EU GPSR FAQ Covered Products

The GPSR covers products placed or made available on the EU market when they are intended for consumers or are likely, under reasonably foreseeable conditions, to be used by consumers. It applies to products supplied for payment or free of charge, including products supplied in the context of a service.

Treat the product as covered if it is a consumer product on the EU market and no listed exclusion applies. If a specific EU product-safety law covers the product, GPSR still matters for risks or aspects that the specific law does not cover.

For legacy stock, Article 51 preserves a transition: Member States shall not impede the continued making available of products that were covered by Directive 2001/95/EC, complied with that directive, and were placed on the market before 13 December 2024. For this transition, placing on the market means the first making available of the individual product on the Union market, so record that event and the former-law conformity basis instead of treating every later resale date as a new GPSR placing.

Article 2 lists exclusions that should be checked before treating a product as covered. The exclusions are product-category exclusions, not general business-model exceptions.

The regulation excludes medicinal products for human or veterinary use, food, feed, living plants and animals, genetically modified organisms and genetically modified microorganisms in contained use, products of plants and animals relating directly to future reproduction, animal by-products and derived products, plant protection products, transport equipment on which consumers ride or travel when a service provider directly operates it, the aircraft specified in Article 2(2)(h), and antiques. Apply the exact category test; the exclusion for provider-operated transport equipment does not automatically cover consumer-operated bicycles, scooters, or similar equipment.

Yes, where the Article 2 scope test is met. GPSR expressly applies to products placed or made available on the market whether they are new, used, repaired, or reconditioned.

Online or other distance-sale offers count as made available on the market when the offer targets consumers in the Union. That means marketplace, ecommerce, and distance-sale listings need a scope review when the seller directs activity to one or more EU Member States.

Keep the record short and product-specific. A useful GPSR scope record names the item, intended and foreseeable consumer use, route to the EU market, whether the sale is online or offline, any Article 2 exclusion considered, and any sector-specific EU product-safety law that covers the same risk.

The answer should be tied to the risk being assessed. A product can be subject to specific Union harmonisation law for one risk while GPSR remains relevant for another risk not covered by that law. For risks covered by Union harmonisation legislation, Article 2(1) switches off Chapter II; Chapter IIa, Chapter III Section 1, Chapters V and VII, and Chapters IX to XI also do not apply. Chapter IIa can operate only when the internal market emergency mode has been activated under Regulation (EU) 2024/2747. Do not describe the GPSR as an unrestricted second layer.