EU General Product Safety Regulation (GPSR): Core Obligations and Compliance Guidelines for Manufacturers

1. Overview of the Regulation

The General Product Safety Regulation (EU) 2023/988 (GPSR), as the new EU legislation governing consumer product safety, has a core objective of achieving dual safeguards: ensuring a high level of protection for consumers' health and safety while safeguarding the efficient functioning of the internal market of the European Union.

Regarding the definition of a "manufacturer", it includes any natural or legal person who manufactures a product, designs a product, or commissions another party to manufacture a product, and sells that product in the EU under their own name or trademark. Such entities must strictly comply with the new obligations and updated provisions in the Regulation and complete compliance adjustments by 13 December 2024.

2. List of Core Obligations for Manufacturers

2.1 Obligation to Manage Product Technical Documentation

1. Basis for Compilation and Content: Technical documentation shall be compiled based on internal risk assessments. Its content should include a general description of the product, various elements required for assessing product safety, and shall specify relevant European standards or other considerations.

2. Requirements for Storage and Provision: Technical documentation shall be kept for 10 years and must be provided promptly when requested by market surveillance authorities. In addition, products manufactured in batches shall comply with general safety requirements.

2.2 Obligation to Comply with Product Marking Specifications

Products, their packaging, or accompanying documents shall be marked with information that is easily visible and identifiable to consumers, including:

• The manufacturer's name, registered trade name, or registered trademark;

• The manufacturer's postal address and email address;

• The product's model number, batch number, serial number, or other information that enables the identification of the product;

• Clear instructions and safety information written in a language understandable to local consumers.

2.3 Obligation to Handle Dangerous Products

If a product is dangerous, manufacturers shall fulfill two key obligations: first, immediately notify all economic operators in the supply chain; second, notify the relevant authorities through the Safety Gate, and must take corresponding corrective measures.

2.4 Obligation to Consumer Communication and Data Management

1. Establishment of Complaint Channels: Complaint channels shall be made public. Consumers shall be facilitated to submit complaints and report product-related accidents or safety issues through means such as telephone, email address, or a dedicated section on the website.

2. Internal Registration and Data Storage: An internal complaint register must be established. Data related to complaints may only be stored for the period necessary for the investigation, and the storage period shall not exceed five years from the date of entry. Meanwhile, the processing of personal data shall strictly comply with EU laws on the protection of personal data.