GPSR and the responsible person – what a marketplace listing must include

Updated: 2 November 2026 · GrowNow team

What the GPSR is

The GPSR (General Product Safety Regulation) replaced the 2001 directive and applies directly in all EU countries. It covers consumer products, and for products with their own sector-specific rules, e.g. toys or electronics, it supplements them on matters those rules do not regulate. It does not apply to, among others, food, medicines and plant protection products. For online sales, three provisions matter most: Article 16 (the economic operator in the EU), Article 19 (data in the listing) and Article 22 (platform obligations).

The GPSR is an EU regulation, so it does not govern sales into Great Britain, which has its own product safety rules.

Who the responsible person is

Under Article 16 GPSR, a product may be placed on the EU market only if an economic operator established in the Union is responsible for it. In order, this can be:

• a manufacturer established in the EU,
• the importer, if the manufacturer is outside the EU,
• an authorised representative with a written mandate from the manufacturer,
• a fulfilment service provider, if none of the above exists.

For a Polish manufacturer the conclusion is simple: you are the responsible economic operator. You don’t need to buy a “Responsible Person” service – it is enough that your details are on the product and in the listing. A separate responsible person is only needed when a brand manufactures outside the EU, e.g. in Asia, and has no importer in the Union.

What a listing must include (Article 19)

The data must be visible directly in the listing – a link or QR code alone is not enough; at most they can supplement it. The same manufacturer information goes on the product or, where that is not possible, on the packaging or in a document accompanying the goods.

Obligations a manufacturer cannot pass on to the seller

• Risk analysis and technical documentation, kept for 10 years after the product is placed on the market.
• Marking the product with a type, batch or serial number.
• Instructions and safety information in the language of the country of sale.
• Reporting accidents through the Safety Business Gateway portal and carrying out product recalls.

Watch out for Article 13 GPSR: anyone who sells a product under their own brand or substantially modifies it takes on the manufacturer’s obligations – including the technical documentation and risk analysis.

Marketplace obligations

The GPSR also places obligations on platforms (Article 22). They must register in the Safety Gate system, give sellers fields for the Article 19 data, carry out orders from market surveillance authorities within 2 working days and handle notices within 3 working days. In practice, Amazon, Allegro and Kaufland require complete manufacturer data in every listing, and gaps end with the listing being hidden.

Penalties in Poland from 2026

The Act of 7 November 2025 on the supervision of general product safety (Journal of Laws 2025, item 1826) entered into force on 3 January 2026 and replaced the 2003 act. Supervision is exercised by the President of UOKiK together with the Trade Inspection, and breaches of the GPSR carry administrative fines – the highest reach PLN 1 million. In the countries you sell to, penalties are imposed by the local authorities.

GPSR in the GrowNow model

At GrowNow, we are the distributor and the seller in the listing. We complete the Article 19 data in all channels, prepare local content and keep track of platform requirements. The manufacturer remains the manufacturer: from you we need the technical documentation, the markings on the product, and the instructions and warnings, which we help prepare in the languages of the markets.

See how we take over GPSR and EPR ›

Frequently asked questions