The exact requirements depend on the product and your role in the supply chain. A manufacturer, importer, distributor and online marketplace can have different responsibilities.

However, there are several important areas that businesses need to consider.

1. Make sure your products are safe

The starting point for GPSR compliance is straightforward: only safe products should be placed on the EU market.

Businesses need to consider the characteristics of the product, including its design, technical features, composition, packaging, instructions and reasonably foreseeable use.

For example, a jewellery business may need to consider risks associated with:

• Metal composition and restricted substances.
• Nickel release and potential skin exposure.
• Lead and cadmium content.
• Coatings and finishes.
• Small components.
• Sharp edges or points.
• Product durability.
• How the product is likely to be worn or used.

The risks will be different for other products. A wearable electronic product, accessory, household item or children’s product, for example, may require a different assessment.

GPSR therefore isn’t simply about carrying out one standard test on every product. The appropriate assessment depends on the product and its potential risks.

2. Carry out a risk assessment

Manufacturers are required to carry out an internal risk analysis before placing a product on the market.

The assessment should consider the potential risks associated with the product and the measures used to eliminate or reduce those risks.

For a jewellery or accessories business, this might mean considering the materials used, how the product comes into contact with the consumer and whether components could present a safety risk.

A good risk assessment should be part of the product development and compliance process rather than something considered only after a problem occurs.

3. Keep technical documentation

One of the important GPSR compliance requirements is having technical documentation for products within scope.

This documentation should contain information about the product and its characteristics that are relevant to assessing its safety. Where risks have been identified, it should also record the risks and the solutions used to eliminate or reduce them.

The amount of information required will depend on the complexity and risk profile of the product.

Testing reports can form an important part of this evidence. They can help demonstrate that particular materials, components or finished products have been assessed against relevant requirements.

4. Make products traceable

GPSR also places greater emphasis on product identification and traceability.

Products need appropriate identification, such as a type, batch or serial number, or another element that allows the product to be identified.

Businesses also need to provide relevant manufacturer and responsible economic operator information.

For businesses selling online, product safety and traceability information also needs to be made available as part of the product listing in the circumstances covered by the Regulation.

Good traceability can also make it easier for a business to identify affected products if a safety issue is discovered.

5. Provide appropriate instructions and safety information

Products must be accompanied by appropriate instructions and safety information where required.

This information should be clear and understandable to consumers and provided in the relevant language requirements for the market.

The aim is to help consumers use products safely and understand any relevant warnings or limitations.

For jewellery and accessories, this could include information about safe use, care or particular product characteristics where this is necessary to reduce a foreseeable risk.

6. Understand your responsibilities as a manufacturer, importer or distributor

GPSR responsibilities are not the same for every business.

You need to understand which role you have in relation to each product.

For example:

Manufacturers are responsible for ensuring their products meet the applicable safety requirements, carrying out risk assessments and preparing technical documentation.

Importers have responsibilities for checking that manufacturers have met relevant requirements before products are placed on the market.

Distributors and retailers also have responsibilities, including checking relevant product identification, traceability and safety information before making products available.

A business can also fall into more than one category depending on how it operates.

7. Check whether you need an EU Responsible Person

If you are selling products into the EU from outside the EU, you may need an EU-based responsible economic operator.

For products covered by GPSR, there must be a responsible economic operator established in the EU. Depending on the circumstances, this could be an EU manufacturer, importer, authorised representative or fulfilment service provider.

The responsible person’s details also need to be indicated as required by the Regulation.

For UK businesses selling into the EU, this is an important requirement to check as part of your market-entry process.

For businesses selling into Northern Ireland, specific GPSR requirements also apply, including the requirement for a responsible economic operator established in NI or the EU.