EU GPSR Imported Products

Article 11 requires the importer to verify, before placing the product on the market, that the product complies with the GPSR general safety requirement and that the manufacturer has complied with Article 9(2), (5) and (6). If the importer has reason to believe the product is not compliant, the product should not be placed on the market until the issue is corrected.

For products from outside the Union, also document the Article 16 responsible-person position. The GPSR says a covered product may not be placed on the market unless an economic operator established in the Union is responsible for the Article 4 support tasks, and Article 16 adds checks against the GPSR technical-documentation and product-information requirements where appropriate for the product risk.

The importer does not supersede the manufacturer's GPSR technical file, but Article 11 requires the importer to keep a copy of the Article 9 technical documentation available to market surveillance authorities for 10 years after the importer places the product on the market. The file should therefore be controlled as release evidence, not treated as a supplier promise.

Traceability evidence should let the importer answer an authority request without rebuilding the supply chain from emails. Article 15 requires economic operators to identify who supplied the product or relevant parts, components, or embedded software, and who they supplied the product to; the GPSR also sets time periods for presenting risk and traceability information.

GPSR distance-sale rules apply when the online or distance offer is targeted at consumers in the Union. Article 19 requires the offer to clearly and visibly show manufacturer contact details, the responsible person when the manufacturer is not established in the Union, product identification including a picture, type and other identifier, and required warning or safety information in the relevant consumer language.

For imported products sold through marketplaces or direct ecommerce, the release checklist should therefore include page-level evidence. Capture the live product page, product identifiers, safety warnings, responsible-person details, language variants, seller account, marketplace interface, and the unique offer URL used for monitoring or later takedown.

When an importer has reason to believe a product it placed on the market is dangerous, Article 11 requires immediate escalation: inform the manufacturer, ensure corrective measures are taken or take them directly, inform consumers under the GPSR recall or safety-warning rules, and inform the relevant Member State market surveillance authorities through the Safety Business Gateway.

Accident handling has a separate trigger. Importers and distributors that know of an accident caused by a product they placed or made available on the market must inform the manufacturer without undue delay; if the non-EU manufacturer is not established in the Union, the Article 16 responsible person or Article 4 responsible person with knowledge of the accident must ensure the notification is made.