EU GPSR deadlines and compliance calendar

The key date is 13 December 2024. Regulation (EU) 2023/988 applies from that date, Directives 87/357/EEC and 2001/95/EC are repealed from that date, and Member States must not block products that complied with Directive 2001/95/EC and were placed on the market before that date.

Two implementing measures also apply from 13 December 2024: the Commission recall-notice template under Implementing Regulation (EU) 2024/1435 and the Safety Gate Rapid Alert System rules under Delegated Regulation (EU) 2024/3173.

For dangerous products, the clock starts when the relevant economic operator considers or has reason to believe that the product is dangerous. For an Article 20 accident, the manufacturer's notification clock starts when it knows of an occurrence associated with product use that caused death or serious adverse effects on health and safety. A complaint without that outcome may still require dangerous-product assessment and corrective action even when Article 20 does not apply.

Online marketplaces have two explicit working-day clocks. They must act on market-surveillance orders for dangerous-product content without undue delay and in any event within two working days from receipt. They must process product-safety notices received under the Digital Services Act notice mechanism without undue delay and in any event within three working days from receipt.

Recall timing is also event-triggered. When a product safety recall or safety warning is required, identifiable affected consumers must be notified directly without undue delay. If not all affected consumers can be contacted directly, the business or marketplace must disseminate a clear and visible recall notice or safety warning through other appropriate channels.

The recall file should also track remedy timing. The responsible economic operator must offer an effective, cost-free, and timely remedy. Consumers are entitled to a refund when repair or replacement is not completed within a reasonable time and without significant inconvenience. The GPSR does not set one number of days for reasonable time.

Base periodic review on GPSR triggers and product risk. The regulation does not prescribe a monthly or quarterly interval. The EU responsible person must regularly check technical-documentation conformity and labelling or contact-information compliance where appropriate for product risk. Manufacturers must keep technical documentation up to date and preserve it for 10 years after placing the product on the market.

Do not assign authority deadlines to the business. National authorities submit serious-risk corrective measures through the Safety Gate Rapid Alert System without delay and no later than four working days after the measure is taken. The Commission then has four working days from receipt of a complete notification to check and transmit it. Other Member States use the same four-working-day outer limit for follow-up measures or actions on the product.

Keep business retention and review dates separate from response clocks. Manufacturers and importers keep the applicable technical documentation available to market surveillance authorities for 10 years after placing the product on the market. The regulation also sets Commission review milestones; they are not recurring company filing deadlines.