| Scope boundary | GPSR Article 16 says a GPSR-covered product cannot be placed on the market unless an EU-established economic operator is responsible for the Article 4(3) tasks from Regulation (EU) 2019/1020. GPSR also adds product-safety checks against GPSR technical documentation and information duties, plus documented evidence for authority requests. | Regulation (EU) 2019/1020 Article 4 applies to specified Union harmonisation legislation and identifies the EU manufacturer, importer, authorised representative, or fulfilment service provider that must keep declarations or technical documentation available, answer authority requests, report product risks, and cooperate on corrective action. | For GPSR products, keep the Article 16 responsible-person record with the consumer-safety file. For harmonised products, keep the Article 4 record separate unless the sector law says otherwise. |
|---|
| Covered actors | GPSR Article 23 applies specified market-surveillance provisions from Regulation (EU) 2019/1020 to GPSR-covered products, with references read as references to the GPSR. GPSR also lets authorities request manufacturer information on other products from the same procedure, components, or batch when a dangerous product is identified. | Regulation (EU) 2019/1020 requires market surveillance authorities to perform documentary, physical, and laboratory checks using a risk-based approach, including hazards, operator history, complaints, and other information that may indicate non-compliance. | Use the GPSR side for dangerous-product follow-up and the Regulation (EU) 2019/1020 side for risk-based checks. Keep batch and component references on both sides so authorities can trace related products quickly. |
|---|
| Trigger | GPSR requires operators and online marketplaces to hold and transmit product-safety evidence, including Article 16 documented checks, Article 19 distance-sales information, Article 20 accident notifications, and Article 22 marketplace cooperation and Safety Business Gateway information. | Regulation (EU) 2019/1020 Article 4 requires the responsible economic operator to provide information and documentation necessary to demonstrate conformity after a reasoned authority request, and Article 11 requires authorities to take due account of accredited test reports or certificates. | Keep a source-tagged evidence index rather than one generic compliance pack. Separate GPSR safety evidence from conformity evidence, then cross-reference test reports, certificates, product identifiers, and authority replies that support both. |
|---|
| Core obligations | GPSR uses dangerous-product handling for consumer products: accident notification, marketplace reporting, Safety Gate/Safety Business Gateway flows, authority cooperation, and a presumption that products deemed dangerous by one Member State authority are presumed dangerous by authorities in other Member States. | Regulation (EU) 2019/1020 distinguishes products presenting a risk and products presenting a serious risk. For serious-risk products, authorities must ensure withdrawal or recall where no other effective means can eliminate the serious risk, or prohibit availability, and notify the Commission immediately. | If the issue is consumer harm or a recall notice, use GPSR. If the issue is a market-surveillance serious-risk action or a control order, use Regulation (EU) 2019/1020. |
|---|
| Evidence record | GPSR sets the consumer-facing recall workflow: direct notification without undue delay where affected consumers can be identified, clear and visible recall notices where they cannot all be contacted, required recall-notice content, and remedies such as repair, replacement, or refund. | Regulation (EU) 2019/1020 treats recall as a market-surveillance measure and gives authorities power to order withdrawal or recall when corrective action fails or a serious risk remains. It does not supply the GPSR consumer-remedy structure. | Use GPSR for the recall notice and consumer remedy package, and use Regulation (EU) 2019/1020 for the authority-control record showing why withdrawal, recall, prohibition, or corrective action was required. |
|---|
| Timing and deadlines | GPSR uses the Safety Gate Rapid Alert System, Safety Gate Portal, and Safety Business Gateway for dangerous-product notifications, public information, marketplace interfaces, and economic-operator or marketplace submissions. | Regulation (EU) 2019/1020 designates market surveillance authorities, single liaison offices, the information and communication system for enforcement data, and authorities for controls on products entering the Union market. | Route messages by system and audience: Safety Business Gateway for GPSR dangerous-product and accident submissions, Safety Gate for rapid-alert/public information workflows, and Regulation (EU) 2019/1020 channels for market-surveillance and border-control cooperation. |
|---|
| Enforcement | GPSR Article 16 requires an EU-established economic operator for GPSR-covered products and adds regular checks that the product matches the GPSR technical documentation and the GPSR information duties. | Regulation (EU) 2019/1020 Article 4 applies to specified Union harmonisation legislation and identifies the EU manufacturer, importer, authorised representative, or fulfilment service provider that must keep declarations or technical documentation available, answer authority requests, report product risks, and cooperate on corrective action. | Use GPSR Article 16 to establish the product's EU responsible person and use Article 4 of Regulation (EU) 2019/1020 to preserve the broader conformity file. |
|---|
| Overlap and reuse | GPSR Article 23 applies specified market-surveillance provisions from Regulation (EU) 2019/1020 to GPSR-covered products, with references read as references to the GPSR. GPSR also lets authorities request manufacturer information on other products from the same procedure, components, or batch when a dangerous product is identified. | Regulation (EU) 2019/1020 Article 4 applies to specified Union harmonisation legislation and identifies the EU manufacturer, importer, authorised representative, or fulfilment service provider that must keep declarations or technical documentation available, answer authority requests, report product risks, and cooperate on corrective action. | Use the overlap to reuse contact details, batch logic, and authority correspondence, but keep the GPSR dangerous-product file distinct from the Article 4 conformity file. |
|---|
| Practical decision rule | GPSR Article 16 requires an EU-established economic operator for GPSR-covered products and adds regular checks that the product matches the GPSR technical documentation and the GPSR information duties. | Regulation (EU) 2019/1020 Article 4 applies to specified Union harmonisation legislation and identifies the EU manufacturer, importer, authorised representative, or fulfilment service provider that must keep declarations or technical documentation available, answer authority requests, report product risks, and cooperate on corrective action. | Use GPSR for consumer-safety decisions and use Regulation (EU) 2019/1020 for harmonised-product conformity decisions. Where both apply, keep the records separate and cross-reference them. |
|---|