Start the release by identifying the exact product version that will appear online: model, variant, bundle contents, software or firmware state, age or user limitations, EU countries of sale, seller role, and whether another Union product regime adds more specific rules. An online offer falls within the GPSR rule when the economic operator directs its activities to consumers in one or more Member States; dispatch areas, languages, ordering flow, payment methods, currency, and Member State domain names can show targeting, while mere website accessibility is insufficient. A product covered by the GPSR also needs an economic operator established in the Union to perform the Article 16 tasks before it is placed on the Union market.
The GPSR covers consumer products and products likely to be used by consumers under reasonably foreseeable conditions, including new, used, repaired, and reconditioned products. Article 2 excludes listed categories and limits the GPSR where another EU rule regulates the same safety objective. Record the product-specific law, relevant risk, and resulting GPSR provisions before release. For products subject to Union harmonisation legislation, Chapter III Section 1, including Articles 9 to 18, does not apply. Use the sector-law documentation and responsible-operator requirements for those products rather than treating the GPSR evidence gate below as an additional manufacturer obligation.
Reopen scope and role review when a new supplier, component, software function, private-label brand, bundle, or safety-relevant modification changes the product facts. Where Article 13 applies, own-brand placing creates manufacturer duties. A modification must affect safety and meet all three criteria: the initial risk assessment did not foresee it; the hazard changes, a new hazard arises, or risk increases; and it was not made by consumers or on their behalf for their own use. Duties cover the affected part, or the whole product if overall safety is affected.