GPSR on Amazon: the EU responsible person is the real bottleneck

The GPSR (Regulation (EU) 2023/988) replaced the old General Product Safety Directive and applies directly in every EU member state. For Amazon sellers in the DACH region the headline change is not a new label on the box — it is the requirement that every product must have a responsible person established in the EU. Where that actor is missing, Amazon can and does deactivate listings. This guide walks through who that person is, who is affected, what Amazon asks for and how to work through it methodically.

What is the GPSR?

The General Product Safety Regulation is the EU's overarching safety framework for consumer products that are not covered by more specific sector rules (such as toys, cosmetics or electrical goods, which have their own directives). It has applied since 13 December 2024 and, because it is a regulation rather than a directive, it takes effect directly in all member states without needing national transposition to work at its core.

The regulation's goal is simple: only safe products should reach EU consumers, and when something goes wrong there must be a clearly identifiable party inside the EU that authorities can contact. That is why the concept of the responsible person sits at the heart of it. The GPSR also expands documentation, traceability and online-listing obligations, but for most Amazon sellers the responsible person is where compliance succeeds or fails.

The EU responsible person

Under Article 16, a product may only be placed on the market if an economic operator established in the EU is responsible for it. That role can be filled by one of the following, in order of who usually carries it:

• Manufacturer in the EU: if the manufacturer is itself based in the EU, it is automatically the responsible person.
• Importer: anyone who brings a product from a non-EU country into the EU becomes the importer and takes on the role.
• Authorised representative: an EU-established authorised representative that the non-EU manufacturer appoints in writing (the EU Authorised Representative).
• Fulfilment service provider: a fulfilment service provider in the EU can take on the role where no other actor applies.

The responsible person keeps the technical documentation available, checks that the required labelling is in place, cooperates with market surveillance authorities and acts on safety issues. Without such a person established in the EU, the product simply may not be sold — regardless of how good the listing looks.

Who is affected

The scope is broad and catches far more sellers than people expect. The GPSR applies to manufacturers, importers, distributors and resellers alike, and it covers new, used, repaired and reconditioned products. If you list a product on Amazon, you must make sure a responsible person exists in the EU before you offer it — whether you manufacture, import or simply resell.

A few practical takeaways:

• Pure resellers are in scope. Distributing a product you did not make does not exempt you; you still have to confirm that an EU responsible person is behind it.
• Non-EU sourced goods carry the highest risk. Products bought from manufacturers outside the EU are where the EU actor is most often missing, and where deactivation is most likely.
• Some things are excluded. Genuinely private, non-commercial sales and certain categories such as antiques fall outside the regulation. If you sell commercially on Amazon, assume you are in scope.

What Amazon requires in Seller Central

Based on practice observed as of July 2026, Amazon asks for information per ASIN covering the manufacturer, the responsible person and any safety and warning notices. Where these are missing, Amazon can deactivate the listing, and affected ASINs appear in a report labelled "GPSR Issues".

A few things worth knowing about how this behaves in the account:

• The fields are attached at the ASIN level, so a large catalogue means a lot of data entry unless you use a bulk upload.
• Amazon has been changing and adding fields on an ongoing basis, so what you see today may differ next quarter.
• The GPSR Issues report is the early-warning system — ASINs flagged there are the ones at risk of being switched off.

Labelling and warnings

Beyond the Seller Central fields, the physical product and its packaging must carry the required identifiers, and the online listing has to match. In practice this means:

• Traceability marks: the product and packaging should show a type, batch or serial number so a specific item can be identified.
• Operator addresses: the manufacturer's and, where relevant, the importer's name and address must be present.
• Local language: warnings and safety information must be provided in the language of each marketplace — for the DACH markets that means German.
• Online mirror: mandatory details and warnings need to appear in the listing itself, as both image and text, not only on the packaging. A buyer should be able to see the safety information before purchasing.

Implementation checklist

Work through your catalogue in this order to close the biggest gaps first:

• Identify the responsible person: for each product, determine who the EU responsible person is — manufacturer, importer, authorised representative or fulfilment service provider. Where there is no one, appoint someone.
• Non-EU goods first: prioritise products from non-EU manufacturers. This is where the EU actor is missing most often and where the deactivation risk is greatest.
• Fill the Amazon fields: enter the manufacturer, responsible person and warning notices per ASIN in Seller Central. For large catalogues use the bulk upload, but always against the current field structure.
• Check the labelling: confirm that the product and packaging carry a type/batch number and the manufacturer's or importer's address.
• Ensure local language: provide warnings and safety information in the language of each marketplace — German for DACH.
• Update the online listing: add the mandatory details and warnings to the listing as image and text, not just on the packaging.
• Check the GPSR Issues report: open the report under "GPSR Issues" and work through the flagged ASINs before they are deactivated.

Penalties and enforcement

The GPSR leaves the specific sanctions to the member states (Article 44), so the amounts differ from country to country and we deliberately do not quote figures here that we cannot back with a reliable primary source. What is consistent across the EU is the range of consequences: alongside fines, authorities can order a recall or withdrawal of the product, and in the online channel the most immediate effect is delisting — Amazon switching off the affected ASIN.

For a seller, the commercial risk is usually the delisting rather than the fine: a deactivated best-seller costs revenue every day it is offline. That is why the practical priority is keeping the Amazon fields complete and the GPSR Issues report clear.

Common mistakes

A handful of recurring errors account for most deactivations:

• Assuming a reseller is exempt. Distributors and resellers are in scope; you still have to confirm an EU responsible person exists.
• Forgetting you are the importer. Buying directly from a non-EU manufacturer makes you the importer — and therefore the responsible person — whether you intended to be or not.
• Filling the fields once and moving on. Amazon changes the fields; a bulk upload against an old structure can leave gaps that surface later in the GPSR Issues report.
• Putting warnings only on the box. The listing itself needs the mandatory details and warnings as image and text, in the marketplace language.
• Ignoring the GPSR Issues report. It is the warning before deactivation — flagged ASINs left untouched are the ones that get switched off.

None of this is exotic; it is mostly disciplined catalogue hygiene. Treat the responsible person as a data field you own per product, keep the Seller Central details current, and the GPSR becomes a routine check rather than a source of surprise deactivations.

Frequently asked questions