Article 22 adds product-safety duties for online marketplaces and ties several of them to mechanisms, including orders, notices, trader information, repeated non-compliance, and product-safety information in listings.
This comparison helps separate the product-safety file from the marketplace workflow, especially for dangerous products, online-interface takedown, listing data, recalls, accident reports, and evidence.
Start with Article 22 when an online marketplace case concerns a dangerous consumer product. It adds product-safety duties and imports selected procedures; it does not replace the DSA or reduce the platform's other DSA duties. For this comparison, separate the product-safety decision from the platform process for listings, orders, notices, trader information, repeated non-compliant traders, recalls, consumer warnings, accident notifications, and evidence.
Side-by-side comparison
GPSR vs DSA marketplaces: dangerous-product comparison
A scope-bounded comparison of marketplace duties and the mechanisms that GPSR Article 22 references for dangerous products offered online.
controls the consumer-product safety question: whether a product is safe, dangerous, recalled, withdrawn, subject to a safety warning, or reportable through Safety Business Gateway or Safety Gate workflows.
Second framework
DSA marketplace touchpoints
The side is limited here to the mechanisms Article 22 references for marketplaces: contact points, orders, notices, listing information, trader self-certification, and suspension of frequent non-compliant traders.
GPSR vs DSA marketplaces: dangerous-product comparison
asks whether a consumer product made available on the EU market is safe, dangerous, non-compliant, recalled, withdrawn, or subject to a safety warning or accident report.
Grounds the GPSR focus on safe consumer products, dangerous products, recalls, safety warnings, accident reporting, and marketplace duties.
place only safe products on the market
The -referenced marketplace question is narrower: whether the online platform process for product-safety orders, notices, listing information, trader commitments, or repeated non-compliance has been triggered.
GPSR Article 22 references selected DSA mechanisms for marketplace contact points, orders, notices, listing information, trader self-certification, and trader suspension.
in accordance with Article 16 of Regulation (EU) 2022/2065
Open the case under when the fact pattern is a product-safety risk; add the -referenced marketplace track only for the platform process that handles the offer.
gives market-surveillance authorities a product-safety route to require removal of content for an offer of a dangerous product, disabling access to it, or displaying an explicit warning. The marketplace must act without undue delay and in any event within two working days of receiving the order, then inform the issuing authority electronically of the effect given to it.
requires marketplace interfaces to let traders provide specified product-safety information for each offered product and to display it or make it easily accessible to consumers on the listing.
Article 22(9) grounds marketplace interface design for product-safety information that traders provide and consumers can see or easily access.
displayed or otherwise made easily accessible
The supplies two related controls. Article 31 requires marketplaces to design their interfaces so traders can provide Article 30 information, and Article 22(9) adds the product-safety fields. GPSR Article 22(10) separately requires the trader's DSA Article 30(1) self-certification before the offer is published.
DSA Articles 30 and 31 establish trader traceability, self-certification, and marketplace interface-design duties; GPSR Article 22(9) and (10) add the product-safety use of those controls.
Listing QA should test product-safety fields, trader information, product identifiers, warnings, and displayed accessibility before the listing goes live.
says marketplace providers must process notices related to product-safety issues for products offered online without undue delay and in any event within three working days of receipt.
Article 22(8) supplies the GPSR processing clock for product-safety notices received by online marketplaces.
within three working days
The touchpoint is the notice channel: identifies notices received in accordance with DSA Article 16, but the deadline stated here comes from GPSR Article 22(8).
evidence can include accident information, dangerous-product notifications, Safety Business Gateway submissions, Safety Gate follow-up, and corrective measures such as withdrawal, recall, or online-content removal.
Grounds accident, risk, traceability, corrective-measure, recall-link, and Safety Business Gateway reference fields.
information on reported accidents
The -referenced marketplace evidence is the platform trail around the offer: listing identifiers, provider name, notices, orders, removals, warnings, trader suspension, and consumer communications.
Article 22 grounds marketplace records for product-safety notices, orders, listings, trader suspension, recalls, and consumer safety warnings.
providers of online marketplaces shall
Do not rely on a takedown ticket alone. Pair it with product-risk evidence, accident or incident facts, notification status, and recall or corrective-action records.
requires affected consumers who can be identified to be notified directly and without undue delay in product safety recalls or safety warnings, including marketplace-provider duties under Article 22(12).
Grounds recall notice structure and online recall notice requirements.
Product safety recall
The touchpoint does not supersede the recall file. The marketplace record should show how the platform used buyer data, listing records, and consumer-contact paths to support the GPSR recall or safety warning.
Article 22(12) grounds marketplace-provider cooperation with recall and safety-warning communication; no broader DSA recall duty is asserted here.
directly notifying all affected consumers
Keep recall notice content, direct-consumer notification evidence, remedy information, listing history, and marketplace customer-data decisions in the same case record.
For compliance with Article 23, Article 22(11) requires marketplaces to suspend, for a reasonable period and after a prior warning, traders that frequently offer products non-compliant with the GPSR. The assessment must be case-specific, proportionate, and objective.
Article 22(11) grounds service suspension for traders that frequently offer products non-compliant with GPSR.
frequently offer products which are non-compliant
Article 23 supplies the suspension framework and requires case-by-case assessment of relevant facts and circumstances. identifies frequent GPSR product non-compliance as the conduct to which that framework applies here.
DSA Article 23 establishes suspension after prior warning and a case-by-case, proportionate and objective assessment; GPSR Article 22(11) applies it to traders that frequently offer GPSR-non-compliant products.
Build a trader history file with warnings, non-compliant listings, evidence of repeat conduct, suspension decision, duration, and reinstatement criteria.
and the -referenced marketplace rules often use the same listing, notice, trader, and order record, so the record should avoid splitting one incident into two disconnected evidence sets.
GPSR Article 22 ties marketplace duties to product-safety duties for listings, orders, notices, recalls, and repeated non-compliance.
providers of online marketplaces shall
The references in Article 22 are only there to run the marketplace process around a product-safety problem, not to turn the matter into a full DSA compliance review.
If the immediate question is whether the product is safe, dangerous, recalled, or reportable, anchor the case in and treat the marketplace steps as support work.
Grounds the GPSR focus on safe consumer products, dangerous products, recalls, safety warnings, accident reporting, and marketplace duties.
place only safe products on the market
If the immediate question is how the platform should process the listing, notice, order, or trader account, apply the Article 22 marketplace track but keep the scope on product safety.
Supports keeping dangerous-product, accident, traceability, corrective-action, and online-offer evidence attached to the GPSR case.
dangerous products
Scope boundary
GPSR
asks whether a consumer product made available on the EU market is safe, dangerous, non-compliant, recalled, withdrawn, or subject to a safety warning or accident report.
Grounds the GPSR focus on safe consumer products, dangerous products, recalls, safety warnings, accident reporting, and marketplace duties.
place only safe products on the market
DSA marketplace touchpoints
The -referenced marketplace question is narrower: whether the online platform process for product-safety orders, notices, listing information, trader commitments, or repeated non-compliance has been triggered.
GPSR Article 22 references selected DSA mechanisms for marketplace contact points, orders, notices, listing information, trader self-certification, and trader suspension.
in accordance with Article 16 of Regulation (EU) 2022/2065
Operational implication
Open the case under when the fact pattern is a product-safety risk; add the -referenced marketplace track only for the platform process that handles the offer.
Supports separating the product-safety determination from the marketplace process that handles the online offer.
as regards product safety
Authority orders
GPSR
gives market-surveillance authorities a product-safety route to require removal of content for an offer of a dangerous product, disabling access to it, or displaying an explicit warning. The marketplace must act without undue delay and in any event within two working days of receiving the order, then inform the issuing authority electronically of the effect given to it.
Supports retaining offer URL, unique identifier, marketplace provider name, corrective measure, and recall link evidence.
the URL of the offer and its unique identifier
Listing design and trader information
GPSR
requires marketplace interfaces to let traders provide specified product-safety information for each offered product and to display it or make it easily accessible to consumers on the listing.
Article 22(9) grounds marketplace interface design for product-safety information that traders provide and consumers can see or easily access.
displayed or otherwise made easily accessible
DSA marketplace touchpoints
The supplies two related controls. Article 31 requires marketplaces to design their interfaces so traders can provide Article 30 information, and Article 22(9) adds the product-safety fields. GPSR Article 22(10) separately requires the trader's DSA Article 30(1) self-certification before the offer is published.
DSA Articles 30 and 31 establish trader traceability, self-certification, and marketplace interface-design duties; GPSR Article 22(9) and (10) add the product-safety use of those controls.
Operational implication
Listing QA should test product-safety fields, trader information, product identifiers, warnings, and displayed accessibility before the listing goes live.
Supports retaining listing-level identifiers and traceability evidence where products are or have been sold online.
traceability information
Product-safety notices
GPSR
says marketplace providers must process notices related to product-safety issues for products offered online without undue delay and in any event within three working days of receipt.
Article 22(8) supplies the GPSR processing clock for product-safety notices received by online marketplaces.
within three working days
DSA marketplace touchpoints
The touchpoint is the notice channel: identifies notices received in accordance with DSA Article 16, but the deadline stated here comes from GPSR Article 22(8).
Supports recording the notice receipt, product-safety issue, and timely marketplace processing action.
notices related to product safety issues
Evidence record
GPSR
evidence can include accident information, dangerous-product notifications, Safety Business Gateway submissions, Safety Gate follow-up, and corrective measures such as withdrawal, recall, or online-content removal.
Grounds accident, risk, traceability, corrective-measure, recall-link, and Safety Business Gateway reference fields.
information on reported accidents
DSA marketplace touchpoints
The -referenced marketplace evidence is the platform trail around the offer: listing identifiers, provider name, notices, orders, removals, warnings, trader suspension, and consumer communications.
Article 22 grounds marketplace records for product-safety notices, orders, listings, trader suspension, recalls, and consumer safety warnings.
providers of online marketplaces shall
Operational implication
Do not rely on a takedown ticket alone. Pair it with product-risk evidence, accident or incident facts, notification status, and recall or corrective-action records.
Supports tying the marketplace trail to risk and corrective-action evidence rather than treating removal as the whole file.
corrective measures
Consumer recall notifications
GPSR
requires affected consumers who can be identified to be notified directly and without undue delay in product safety recalls or safety warnings, including marketplace-provider duties under Article 22(12).
Grounds recall notice structure and online recall notice requirements.
Product safety recall
DSA marketplace touchpoints
The touchpoint does not supersede the recall file. The marketplace record should show how the platform used buyer data, listing records, and consumer-contact paths to support the GPSR recall or safety warning.
Article 22(12) grounds marketplace-provider cooperation with recall and safety-warning communication; no broader DSA recall duty is asserted here.
directly notifying all affected consumers
Operational implication
Keep recall notice content, direct-consumer notification evidence, remedy information, listing history, and marketplace customer-data decisions in the same case record.
For compliance with Article 23, Article 22(11) requires marketplaces to suspend, for a reasonable period and after a prior warning, traders that frequently offer products non-compliant with the GPSR. The assessment must be case-specific, proportionate, and objective.
Article 22(11) grounds service suspension for traders that frequently offer products non-compliant with GPSR.
frequently offer products which are non-compliant
DSA marketplace touchpoints
Article 23 supplies the suspension framework and requires case-by-case assessment of relevant facts and circumstances. identifies frequent GPSR product non-compliance as the conduct to which that framework applies here.
DSA Article 23 establishes suspension after prior warning and a case-by-case, proportionate and objective assessment; GPSR Article 22(11) applies it to traders that frequently offer GPSR-non-compliant products.
Operational implication
Build a trader history file with warnings, non-compliant listings, evidence of repeat conduct, suspension decision, duration, and reinstatement criteria.
Supports retaining warning, suspension, duration, and repeated-non-compliance evidence for marketplace governance.
after having issued a prior warning
Overlap and reuse
GPSR
and the -referenced marketplace rules often use the same listing, notice, trader, and order record, so the record should avoid splitting one incident into two disconnected evidence sets.
GPSR Article 22 ties marketplace duties to product-safety duties for listings, orders, notices, recalls, and repeated non-compliance.
providers of online marketplaces shall
DSA marketplace touchpoints
The references in Article 22 are only there to run the marketplace process around a product-safety problem, not to turn the matter into a full DSA compliance review.
Supports separating the product-safety determination from the marketplace process that handles the online offer.
as regards product safety
Practical decision rule
GPSR
If the immediate question is whether the product is safe, dangerous, recalled, or reportable, anchor the case in and treat the marketplace steps as support work.
Grounds the GPSR focus on safe consumer products, dangerous products, recalls, safety warnings, accident reporting, and marketplace duties.
place only safe products on the market
DSA marketplace touchpoints
If the immediate question is how the platform should process the listing, notice, order, or trader account, apply the Article 22 marketplace track but keep the scope on product safety.
Supports keeping dangerous-product, accident, traceability, corrective-action, and online-offer evidence attached to the GPSR case.
dangerous products
Practical decision rule
How should teams decide which duty owns the next action?
If the question is whether the product is dangerous, recalled, reportable, or safe to keep available, treat as the controlling track.
If the next step is a product-safety order, notice, listing-field fix, trader self-certification, or repeated non-compliant trader action, run the Article 22 marketplace track and keep the reference narrow.
For recommender systems, advertising, systemic risk, or transparency reporting, open a separate review using the provisions that apply to the service.
Supports keeping dangerous-product, accident, traceability, corrective-action, and online-offer evidence attached to the GPSR case.
dangerous products
1
Section 1
Where GPSR and DSA marketplace duties meet
The starts from consumer product safety: only safe products may be made available on the EU market, and providers of online marketplaces have specific product-safety duties when products are offered through their services.
Article 22 expressly connects to Articles 9, 11, 12, 16, 23, 30 and 31. Those cross-references cover authority orders, contact points, notices, trader traceability and self-certification, interface design, and suspension. The DSA still applies on its own terms, including duties outside product safety; this page does not assess those wider duties.
Use for the product-safety judgment: dangerous product, risk information, corrective action, recall, safety warning, Safety Business Gateway, and Safety Gate Portal evidence.
Use the references only where Article 22 invokes them for online marketplace operation: orders, notices, listing information, trader traceability, and repeated non-compliance.
Keep one evidence index, but tag every record as -only, -referenced-by-GPSR, or shared because the same listing, notice, or trader record supports both.
Explains the interoperable interface that marketplace providers may use after Safety Gate Portal registration to obtain information about measures against dangerous products.
providers of online marketplaces may link their interfaces
Binding DSA source for the order, contact-point, notice-and-action, suspension, trader-traceability, self-certification, and compliance-by-design provisions that GPSR Article 22 cross-references.
2
Section 2
Evidence to keep when a marketplace listing becomes a product-safety issue
For a dangerous-product matter, the case file should show the product identifier, offer URL, unique listing identifier where available, trader and marketplace information, risk basis, notice or order received, content action taken, consumer communication, recall notice, accident information, and any Safety Business Gateway or Safety Gate follow-up.
records should also show why the product was treated as dangerous or non-compliant. The delegated Safety Gate rules reference product identification, traceability information, offer URL and unique identifier, marketplace provider name, risk description, accidents or incidents, corrective measures, and links to recall notices where available.
Capture screenshots or exports of the online interface before and after removal, disabling, warning display, or listing correction.
Keep the notice, order, trader communication, internal triage note, product-risk evidence, and timestamped action log together.
When recall or safety-warning duties are triggered, retain the direct-consumer notification plan, recall notice text, remedies offered, and any customer-data use decision.
Provides the EU recall-notice template and instructions for machine-readable online recall information, hazard description, consumer action, remedies, and contact details.
Product safety recall
Recommended next step
Separate product-safety and marketplace evidence
Turn dangerous-product listings, takedown orders, recall notices, accident reports, and marketplace evidence into a traceable GPSR workflow with cited DSA touchpoints.
Operating rule for takedown, listing, recall, and incident workflows
Treat each case as two linked tracks. The track decides whether the consumer product is dangerous or non-compliant, what corrective action is needed, whether consumers must be warned or recalled, and whether Safety Business Gateway or Safety Gate records are needed. The marketplace track implements the online-interface action and preserves the listing, notice, order, trader, and consumer-notification evidence.
Do not generalize beyond the provisions cited here. For recommender-system transparency, advertising, systemic risk, or wider DSA governance, use DSA-specific sources.
For listings: require product-safety and traceability fields that Article 22 says marketplaces must enable and display or make easily accessible to consumers.
For takedown: record whether the action came from a market-surveillance order, a Article 16 notice concerning product safety, the marketplace's own Article 22 monitoring, voluntary removal, or a recall or withdrawal decision.
For recalls and accidents: keep product identification, hazard, consumer action, remedy, marketplace notification, Safety Business Gateway submission, and any follow-up authority communication in one case record.
For authority orders, act without undue delay and within two working days of receipt; for product-safety notices through the Article 16 mechanism, process without undue delay and within three working days. Record the receipt and action times for the applicable clock.
Supports the risk and notification evidence model for dangerous products, corrective measures, traceability, accidents, and Safety Business Gateway references.
Grounds evidence fields for dangerous-product notifications, including traceability, offer URL, unique identifier, marketplace provider name, accident information, corrective measures, and recall notice links.
Supports the risk and notification evidence model for dangerous products, corrective measures, traceability, accidents, and Safety Business Gateway references.
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Supports retaining offer URL, unique identifier, marketplace provider name, corrective measure, and recall link evidence.
Supports retaining listing-level identifiers and traceability evidence where products are or have been sold online.
Grounds accident, risk, traceability, corrective-measure, recall-link, and Safety Business Gateway reference fields.
Supports tying the marketplace trail to risk and corrective-action evidence rather than treating removal as the whole file.
Supports keeping dangerous-product, accident, traceability, corrective-action, and online-offer evidence attached to the GPSR case.
Source for recall-notice template requirements, including product identification, hazard description, consumer action, remedies, contact details, and machine-readable online information.
Provides the EU recall-notice template and instructions for machine-readable online recall information, hazard description, consumer action, remedies, and contact details.
Grounds recall notice structure and online recall notice requirements.
Binding DSA text for Articles 9, 11, 12, 16, 23, 30, and 31, which GPSR Article 22 uses for marketplace orders, contact points, notices, suspension, trader traceability, self-certification, and interface design.
Binding DSA source for the order, contact-point, notice-and-action, suspension, trader-traceability, self-certification, and compliance-by-design provisions that GPSR Article 22 cross-references.
DSA Articles 30 and 31 establish trader traceability, self-certification, and marketplace interface-design duties; GPSR Article 22(9) and (10) add the product-safety use of those controls.
Show 1 more
DSA Article 23 establishes suspension after prior warning and a case-by-case, proportionate and objective assessment; GPSR Article 22(11) applies it to traders that frequently offer GPSR-non-compliant products.
Source for the Safety Gate Portal interoperable interface that marketplace providers may use after registration.
Explains the interoperable interface that marketplace providers may use after Safety Gate Portal registration to obtain information about measures against dangerous products.
"providers of online marketplaces may link their interfaces"