition, so the rule is category-wide and a seller who is not the manufacturer does not owe it.

Manufacturer ensures the product meets the general safety requirement (Art. 5)

Must meet the conditions of Regulation (EU) 2023/988 Art. 5 general safety requirement (design and manufacture)

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Manufacturer

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products placed on the market on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52: "It shall apply from 13 December 2024"; entry into force the twentieth day after publication). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)). Duty of the manufacturer (Art. 9(2)-(3)); the schema has no operator-role condition, so the rule is category-wide and a seller who is not the manufacturer does not owe it.

Manufacturer keeps the technical documentation up to date

Declaration required

technical documentation kept up to date and available to market surveillance authorities for 10 years

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Manufacturer

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products placed on the market on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52: "It shall apply from 13 December 2024"; entry into force the twentieth day after publication). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)). Duty of the manufacturer (Art. 9(2)-(3)); the schema has no operator-role condition, so the rule is category-wide and a seller who is not the manufacturer does not owe it.

Manufacturer internal risk analysis and technical documentation before placing on the market

Declaration required

Internal risk analysis and technical documentation (general product description, essential characteristics, risk analysis, standards applied), kept up to date and at the disposal of market surveillance authorities for 10 years

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Your role: Manufacturer

Depends on: economic operator role

In force since 13 Dec 2024

Applies to products placed on the market on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52: "It shall apply from 13 December 2024"; entry into force the twentieth day after publication). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)). Duty of the manufacturer (Art. 9(2)-(3)); the schema has no operator-role condition, so the rule is category-wide and a seller who is not the manufacturer does not owe it.

Information in online and distance-sales offers

Disclosure to online listing

Clearly and visibly: manufacturer name, trade name or trade mark and postal and electronic address; EU responsible person name, postal and electronic address where manufacturer is not established in the Union; product identification including a picture, type and other identifier; any warning or safety information in a language easily understood by consumers

• It is a product intended for consumers, or likely to be used by consumers, placed or made available on the market (Reg. (EU) 2023/988 Art. 3(1))
• Sold online

Depends on: whether it is sold online

In force since 13 Dec 2024

Applies to products placed on the market on or after 13 Dec 2024

Applies from 13 December 2024 (Art. 52). Applies only to aspects not covered by specific Union safety requirements (Art. 2(1)).