Since Brexit, selling from Great Britain into the EU has meant customs forms and VAT. Since December 2024 it also means product safety paperwork. Most of what is published about GPSR is written by companies selling Responsible Person services, and it naturally concludes that you should appoint one today. This guide asks a different question: when does GPSR actually bind a UK Etsy shop, what exactly does it require, and is opening the EU worth it for you?
What GPSR is and where it applies
GPSR replaced the 2001 General Product Safety Directive. As a regulation, it applies directly and identically in all 27 member states. Its aim is simple: behind every consumer product sold in the EU there must be someone responsible for its safety who can be reached inside the EU.
Products without their own EU safety legislation, such as jewellery (which also carries REACH metal limits; see our jewellery GPSR and REACH guide), home decor, candles, textile accessories and stationery, fall directly under GPSR. Cosmetics, toys and electrical goods have their own rules, and GPSR only fills the gaps.
| Region | Which rules |
|---|---|
| 27 EU member states | EU GPSR |
| Northern Ireland | EU GPSR (under the Windsor Framework) |
| England, Wales, Scotland | UK General Product Safety Regulations 2005 |
When it becomes mandatory
This is where most sellers get it wrong. Under Article 4, a product sold at a distance is made available on the EU market if the offer is targeted at EU consumers. The Commission’s November 2025 guidelines list the indicators: the countries you ship to, the languages used, the currency and the payment methods. They also state that a website simply being accessible from the EU is not enough.
| Situation | GPSR obligation |
|---|---|
| EU shipping off, listings visible from the EU | None |
| EU shipping on, even to one country | Full |
| EU buyer orders to an address outside the EU | Not placed on the EU market |
Etsy’s opt-out: since February 2025 Etsy has let sellers restrict sales to the EEA and Northern Ireland at shop level. The setting applies to the whole shop, and it covers Northern Ireland as well. If you want to keep selling to Belfast, you need to be GPSR-ready for the EU too.
Bottom line
While EU and NI sales are off, GPSR does not bind you. Everything below starts the day you decide to open them.
Who is responsible: roles
GPSR attaches obligations to roles, not people.
| Role | Who |
|---|---|
| Manufacturer | Whoever makes the product or places it on the market under their own name or brand |
| Authorised representative (Responsible Person) | A person or company established in the EU, appointed by written mandate |
| Importer | Whoever brings the product into the EU from outside |
| Online marketplace | Etsy |
Key point: under Article 13, anyone who places a product on the market under their own brand is treated as the manufacturer. Outsourcing production to a workshop does not change this. If the product is sold under your brand, all manufacturer obligations are yours. Etsy’s “Who made it” answer is Etsy’s own classification and has no effect on your GPSR role.
The five core obligations
1. An EU-based Responsible Person
Article 16 says a product cannot be placed on the EU market unless an economic operator established in the EU is responsible for it. When you ship from the UK directly to consumers there is no EU importer in the chain, so your only route is an authorised representative appointed by written mandate. For Northern Ireland, Etsy accepts a Responsible Person established in the EEA or in Northern Ireland; a business based in Great Britain does not qualify.
The Responsible Person keeps your technical file available to authorities, answers market surveillance requests, reports serious accidents and helps coordinate recalls. Their name and full postal address appear on your packaging and on your Etsy listing.
2. Technical file and risk assessment
Under Article 9 you carry out an internal risk analysis before the product goes on sale, prepare technical documentation and keep it for 10 years. The file is kept per model, not per unit sold.
In November 2025 the European Commission published GPSR guidelines that include a ready-made technical documentation template. Using it is optional, but it is the quickest way to reassure an inspector. A typical file contains:
| Section | Contents |
|---|---|
| Identity | Manufacturer and Responsible Person details, model or SKU, batch numbering scheme |
| Description | Product and packaging photos, dimensions, intended users, foreseeable misuse |
| Materials | Materials by component, with supplier documents |
| Risk analysis | One line per risk: chemical, small parts, sharp edges, breakage, flammability |
| Evidence | Test reports, supplier declarations of conformity |
| Labelling | Label, packaging and leaflet artwork, with translations |
| After sale | Complaint log, accident reporting and recall plan |
3. Traceability
The product must carry a type, batch or serial number that consumers can easily see. It must show the manufacturer’s name, postal address and electronic address. The Commission’s guidelines define the electronic address as an email address or a dedicated part of your website that lets consumers contact you directly; a homepage URL on its own is not enough.
4. Labelling and language
The information belongs on the product. It may move to the packaging or an accompanying document only when the product’s size or nature makes that necessary. The Commission is explicit that aesthetics are not a valid reason. For most handmade products three pieces are enough: a product label or hang tag, a packaging label with the manufacturer and Responsible Person block and batch number, and an insert card with warnings and care instructions.
Language is the hardest part. Article 9(7) requires instructions and safety information in the language set by each member state where the product is sold. There is no single EU language. Germany’s new Product Safety Act (ProdSG), in force since 19 February 2026, explicitly requires German for safety information.
A smart start
Instead of opening the whole EU, start with Ireland and Malta, plus Northern Ireland. All accept English. You still need a Responsible Person and a technical file, but the translation and printing workload disappears. Add Germany and France once the system is running.
5. Accident reporting and recalls
Under Article 20, accidents that cause death or serious adverse effects on health must be reported without delay through the Safety Business Gateway. If a recall is needed, consumers must be offered at least two of repair, replacement or refund, free of charge, and the recall notice must not play down the risk with words such as “voluntary” or “precautionary”.
What to do on Etsy
Etsy has added two places for this information. Filling in either is enough:
- Shop level: Shop Manager → Settings → Partners you work with → economic operator. Best when one Responsible Person covers every product.
- Listing level: the “Manufacturers and product safety info” field in the listing editor. Use it for product-specific warnings.
Article 19 requires four items to be visible on the listing itself, before purchase:
- The manufacturer’s name, postal address and electronic address
- If the manufacturer is outside the EU, the Responsible Person’s name, postal address and electronic address
- Information identifying the product: photo, type, model or SKU
- Warnings and safety information, in the buyer’s language
For a UK seller this means two separate blocks on the listing: yours and your Responsible Person’s.
How to choose a Responsible Person
Etsy does not act as your Responsible Person. Its Seller Handbook points to two providers, Cert-Rep and International Associates, and says you are free to choose another. The market grew quickly after December 2024, so look at the pricing model as well as the price.
| Pricing model | Typical annual price (August 2026) | Best for |
|---|---|---|
| Per company, unlimited products | €150 – €1,200 | Small shops with many designs and variants |
| Per product type or family | €200 – €900 | Shops with a few product groups |
| Per SKU, enterprise packages | €1,000 and up | Businesses with hundreds of products |
Watch for extras: set-up fees of €50 to €300, €20 to €50 per additional SKU and renewal increases of 30 to 50 percent are common. If your products come in variants, get it in writing that colour, size and material variants count as one product family.
Five questions to answer in writing before you sign:
- Which legal entity will sign the mandate? Full legal name and EU company registration number.
- What exact EU street address will appear on my listing and packaging? PO boxes are not accepted.
- Will you answer market surveillance authorities in their language? Is there an extra fee?
- What happens to my 10-year technical file if you stop trading?
- Do you check compliance, or only provide an address and document storage?
For most providers the answer to question 5 is “address and storage only”. That can be fine, but choose it knowingly. Be wary of “one-off fee, lifetime representation” offers, providers that do not publish a company registration number, and sites that sell listing-scanning software rather than representation.
Alternative: the regulation says an authorised representative can be a “natural or legal person”. A trusted person living in the EU can act as your Responsible Person under a written mandate. The burden is real: their name and address are printed on your products, authorities expect timely replies, and they must keep the file for ten years after your last sale. If they leave the EU or withdraw the mandate, your products become non-compliant immediately.
Enforcement: how seriously to take it
GPSR leaves penalties to national law. In Germany, for example, the new ProdSG allows fines of up to €10,000 for most breaches and up to €100,000 for serious ones.
Enforcement is also stepping up. The European Commission’s Safety Gate report for 2025, published in March 2026, recorded 4,671 alerts about dangerous products, the highest since the system began in 2003, and 5,794 follow-up actions, up 35 percent on the previous year. Those actions include withdrawals and removal of listings from online marketplaces. Appointing a Responsible Person without labels and a risk assessment is not compliance.
What about the UK itself?
In Great Britain the UK General Product Safety Regulations 2005 still apply, and there is no EU-style Responsible Person requirement for UK sellers today. That may change: the government consulted from 31 March to 23 June 2026 on a new product safety framework under the Product Regulation and Metrology Act 2025, including duties for online marketplaces and a UK responsible person for certain higher-risk products. Watch for the government’s response before assuming the current position will last.
Cost and timeline
| Item | First year | Following years |
|---|---|---|
| EU Responsible Person | €150 – €1,200 | €150 – €1,200 a year |
| Testing and supplier documents | €0 – €1,500 depending on product category | When materials or suppliers change |
| Technical file | Your own time, or a paid template | Updates |
| Label printer and consumables | ~€200 | ~€50 |
| Multilingual insert cards | ~€100 | ~€100 |
Timeline: collecting supplier documents 2 to 4 weeks, testing (if needed) 3 to 4 weeks, Responsible Person contract about 1 week, label design and printing 1 to 2 weeks. Run in parallel, realistic preparation time is 2 to 3 months.
Step-by-step roadmap
- Ask your suppliers for material and conformity documents.
- Decide which tests your product category needs and get quotes.
- Build a technical file for each model using the Commission template.
- Choose a Responsible Person, ask the five questions and sign a written mandate.
- Set up batch numbering.
- Print product labels, packaging labels and insert cards in the target languages.
- Complete the economic operator and product safety fields on Etsy.
- Add your target EU countries to your shipping profiles.
- Last of all: remove the EEA and Northern Ireland sales restriction.
The last step really does come last.
The moment the restriction is lifted, EU buyers can purchase. If you open before you are ready, you are placing products on the EU market while non-compliant, which is a far worse position than never having opened.
What not to do
| Don’t | Why |
|---|---|
| Put a CE mark on a product that has no CE legislation | CE is only for products covered by specific EU laws. Using it on an out-of-scope product is an offence in most member states. |
| Claim “nickel-free” or “non-toxic” without tests or documents | Unsupported product claims are a risk under Etsy policy and consumer law |
| Use child-oriented wording or images for adult products | It can pull the product into the Toy Safety Directive, with CE marking and extra tests |
| Appoint a Responsible Person and stop there | Inspections also look at labels, listing warnings and the risk assessment |
| Assume a GB address covers Northern Ireland | For NI you need an EEA or NI-based Responsible Person |
Frequently asked questions
Do I need to do anything if I never sell to the EU?
No. While EU and Northern Ireland shipping is switched off, GPSR does not apply. Make sure Etsy’s EEA and Northern Ireland sales restriction is on.
Does selling to only one EU country reduce the obligations?
The Responsible Person and technical file duties apply in full. Only the language burden shrinks, which is why starting with English-speaking Ireland and Malta makes sense.
Is the Responsible Person liable for defects in my product?
No. GPSR does not make the authorised representative liable for the product. Their role is administrative: keeping documents, dealing with authorities and making notifications.
Will my Responsible Person prepare the technical file?
Usually not. Most services store the file but do not write it. Preparing it is the manufacturer’s job, so clarify this before you sign.
Are listings created before 13 December 2024 exempt?
The regulation exempts products placed on the market before that date. Placing on the market is assessed for each individual item, so a newly made product sold today from an old listing is not exempt.
Can a UK company be my Responsible Person?
Not for the EU. The Responsible Person must be established in the EU, or in the EEA or Northern Ireland for NI sales under Etsy’s setup. A company based only in Great Britain does not qualify.
General information, not legal advice
This guide summarises the rules as of September 2026. Speak to a lawyer before signing a Responsible Person contract or opening EU sales.
Before opening the EU, check whether your prices can carry the Responsible Person and labelling costs with the Etsy fee calculator. If you want a second pair of eyes on whether your shop is ready for the EU, the Etsy Shop Audit includes that check.
Sources
- Regulation (EU) 2023/988 (GPSR), EUR-Lex
- European Commission, GPSR guidelines and technical documentation template, November 2025
- European Commission, Safety Gate 2025 report, March 2026
- Etsy Seller Handbook: Selling Consumer Products to Europe Under the GPSR
- GOV.UK: General Product Safety Regulations in Northern Ireland
- UK product safety framework consultation, 31 March to 23 June 2026
- IHK Köln: the new German Product Safety Act (ProdSG) 2026