Many online sellers found themselves facing an unpleasant shock in late 2024 when their listings were removed from EU marketplaces or were received by email with a demand for an ‘EU Responsible Person’ and safety documentation of which they had never heard. This was due to the General Product Safety Regulation — GPSR — which came into full effect on 13 December 2024 and thus became one of the major changes to EU rules concerning consumer products in the past twenty years.
The subsequent coverage mostly regarded GPSR as a legal or listing issue—things like new information requirements, the need for a mandatory EU representative, and the completion of marketplace compliance fields. Much less attention was paid to the operational aspect—and for a brand selling into the EU from outside the region, it is in this area that GPSR has a real impact. The regulation lists fulfilment service providers as economic operators, links compliance to labelling and traceability which take place in the warehouse, and makes the selection of the fulfilment partner an integral part of the compliance process rather than something separate from it.
The guide looks at GPSR from an operational point of view by explaining what the regulation demands, why it is important in particular for brands that produce outside the EU—such as those in Turkey—and how it affects fulfilment and the choice of partners. Enforcement is now no longer just a matter of theory: in 2025 the European Commission recorded a record number of 4,671 Safety Gate alerts, a 13% increase compared with the previous year, together with a 35% rise in recalls, withdrawals and marketplace delistings.
Note that this should be regarded as a general, operationally oriented summary and is not intended as legal advice. If you want a binding assessment of your case—especially concerning the Responsible Person role and the labeling requirements—you should seek advice from a qualified lawyer or turn to a specialist compliance provider.
Table of Contents
What GPSR Is — and Why It’s More Than a Legal Topic
The GPSR (Regulation (EU) 2023/988) has taken the place of the previous General Product Safety Directive of 2001 and covers almost all consumer products that are neither food nor cosmetics and which are sold to consumers in the EU, provided that they are not entirely covered by specific EU legislation for that sector. Since it is a regulation and not a directive, it is in force directly in all member states without the need for national transposition and comes into effect by the deadline of December 2024.
The basic principle is one of safety: economic operators are permitted to put only safe consumer products on the EU market. Although that may seem obvious, the regulation links this principle to a series of specific and recordable duties which are shared out among all the parties in the supply chain. It is at this point that a legal issue turns into an operational one: a significant portion of these duties—such as labeling, traceability, storage conditions, and being ready for recall—are not carried out at an office but rather in the warehouse and during the dispatch process.
The directive in question came before the age of market-place-driven, cross-border, direct-to-consumer commerce. GPSR was designed specifically with that situation in mind – one in which a seller, a platform, a manufacturer, and a fulfilment provider could each be based in a different country – since it is because of this that it covers the operational parties that the earlier rules had not dealt with.
The Term That Matters: Economic Operator — and Why Fulfillment Providers Are One
The term economic operator is used by GPSR and specifically covers the manufacturer, the authorized representative, the importer, the distributor, and — by name — the fulfillment service provider. This implies that a logistics partner is, for the first time, not just an executing vendor but also a party who has to meet product safety obligations themselves.
The implications of this classification go beyond the agreement between the brand and its fulfillment partner. A fulfillment provider which carries out storage, packing, labelling and shipping of products has, under GPSR, shared responsibility for such products where the requirements are met — for example, regarding labelling and traceability. This is analogous to the position that electronics fulfilment providers currently hold under the WEEE producer responsibility rules: in that case, the logistics partner becomes a control point in the compliance chain rather than simply a point at which the goods change hands.
For brands the meaning is clear: under GPSR selecting a fulfilment partner involves making a compliance choice. If a partner is familiar with the GPSR requirements and takes active steps to meet them, it reduces the brand’s compliance risk. On the other hand, if a partner ignores those requirements it passes the risk back to the brand—typically in an invisible way—until a market surveillance authority or a marketplace compliance team makes the problem visible.
The Requirement That Hits Non-EU Brands First: The EU Responsible Person
For brands which are based outside the EU – for example, in Turkey – one of the requirements under the GPSR is essential in that each product must have an economic operator based in the EU appointed as its ‘Responsible Person’; otherwise the product will not be able to be placed on the EU market. The Commission’s guidance of November 2025 on this point was clear – there is no way around it and no grace period.
The Responsible Person (as provided for in Article 16) may be an EU-based manufacturer, an EU-based importer, an EU-authorized representative, or—when all else has failed—an EU-established fulfilment service provider if no other economic operator has a presence in the EU. The duties which are then assumed by this entity include holding the technical and conformity documentation, acting as the point of contact for the market surveillance authorities, ensuring that the product has the required labelling, and working together on any corrective actions or recalls. According to Commission guidance, this responsibility must be a genuine one involving access to the compliance documentation—rather than simply having a postal address.
Turkish companies will see the same structure: it is similar to the obligation for authorised representatives in the case of electronics under WEEE/ElektroG. A brand that is selling from Turkey into the EU but does not have its own establishment in the EU must appoint a Responsible Person for product safety, just as it must have a WEEE representative for electrical goods. In both cases the roles are a necessary condition for the product being legally placed on the market.
An important point regarding operations is that the Responsible Person’s contact information (including their name, postal address and email address) must be printed on the product, on the packaging, on the parcel, or in the accompanying documents—and the details of the manufacturer/’Responsible Person’ also have to be clearly visible in the online listing. This requirement is not optional and the marketplaces check it actively.
Why Marketplaces Enforce GPSR Faster Than Regulators
For most brands, the very first interaction with GPSR does not take place with a regulator but through a marketplace. According to Article 22, online marketplaces have their own duties, namely registering with the Safety Gate portal, designating a contact point, removing dangerous listings when instructed within two working days, and making sure that the sellers’ listings include the traceability information required by the regulation. By the end of 2025 over 1,200 marketplaces had registered on the Safety Gate portal.
The result in practice is that the compliance teams within the marketplace are now carrying out GPSR enforcement more quickly than the regulatory authorities do: a listing that fails to include its Responsible Person information or safety details is suspended long before a regulator even gets involved. Amazon has already taken down non-compliant listings from its EU marketplaces, and the optional compliance-support programme that it previously provided was discontinued in 2024 – thus the responsibility now entirely lies with the seller. For a brand, a suspended listing means an immediate halt to revenue, regardless of any fine or formal action.
That’s the reason why GPSR compliance should not be approached as a slow-moving legal exercise. As compliance professionals point out, it’s never actually carrying out the safety work; instead, they merely locate the documents when the market suddenly calls for a risk assessment or a Declaration of Conformity.
The Information and Labeling Obligations
All product listings that are seen by consumers in the EU must clearly and prominently display: the manufacturer’s name, the registered trade name or trademark, and the manufacturer’s postal and email addresses; in the case where the manufacturer is outside the EU, the name, postal address, and email address of the EU Responsible Person; the product identification information, including an image, the type and any other identifiers; and all any warnings or safety information — all in a language that is easily understandable to consumers in the member state in which the product is sold, a language which that state decides.
There is an operational aspect associated with that last point which is often overlooked. Warnings, safety information, and where appropriate instructions must be in the language of the target market; for Germany this means German and for France it means French. Labeling which is adequate for the brand’s home market or for one country in the EU does not automatically meet the language requirements of another country.
It is at this point that GPSR compliance shifts from the listing stage to the warehouse stage: in so far as a product has to have a warning label or instruction leaflet in the relevant language, this becomes an issue for inbound inspection and, where necessary, for re-labeling at the distribution centre — something that is a part of the fulfilment process and not a legal requirement.
Where GPSR Compliance Becomes a Fulfillment Process
GPSR is mostly talked about in public in terms of listing and labeling, and it has a direct impact on several key fulfillment processes in practice.
Inbound inspection is the very first point at which compliance is checked. Does the incoming stock have the correct labelling? Is the warning or instruction in the relevant language included? Are the product identifiers required for traceability recorded? A fulfilment partner that incorporates this check into the receiving process picks up any compliance gaps before the products are sold — rather than after the fact, when the only remedy would be to recall the already shipped units.
Traceability is a key point in the GPSR requirements: products have to be given identifying information so that the relevant authorities and sellers are able to track the items through the supply chain and remove them swiftly should a safety problem arise. In reality, the fulfilment operation has to be capable of recording and linking batch or product identifiers — a feature which a modern WMS provides, but one that must be set up and put into use. It is essential that traceability exists if a precise recall is to take place.
It is in the area of recall readiness that GPSR has the most significant operational impact. The regulation enhances the rights of consumers during a recall since a recall notice cannot simply be a general “please stop using this” and consumers are entitled to have their products repaired, replaced or refunded. For the fulfilment operation this involves knowing which batch was sent to which location, having the ability to quickly freeze the relevant stock in the warehouse, and providing operational support for the reverse process. A recall is only to a limited extent a legal procedure; mainly it is a warehouse and logistics operation.
The conditions for storage and transport are also included: when a product is under the care of an economic operator, its safety must be maintained by means of proper storage and handling – this is a specific requirement in the case of temperature-sensitive or otherwise susceptible goods.
“But I Already Have a CE Mark” — A Common Misunderstanding
A common source of misunderstanding is the idea that if a company has products with the CE mark then it is protected. This is generally not the case, at least not completely. The CE marking indicates that a product meets the requirements set out in particular EU directives which apply to it—such as those relating to electronics, machinery, and toys, for example. GPSR forms the general safety baseline, which applies either in addition to or in place of the sector-specific rules. A Bluetooth speaker that has the CE mark complies with the technical safety requirements set out in its sector’s directives, but it is still subject to GPSR-type obligations—including traceability, the appointment of a Responsible Person, the preparation of a risk file, and the provision of safety information to consumers.
For the Turkish electronics company, GPSR should be seen as complementary to the CE and WEEE obligations which are already discussed in our guide on electronics fulfilment and EU compliance from Turkey, not as an alternative to them. The various requirements apply one after another; fulfilling one does not release the company from the others.
What This Means Concretely for Turkish Brands Selling into Europe
For brands that sell products from Turkey into Germany and the wider EU there is already in place a framework covering compliance requirements. A brand dealing in electronics is already familiar with its obligations under WEEE/ElektroG and with the representative role; a brand bringing packaged goods onto the market is aware of its packaging-registration responsibilities. The GPSR introduces a product-safety requirement which applies to almost all consumer products – not merely to those in the regulated special categories.
The core action points:
You must appoint an EU Responsible Person; otherwise the product cannot be marketed. This arrangement has to be made before selling, not when a regulatory authority or a marketplace requests it.
Prepare target-market labeling. Warnings, safety information, and instructions in the target market’s language. Home-market labeling doesn’t automatically qualify.
Complete listing information. Manufacturer and Responsible Person contact details, product identifiers, and warnings must be visible in the online listing.
Ensure traceability and recall readiness. The fulfillment operation must capture batch/identifier data and be able to act in a recall.
Assess the fulfillment partner as a compliance factor. Because the provider is itself an economic operator, its GPSR competence is part of partner evaluation.
The similarity with the obligations that are already in place is the positive aspect: a brand which has arranged its WEEE, packaging, and CE procedures through a competent fulfillment partner has the necessary organizational basis to take on GPSR as well. The various regimes are interlinked — and a partner who has a full understanding of the situation is much more valuable to a company outside the EU than one that provides only warehouse space and fast shipping.
What to Look for in a Fulfillment Partner Under GPSR
Since the fulfillment provider is an economic operator covered by the GPSR, its compliance capability should be included on the evaluation checklist. The specific questions are:
How does the partner incorporate GPSR-related checks into the inbound process—has it been verified that the products have the necessary labelling and warnings in the relevant language? Can the warehouse management system record the batch and product identifiers for traceability? What are the procedures during a recall—can the affected stock be frozen rapidly and the reverse flow managed? And does the partner assist non-EU brands in understanding their responsibilities as Responsible Persons and the labelling requirements, or does it leave that entirely to the brands?
A fulfillment partner who is well acquainted with the various regulatory regimes — namely GPSR, WEEE/ElektroG, packaging registration, and CE — and who actively brings up these issues eliminates a large portion of the compliance workload. One that has physical facilities in the destination market and experience in the trade route from Turkey to Europe is in a better position in this situation since it understands the destination market’s requirements on the basis of everyday experience rather than merely referring to a checklist. This is the same dual-market capability that forms the basis for setting up fulfillment infrastructure from Turkey into Europe.
Conclusion: GPSR Makes the Fulfillment Partner a Compliance Factor
The EU Product Safety Regulation has come into public awareness in the context of labeling and listing — yet its actual impact extends beyond this. Since it refers to fulfillment service providers as economic operators with their own responsibilities, it incorporates logistics into the requirements for product safety. As a result, inbound inspection, traceability, recall readiness, and labeling are no longer just legal issues; they have become warehouse procedures.
For Turkish brands selling into Europe, GPSR joins the familiar stack — WEEE, packaging, CE — and demands above all an EU-established Responsible Person and correct target-market labeling. With enforcement now real and rising — record Safety Gate alerts, marketplace delistings up sharply — the cost of ignoring it has moved from theoretical to immediate. A brand that sets these requirements up with a fulfillment partner fluent in the interlocking regimes turns a compliance hurdle into a documented, manageable process — and avoids the delistings, fines, and suspensions that non-compliance now reliably triggers.
